Thank you, Madam Chair and members of the committee, for the opportunity to present the views of our members on aviation safety.
The Union of Canadian Transportation Employees is the national union for most employees at Transport Canada, the Transportation Safety Board, the Canadian Transportation Agency, and many of Canada's airports. This includes all inspectors at Transport Canada, except for the pilot inspectors in the civil aviation mode.
Our members play an important role in all aspects of aviation safety, including the collection and storage of reports, monitoring and inspection, and prevention and emergency services. They are literally the eyes and ears of Transport Canada, local airport authorities, and the agencies charged with aviation safety in this country. They are proud of the work that they do in protecting the travelling public. However, they have also shared some concerns with us.
They are concerned that either some things are not being done, or done properly, and that more can and should be done to better secure the safety of Canadians who travel by air. I'm here today to share their voices and ideas with you.
First of all, I want to note the themes that the committee has established for this review. In order to make use of the limited time that was offered, I want to highlight three main areas of concern that our members across the country have raised. They are Transport Canada's safety management system, SMS; airport firefighting services; and the roles, responsibilities, and workings of the Transportation Safety Board.
With regard to the safety management system, SMS, in our view there continues to be far too much regulatory reliance on SMS, which has turned many of our inspectors into program auditors. It is important to note that the concept of SMS is predicated on the philosophy that companies are compliant with the regulations before they adopt SMS. This is simply not the case for a large percentage of the companies in civil aviation.
We would like to point out that, where SMS is concerned, the United States takes a very different approach in comparison to Canada. It is far less reliant on SMS for regulatory oversight. They actually make a virtue out of whistle-blower protections, and even provide significant financial incentives for whistle-blowers. There should be a similar approach in Canada, with the creation of an independent office of whistle-blower protections where air transportation workers, both within and outside of the government, can report incidents without fear of reprisals.
Reliance on corporate SMS plans is creating a situation where the role of the inspector is to check corporate paperwork. If they leave the office to do an SMS audit, also called an assessment by the department, air operators must be given notice. In some instances the minimum notice period is 10 weeks. This gives the operator more than enough time to correct whatever deficiencies might have been present at the time the SMS audit originated. SMS audits continue to replace direct and unplanned inspections, as opposed to being an additional layer of safety.
Inspectors believe this is a grave mistake. Giving airlines primary responsibility for safety oversight is tantamount to putting the fox in charge of the henhouse. For a long time now, UCTE has gone on record stating that SMS must be an additional layer of safety, and that the audit or assessment function should be completely separate from the direct inspection.
Transport civil aviation inspectors are highly qualified industry specialists, many with aircraft maintenance, engineering, and other important credentials. Unfortunately, I'm not sure how much longer I will be able to assert these qualifications. To make matters worse, Transport Canada is mistakenly recruiting generalists for inspector positions, placing emphasis on soft skills such as interpersonal communications and being a team player, instead of industry qualifications, expertise, and knowledge. If the issue is safety, that has to change.
Now, I'll address airport firefighting services. Today, many airports across Canada are not prepared to effectively respond to an airport crash, where fire intervention is essential within the first few vital minutes after an airplane crashes and fire ignites. This is because Transport Canada regulations do not provide for firefighters to rescue passengers or extinguish fires inside an airplane. In the unfortunate event of aviation accidents at airports, the results are more devastating, and the loss of life would be far greater than necessary.
Transport Canada regulations also do not recognize many of the risk factors involved in the complex world of crash firefighting, including aircraft configuration, high numbers of passengers, fuel capacity, emergency medical needs, hazardous materials, and threats from terrorists.
The result of this policy is that hundreds of thousands of airline passengers and crew members face unnecessary dangers on the runways of many airports because emergency response capabilities fall below accepted worldwide standards.