When safety management systems were implemented—and they've been implemented in rail, marine, and aviation in Canada—they were never ever intended to replace regulation. They were always intended to be an additional layer of oversight within a company because, at the end of the day, you can never have a regulation for every possible situation, and you can never have an inspector overseeing every possible action. At the end of the day, the companies must be responsible for identifying hazards and managing their operational risks, but you need a strong, effective regulator when a company can't do that or doesn't want to do that.
It's not a question of a safety management system or regulation; it's really how they work together. Ideally, a company has an effective way of managing its risks. The regulator is there to oversee and make sure that is doing it, that there is at least a common baseline of regulation that applies to everybody, and that they all work together.
With respect to fatigue in particular, we see fatigue as a hazard in any 24-7 transportation system. We always investigate for it. When we identify it and identify it as a contributing factor, we say that in our reports. There are fatigue regulations that apply to the rail industry. They may need to be revised and updated, but they do have some. At the end of the day, it's also up to companies and bargaining agents to work together and not to allow scheduling practices into collective agreements that are counterproductive from a human fatigue perspective.