On Final: The ‘new’ safety approach
By Neil J. MacDonald
In a recent article on the CBC website, Transport Canada (TC) is seemingly taken to task for its new safety approach of having airlines regulate themselves
By Neil J. MacDonald
In a recent article on the CBC website, Transport Canada (TC) is seemingly taken to task for its new safety approach of having airlines regulate themselves (see “Flight policy change called a risky manoeuvre,” Nov. 9, 2011, CBC.ca). In the article, experts warn such an approach could endanger passengers because without oversight, “people are going to do bad things.” Well, I have to disagree. With or without proper oversight, there are people who will do bad things and people who will not.
|One of the obvious problems with the old approach is that the inspectors cannot be in all places at all times. PHOTO: Istock
The “new safety approach” referred to in the piece is a safety management system (SMS), and it is not new – it has been TC’s policy since 2005, and is quickly becoming policy throughout the aviation world.
I imagine, however, many in the Canadian aviation industry cannot come up with a concise description of what SMS is. Many don’t know whether their company has one, or whether it was effective. The purpose of a safety management system is to provide a systematic way to control risk and to provide assurances that those risk controls are effective. SMS focuses on organizational safety, meaning organizations are supposed to look at risks within their company and industry, and ensure those risks have been properly addressed and appropriate mitigation measures have been put in place.
The CBC article has critics correctly saying that when mistakes happen, the airline employee is responsible for filling out an internal safety report. The critics then say that there is no requirement for the company to report the infraction to TC. This is simply wrong. As aviation professionals, we know that “reportable aviation accidents” and “reportable aviation incidents” are defined terms found on the TC website, and if they occur, must be reported within certain timelines.
The other notion I find troubling in the CBC article is that critics suggest the “old” approach of spotchecks – boarding planes to monitor flying skills, checking log books and conducting undercover surveillance – will prevent accidents from happening, while the “new” approach fails to spot potential problems. This argument is too simplistic and fails to address the fact that “one day in the life” of a pilot or helicopter operator does not tell the whole story about how safe an operation is. I would argue that this one-time spot checking of flying skills is much more of a hazard to aviation safety – certainly on that flight – than if it had not occurred.
One of the obvious problems with the old approach is that the inspectors cannot be in all places at all times. To suggest that aviators will only do the right thing if they are watched is analogous to saying people will only drive safely if the police are sitting on the side of the road. While it may be true in some cases, it suggests that driver training and media awareness campaigns about the dangers of speeding are not at all effective. That’s complete nonsense!
Let’s explore what the new approach is about. It’s meant to instil a safety philosophy, or safety culture, throughout the organization – top down, and bottom up, in which employees monitor their own actions and feel comfortable in reporting mistakes made. Employees are comfortable reporting when the culture is one where mistakes are allowed, and if found early, can prevent potential future accidents.
A safety management system often begins life as a reactive system – what happened, why did it happen and how can we stop it from happening again? These experiences are documented and grow into a proactive system. This is where we now begin to look at what may happen in the future given what we know about the past. The final stage is predictive. This occurs when systems are developed that are designed to stop the incident or accident before it can develop. These systems can include finding the best way to maintain equipment, or finding better training techniques. The list goes on and on.
I don’t want to suggest that the new approach is all good, and the old approach is all bad. That would also be too simplistic. I think we need to strike a balance. I think it is proper for TC to implement a national program requiring operators to have a detailed look at safety within their own operations. I believe having aviation professionals design and develop safety systems that work for their environment makes sense. They know what they need to do in order to remain safe. I also believe it is proper for TC to monitor operators as they develop their safety management systems.
It’s time we gave this “new” approach a chance to work the way it was designed to before we decide it is – as CBC reported – a “risky manoeuvre!”
Neil J. MacDonald is a lawyer practising in B.C. He holds an ATPL-H and flew as a captain on B.C. Air Ambulance and IFR Off-Shore. Neil has completed QMS Lead Auditor training in Canada and ISMS training in Singapore. firstname.lastname@example.org This is not a legal opinion. Readers should not act on the basis of this article without first consulting a lawyer for analysis and advice on a specific matter.