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Good morning, colleagues.
This is the 34th hearing of the Standing Committee on Transport, Infrastructure and Communities. Pursuant to Standing Order 108.2, we are examining the transportation of dangerous goods, and safety management systems.
We have witnesses from the Northern Air Transport Association and the Canadian Airports Council. Representatives of the council will also take part in our meeting via teleconference from Halifax and from New Brunswick.
I'd like to ask that the members of the committee specify to whom their questions are addressed, especially in the case of our teleconference participants.
As for our witnesses who are participating via teleconference, please identify yourselves before answering so that we may make a note of it. In addition, if you want to speak, please simply say your name and we will add it to the list for the question and answer period. Does that suit you?
You each have 10 minutes to make your representations.
We will begin with Mr. Stephen Nourse, Executive Director of the Northern Air Transport Association.
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Good morning, ladies and gentlemen.
I'd like to thank the committee for providing this opportunity for the Northern Air Transport Association, or NATA, to present before it. As you've heard, my name is Stephen Nourse, and I'm the executive director of NATA. I will apologize ahead of time if my voice cracks partway through. It's allergies, perhaps, or a cold; I don't know what is still around.
NATA has approximately 107 members and represents 37 commercial air carriers, all of which operate in the northern and remote regions of Canada. We have operator members in every province and territory in Canada with the exception of the three Maritime provinces of Nova Scotia, P.E.I., and New Brunswick. None of them are particularly northern or remote, so why would we?
Our carriers run the gamut from large jet carriers like Air North, Yukon's Airline; Canadian North; First Air; and Air Inuit; all the way down to small mom-and-pop operations and everything in between. We have both fixed- and rotary-wing operators among our members.
I will begin with some comments on the transportation of dangerous goods. On a per-flight basis, I would suggest to you that NATA carriers probably carry far more dangerous goods than the major carriers do in Canada. This is simply a function of where and who our carriers service. A huge part of their market is serving northern and remote communities, where air is the only year-round access to the community. In many cases, it's the only access—period.
With no other mode to move dangerous goods, people have to ship them by air despite all the restrictions in place. Fortunately, the transportation of dangerous goods by air in Canada is a well-developed and mature system based on international standards. If there's any criticism to be made of the system, it's perhaps that in remote locations it can be a bit onerous on the shipper's part.
Air carriers have sophisticated training programs on dangerous goods for handlers, cargo agents, receivers, maintenance personnel, flight crew, even the dispatchers. The manual specifying what can fly under what circumstances, and how packaged, puts the old standby of the Toronto Yellow Pages book to shame in its size. It literally is a multi-day course just to learn how to use the manual properly.
The vast majority of businesses supplying these remote locations know the rules, know how the paperwork goes, and have the specialized labels and packaging necessary to comply with the regulations. However, along comes Fred in a remote community, and all he wants to do is bring back a new battery for his ATV. Daunted by everything involved, or simply not knowing, it ends up either in his luggage or shipped undeclared, and likely improperly packaged. Now we have a potential problem. Fortunately that's relatively rare, but nevertheless it's a potential problem.
A lot of effort is put into DG awareness to prevent this from happening, but more is needed. There also needs to be some thought on how the system could perhaps be simplified for common items moved frequently in remote communities—items such as batteries, bear bangers, snowmobiles, and ATVs, which you and I just go to the hardware store for without a single thought as to how it actually got to the store.
Moving on to safety management systems, CAR 705 operators in Canada, those operating large commercial aircraft, have been under an SMS regimen for many years now. Initially there was a lot of angst among them regarding its implementation. The angst seemed justified for a while, as at first Transport Canada did not do a good job bringing it in.
Initially there was a lot of contradictory information, resistance from the inspectors themselves, and unfortunately a very narrow view of SMS from Transport Canada, limited to just what was regulated by them. The reality is that a successful SMS program requires a cultural shift by the entire organization, not just the portions regulated by Transport.
However, if you go to any of the 705 operators today and ask them about SMS, you will find that they all support it. Yes, it adds costs and complexity to their operations. No, it has not reduced oversight despite public opinion fuelled partially by inspectors who are worried about their jobs. If anything, it has actually provided the inspectors with more and better tools to monitor carriers while still retaining all of their traditional ones.
However, even with all the perceived downsides, it nevertheless has improved the way carriers do business. It has improved safety, streamlined processes, enhanced quality, reduced costs, and above all provided a proactive focus on identifying and managing risk. Has it eliminated crashes? That's hard to say. Has it reduced risk in operations? Yes. Has it made for safer workplaces? Yes. Is it worthwhile? Absolutely yes.
What about extending it to the smaller CARs 704, 703, and 702 carriers? Well, that depends primarily on where Transport Canada is right now in its thinking process. If it is to impose exactly the same requirements the 705 carriers are subject to, then no. That would cripple many of the smaller carriers. It's not that SMS principles won't work for smaller carriers; it's just that the systems imposed on the larger carriers need to be scaled to the size and complexity of the smaller ones. A small business in which people may wear multiple hats cannot afford a dedicated SMS individual, let alone, in some cases, an entire team.
We see this in the airport world today, where the SMS burden imposed on a small certified aircraft receiving a scheduled service of less than one flight per day is simply out of proportion to the size of the actual operation.
To sum up, NATA supports and endorses safety management systems and considers them an important element in the overall aviation safety oversight program. However, they're only successful if the requirements are appropriately tailored to the size and complexity of the operation such that they are not a burden and the organization can truly embrace them as a positive.
Thank you for your attention. I'd be pleased to respond to any questions you might have afterwards.
Mr. Chairman and honourable members, thank you for the opportunity to appear before you today to discuss the Canadian transportation safety regime, including safety management systems. We appreciate the opportunity to discuss this topic from a Canadian airports perspective.
My name is Daniel-Robert Gooch. I am the president of the Canadian Airports Council. Joining me via teleconference are Chris Farmer, from the Greater Moncton International Airport, and Gordon Duke and Michael Rantala, from the Halifax International Airport Authority. As they are airport operational practitioners at class 2 and class 1 airports respectively, I will defer to them for most of the Q and A component of this appearance. I also request your patience, as we may need to follow up with the committee on answers to some of your questions and will of course advise if that is the case.
The CAC is the voice for Canada's airports. Our 45 members operate more than 120 Canadian airports, including nearly all of the national airports-system airports and most major passenger service airports in the provinces and territories. Together, CAC members handle virtually all of the nation's air cargo and international passenger traffic and 90% of domestic passenger traffic.
Safety, of course, is the top concern for the CAC and our member airports. Aviation is the safest mode of transportation there is. This is said so often that it may sound like a cliché, but it is absolutely true, and it permeates all levels of our member airport organizations.
Safety management systems have been characterized as a business-like approach to safety, “a systematic, explicit and comprehensive process for managing safety risks”. A safety management system is part of the DNA of an organization, is part of its culture, and is the way people throughout an organization do their jobs. Airports in Canada support safety management systems and believe this is the right approach for Canada. It reinforces the culture of safety that already existed and promotes a national standard and approach for aviation safety at our nation's airports.
In the case of class 1 airports in Canada, an SMS process has been implemented and activated as per the requirements stipulated by Transport Canada. Many class 2 airports have also completed the implementation of their SMS, while others are in the final stage of having their phase four documentation review completed and are implementing their SMS process.
As the phased implementation of SMS moves forward for airports in Canada, the CAC members have established an SMS working group to lead the development and implementation of the requirements of the SMS regulations, in order to promote a consistent application of the regulations across the country. In the long term, this allows airports to share information and facilitate the sharing of knowledge for the development of subject matter experts.
This partnership approach also allows Canadian airports to establish and share best practices and provide a nationwide approach to implementing SMS. Furthermore, the working group developed a common system of reporting so that information sharing across member airports would be facilitated and site-specific or regional variances between airports on these core issues would be minimized.
The objective of the working group was to establish and maintain a robust SMS process across all airports with a far-reaching scope that includes but is not limited to the following: SMS policy, non-punitive reporting systems, performance objectives, performance measures and targets, hazard identification, reactive/proactive reporting processes, accident/incident investigation, risk assessment, quality assurance, safety management plan format, communications, and sharing of best practices.
The working group also uses Transport Canada's guidelines and evaluation tool, as well as International Civil Aviation Organization—ICAO—SMS documentation as their base.
Now I would like to make a few comments about the issue of dangerous goods, which we understand is also a focus of the standing committee.
Airport employees do not typically handle the transportation of dangerous goods, as this is the responsibility of refuellers for aircraft fuel and air carriers for air cargo that includes dangerous goods. Nevertheless, as with other modes of the transportation sector, the transport of all dangerous goods in and around airports is governed by dangerous goods regulations. In the air mode, these regulations are based on the ICAO technical instructions, which establish the rules for the safe transport of dangerous goods at airports within Canada and abroad.
The aviation industry and our airport members are committed to continuous improvement of standards, processes, and training requirements for dangerous goods. An example of this is the shared investment by airports along with air carriers and fuelling organizations in the update and maintenance of the Canadian Standards Association standard for the storage handling and dispensing of fuel at airports. This dictates common standards by which fuel is managed and adhered to by all parties involved in fuel at airports. CAC members are actively involved in the ongoing revision and updating of this standard.
Thank you for your time and we are pleased to answer any questions you may have. I will defer questions to my colleagues on the phone as appropriate.
To continue in the same vein, what we hope to achieve with the SMS is a decrease in the number of accidents. That is the ultimate objective of all that.
Before me I have the Transport Canada objectives for the number of accidents per 10,000 flight hours. I can see that for 2010-2011, the target rate was 6.5 accidents, for 2012-2013 it was 6.5 and for 2013-2014 it is 6.7. So there is an increase. Transport Canada's targets for accident rates are established by flight hour. Even if there are more flights now than there were before, the objectives are calculated in flight hours.
Unfortunately, the majority of accidents occur in the Canadian North.
Mr. Nourse and Mr. Gooch, I would like to know what you think about that. Do you think it is reasonable that Transport Canada has accident rate objectives that are on the rise? That doesn't make sense to me if we have safety management systems that work.
Mr. Gooch, earlier you spoke about the safety management system and its advantages. However, concretely, there are more and more accidents per flight hour.
Do you have any comments to make on that? What do you think of that? Do you think it makes sense that accident rate objectives are increasing?
Mr. Nourse, you said initially in your evidence that you have 107 members, 37 carriers, and everything from jet operators to small mom-and-pop operations, and that if you imposed the same SMS system on all of them, the requirements would cripple the small operators. Obviously in some of the small mom-and-pop operations the management and the employees are maybe at times hard to distinguish, but they're there for sure. You also said that it would need to be “appropriately tailored” and scaled to size of operation, and that it would need to be “sensitive to the nature of these small operations” and be “achievable”.
Yet we want to be sure that safety is still optimized. When you're looking at those smaller operations and at a great number of operations and the issues you have with infrastructure and everything else that's included, it makes safety a pretty significant issue. So you have to be careful when you're making that adaptation.
I would like to maybe have you give more examples of what you mean by that, actual examples of how you think it may happen. I think you mentioned one of them, the person who might bring something on board unintentionally. You were saying that for small operators in a remote northern area, it's not likely that anyone will try to smuggle stuff on board knowing that it's maybe harmful, particularly if they're on there as well.
That's one example of how you may simply need to ask the person or remind them or educate them and not go through a complex operation, or add in an additional burden that's not necessary. Can you give me more examples of what you mean by that? I would like some concrete examples, if you could.
Mr. Nourse, I would like to go back to the insightful comments you made with respect to the 1:40 versus 1:50 flight attendant ratio.
As I understand it now, if you're flying one of the major 705 carriers, and you want, for example, to sit in an emergency exit, you get the privilege of paying an additional sum of money so you can be of service to the airline should there be a problem. We've all been on different flights. Sometimes you get a thorough briefing; sometimes you get a cursory briefing; sometimes you get no briefing. I don't know how that all shakes down in terms of consistency.
What are Canadians to make of this? We're told it's an ICAO standard. I'm sure your member companies will abide by whatever the standard might be. On the other hand, Canada has filed dozens of exceptions, I think is the right word, to ICAO standards.
What are Canadians to make of this move, this pressure for moving from 1:40 to 1:50 flight attendant ratio? Keep in mind that we've asked the major 705 carriers to give us the financial implications of this move. This committee has not yet received from those witnesses, those companies, the pecuniary consequences and how much cheaper it's going to be. Will there be savings or no savings?
Keeping that in mind yourself in terms of your 107 member companies, can you address that?