Safety management systems are meant to be an additional layer of safety. They're supposed to be an additional layer as a tool for our inspectors to have in their tool box. Transport Canada is not applying them that way; it is making them the main focus of monitoring safety. For years now, we've been calling on Transport to do a review of the safety management systems. What we see is that Transport is devolving its responsibility more to private operators, rather than focusing on prevention, safety and what is dangerous through the SMS inspections. I'm not sure if that makes sense to you.
Transport Canada has been moving towards using audits, but audits only reveal what went wrong; they don't prevent accidents or incidents. Again, safety management is supposed to be there as a tool for our inspectors, to help the companies, not to be the only thing companies rely on.
We'd like to see more random and unannounced inspections of rail companies, operations and equipment, and the hiring of more rail inspectors to ensure compliance with outlined policies and procedures. We feel that Transport Canada has really gone backwards in this regard, rather than forwards.
We would like Transport Canada to have a single, number one priority, and that is safety. It's the safe transport of goods across the country on our rail systems and the safest possible passenger train service in the world. Right now, they work under competing priorities, one of which appears to be reducing the regulatory burden on operators. For Transport to be focused on reducing regulations would appear to be a conflict of interest in terms of what their role as a regulator is.
I'm not sure if that helps.