:
I'd like to thank our witnesses and welcome them here today.
We have, from the National Airlines Council of Canada, Mr. Marc-André O'Rourke, executive director; Mr. Samuel Elfassy, senior director, corporate safety and environment, Air Canada; Captain Scott Wilson, vice-president, safety, security and quality, WestJet; David Deveau, vice president, safety, quality and environment, Jazz Aviation; and Captain Jacques Mignault, senior director, safety, quality and security, Air Transat.
Thank you, gentlemen, for being here.
I understand, Mr. O'Rourke, that you're going to lead off.
Thank you to the committee for the invitation to appear here today as part of a review of the Canadian transportation safety regime. We really do appreciate the opportunity to discuss our experience with the transportation of dangerous goods and the implementation of safety management systems, SMS for short, as it relates to aviation in Canada.
As the chair mentioned, my name is Marc-André O'Rourke. I'm the executive director of the National Airlines Council of Canada, NACC.
The NACC is a trade association that represents Canada's major airlines. Our members are Air Canada, Air Transat, Jazz, and WestJet.
[Translation]
We make sure that air travel is safe, sustainable and competitive by working with the government and industry stakeholders to implement policies, acts and regulations that support a world-class transportation system that is essential to Canada's economic growth and prosperity.
[English]
Many of our council's activities are undertaken by our subcommittees, which represent the combined expertise of our member carriers. Our subcommittees, namely safety, flight operations, and maintenance and engineering, work together to maintain and enhance world-class safety standards.
Given SMS's systematic approach, it's very important to note the collaboration and information sharing between all areas of an airline, from the actual operations to all the support functions. SMS is the concern not only of safety departments, it's a company-wide shared responsibility.
Today I'm joined by representatives of our safety subcommittee, who will share their expertise with you in a few minutes. They are Samuel Elfassy, senior director at Air Canada; David Deveau, vice-president at Jazz Aviation; Captain Scott Wilson, vice-president at WestJet; and Captain Jacques Mignault, senior director at Air Transat.
NACC member airlines directly employ over 43,000 people and carry more than 50 million passengers a year. Together, our members serve more than 60 Canadian communities. They represent 87% of the domestic traffic and 64% of total airline traffic in Canada.
Most importantly, our members' deliberate and unwavering commitment to safety is ingrained in everything they do. Nothing is more important to our members than making sure the passenger gets to his destination safely.
Aviation is the safest mode of transport. Today, modern aviation is safer than it has ever been before. This achievement is not the work of chance. It's the result of a comprehensive and systematic approach to safety taken by the industry.
To the NACC airlines, safety is not just a matter of following the rules. Safety is about proactively managing risks and hazards that go well beyond the minimum requirements established by civil aviation authorities. Safety is the foundation that truly underpins the way an airline is run.
Our carriers have embraced the principles of safety management systems and embarked on a journey which brought about significant and meaningful enhancements to the safety culture that already existed. It's important to note that SMS is internationally recognized by the safety and aviation communities as the most advanced approach to mitigating and ensuring a proper and safe aviation system.
At the outset, I think it's important to take a minute to describe what SMS really is. An SMS system is a holistic approach where policies, processes, and systems are used to proactively identify, mitigate, and eliminate safety hazards and risks. It means that every activity an airline engages in, whether it be the actual flying of the aircraft, the maintenance of the engines, or any of the literally thousands of steps it takes to get from point A to point B, each of these activities is designed in a way that eliminates or reduces the potential for error or accident.
Today I can state unequivocally that transformation toward an improved safety culture has taken place at all levels of our member airlines. From the front-line employees to management to the most senior ranks, our members are fully engaged. This company-wide commitment to safety—again, it's company-wide and all departments are involved—and accountability is a hallmark of an SMS framework.
I would like to be very clear about the fact that the SMS implementation does not mean that airlines are policing themselves with no government inspection or oversight. SMS is a partnership whereby airlines are required to implement even more sophisticated oversight systems than ever before.
No one within the industry is advocating that the oversight and continued surveillance functions have become redundant. On the contrary, certification and oversight activities of Transport Canada are more important than ever and are essential parts of Transport Canada's role.
In fact, under an SMS approach, Transport Canada oversight is much more rigorous and meaningful. SMS adds a layer of safety to what is already the safest transportation industry in the world.
SMS increases oversight by utilizing even more sophisticated risk management techniques, including enhanced two-way communication and data trending. SMS is applied on top of existing safety and quality tools.
The SMS process is not just a general review of procedures and data as it has been suggested by some. SMS includes digging into specific areas of safety to find evidence of what has been done to address these issues.
Airlines must show Transport Canada that they have: one, identified the root cause of a potential problem; two, taken corrective and preventive measures; and three, verified the effectiveness of those measures. SMS seeks to find unknown risks which is far beyond what a regulator on-site inspection can ever do.
However, for oversight to remain effective, it too must evolve. The goal of SMS is to move to a proactive state of safety, a more assertive role in which the air carrier collects and analyzes data to understand the hazards and the safety barriers needed to avert possible negative outcomes.
Any suggestion that air travellers have been exposed to a higher risk as a result of SMS is completely irresponsible and unfounded. It bears repeating that safety is of the utmost importance to our members and their individual and collective safety records speak for themselves.
I'd like now to turn briefly to the issue of dangerous goods, because I know it's also a focus of the committee's review.
As with other modes of transport, the transportation of dangerous goods by air is governed by the transportation of dangerous goods regulations. These regulations incorporate, by reference, the International Civil Aviation Organization technical instructions. These instructions establish the rules for the safe transport of dangerous goods by air, both within Canada and internationally.
It's important to note that the transportation of dangerous goods is highly regulated by a robust and sophisticated international framework. The aviation industry and our members are committed to the proactive and continuous improvement of its standards, processes, and training requirements with respect to transporting dangerous goods by air. NACC members are actively involved in the ongoing revision and updating of the international standards.
[Translation]
To conclude, I would like to reiterate that safety is an absolute priority for the council and its members. Our airlines continue to be strongly committed to improving the safety management system because we know that aviation safety can only be ensured through constant vigilance.
Of course, we are willing to work with Transport Canada, this committee and other stakeholders to ensure the ongoing excellence of aviation safety in Canada.
[English]
I would now like to give an opportunity to the members of our safety committee to briefly introduce themselves. As you will see, we have brought with us today representatives who are well placed to discuss issues dealing with SMS implementation and the transportation of dangerous goods.
Thank you very much. Merci beaucoup.
:
Thank you, ladies and gentlemen.
As Marc-André mentioned, it's not only a privilege but a good opportunity for us to appear today and help inform the dialogue around the topic.
As mentioned, I'm David Deveau. I'm the vice president of safety, quality and environment for Jazz. I also have the privilege of being the chair of the safety subcommittee for NACC with these dedicated and respected folks who are at the table here. I'll mention that I'm also the chair of the safety council of a U.S.-based regional airline association. I mention that because it provides perhaps a unique perspective of SMS from outside of our nation and how it's seen by other countries as well.
One of the things you'll find about aviation safety professionals is that they're very passionate about the topic, and I hope that we can provide some value here.
In terms of a few comments, just to open up, I'd like to be quite blunt, if I could, with respect to SMS and how it's viewed, I think, by many colleagues in this realm. It's very much a set of basic principles and concepts that are not new, in fact, and are based on quality management and organizational management sciences. In terms of its effectiveness, I must respectfully but bluntly say that questioning the value of an enterprise system like SMS is really not a rational argument by those who are informed about what SMS actually is. If I can draw a parallel akin to a financial management system or a human resources management system, it's a sophisticated, structured program based on very sound principles. Really, there's no other way to view its impact on aviation but as an evolution of what was already a very strong safety basis certainly in Canada.
As I mentioned, with respect to the perspective that others may have on SMS, I have to be very clear that when I talk to colleagues in the United States in particular, and even overseas, Canada's aviation safety system is considered to be the best and safest system on the planet, frankly. Indeed, I know that they collaborate and discuss SMS and what's happening in Canada both with operators and with Transport Canada.
For us, and speaking for Jazz, what SMS has done is it has provided a framework to increase the sophistication of what we have always done in aviation with additional tools and has created a much more integrated way of managing risk within the organization. There are many focus areas that SMS has brought for airlines, including a very important focus on organizational culture, a shared culture of safety, so that it's every single person in the organization who shares the accountability to ensure that risk is identified and managed properly.
It also focuses very carefully on organizational factors. If you were to step back in time, you would find that the focus on safety, in general terms, including aviation at a certain point, was very much about the individual and perhaps what the individual didn't do or whether there was error involved. SMS creates a need for us to examine what the organization is doing: systemic issues, root causes. Again, I've used the word “sophistication”, but it really has brought a new layer of sophistication to what we do. It really has done this. Again, speaking for Jazz in my case, it's provided a road map for us to improve on, again, a very strong basis of safety.
With respect to our interaction with the regulator, it has also changed that in a very positive way as well. Although we continue to see the direct surveillance and inspection activity, our interactions and our work with the regulator is frankly much more meaningful than it has been in the past. There is a much greater expectation on airlines under an SMS program that we must demonstrate to the regulator. Certainly if the committee is interested in hearing some more examples on that, I'm happy to expand on that.
I did want to just open up with those initial comments to offer the perspective of one airline.
It's a privilege to be here before you this morning.
I'll provide a brief background on my role at Air Canada. I've been with Air Canada approaching 27 years. I've had the privilege to serve as the senior director of safety, environment and quality. I've also served within the airline over the course of those years with in-flight operations and in other areas. I've also been fortunate to have sat in on a number of working group sessions and meetings over the years with Transport Canada in the early development and then ongoing promulgation of the rules associated with SMS. So I have the benefit and the luxury of recalling and understanding what the spirit and the intent were during the early regulatory development.
The scope and responsibilities and the accountabilities that I have across our profile speak mostly to the oversight that we have as a department within Air Canada. We're operationally independent, reporting to Mr. Calin Rovinescu, who's our president and CEO, as well as reporting to our board of directors for safety oversight as well as environmental oversight. The operational independence is quite important because it allows us to view independently across the organization the ongoing effectiveness and management not only of our safety management system, but our environmental management system as well as our occupational health and safety management system.
That role is to test monitor the effectiveness of our SMS through the various reporting procedures and address the safety hazards that the organization faces.
I'll also echo David's comments relative to how we're regarded within the industry on an international level. I have the luxury of sitting on various committees across various associations, both at IATA and the Airlines for America, as an associate member. Our safety management system is regarded as one of the most robust and rigorous performance-based systems out there. In fact, some international theatres don't have a regulatory requirement for SMS, so we're often sought out for our expertise.
Outside my professional life, I chair a hospital board in the city of Toronto. I mention that because over the years, given our expertise associated with the implementation of SMS, we're finding that we're crossing the boundaries and assisting other safety-sensitive sectors with how to apply the principles of safety management systems to benefit their organizations and reduce adverse outcomes. It's quite an exciting period of time because others are benefiting from our knowledge and our experience, and they are coming to us for that.
To David's point, our interactions with the inspectors within Transport Canada have evolved. I don't want to say on a regular basis, but quite often during the quarter, it is not uncommon for us to invite inspectors to sit in on our management review process which is quite rigorous. It goes through many layers. They have sat in on our corporate safety board where we report to our CEO. They're invited to participate in those meetings as we look to discover our hazards and report to our management team on our risks and our safety profile.
I will leave my comments at that, and we'll appreciate any questions you might have that are associated with our experience.
Thank you.
:
Thank you very much, Mr. Chair.
I thank the committee for welcoming us here today. It's a great honour and privilege to be able to share our experiences on the implementation of safety management systems here in Canada.
I'll give you a bit of background on myself. I've been 13 years with WestJet and a little over 20 years in the industry, primarily in flight operational roles, prior to taking on this role in the safety, security, and quality side for the past three years.
From a WestJet perspective and a greater NACC perspective—I won't touch on some of the technical details that David and Sam have quite eloquently put—I'll talk a little bit about the culture side.
Obviously, coming from a culturally enabled organization such as WestJet, the big differentiator that we have found with safety management systems is how it takes that cultural envelope and leverages that across the system. We may have safety in our names or titles here, representing the four airlines, but the reality is that for the 43,000 front-line employees, they are the front face of safety every day in our airlines. The safety management system is to enable their voice and their opportunity to be a very enabled and active piece of safety within the airline system operating across Canada every day.
With that, I will close. We look forward to the discussion. Thank you for the opportunity.
:
Great. Let's just review some of the things we've heard from Transport Canada's own air inspectors.
The aviation inspectors who work for Transport Canada conducted a very detailed survey. Here are a few of the things they've told us.
They say the way Transport Canada safety management systems are structured prevents the correction of safety problems in a timely fashion, up from 80% who worry this would be the case in the early days of the safety management system. Two-thirds of the minister's own inspectors are telling her that Transport Canada safety management systems will actually increase the chances of a major aviation accident.
The inspectors surveyed also say, as a result of the inspector shortage, airlines can now go as long as five years before Transport Canada inspection is required. We understand it's supposed to be happening on an annual basis. It may be happening for the large companies, but there are an awful lot of other companies that are not being caught.
Officials from the minister's own department previously promised MPs on this committee that 30% of Transport Canada aviation inspections would be direct operational inspections, i.e., on-site aircraft and operational inspections, RAM checks, unannounced inspections, etc. This conflicts with the findings of the inspector survey which reports inspectors spend almost no time on direct inspection.
I put a similar question to the rail industry representatives, the large companies. I asked them whether they thought it was their responsibility to try to make sure their partner in the safety management system, the SMS, was upholding their side of the bargain, their responsibility.
Let me ask you, in the face of what we have heard from the inspectors who inspect your companies, what's your reaction?
:
May I address the member's questions? I think they're relevant questions.
The question does presume that, from the perspective and the experience of the operator, there is a problem with regard to the oversight. I can't speak to the motivations or characterizations in the survey. All I can speak to is fact and the experience we have as operators.
Frankly, I mentioned passion at the beginning, in this realm, in safety, and it is frustrating for us to hear the characterizations that somehow Transport Canada has dissolved into the wind over this transition, whereas the reality, ironically, is quite the opposite. We still see Transport Canada inspectors on a regular basis with much of what you consider the traditional surveillance activities, be they check-rides or visiting our dispatch centres.
What has been added on top of—not instead of, but on top of—that activity is an interaction with us that requires us to peel back the layers of our organization and demonstrate to Transport Canada, with respect to non-compliance, for example, exactly what causal factors were there, how we discovered the issues, and how we're mitigating them, to demonstrate to the regulator that we understand why something may have happened, how we're ensuring that it doesn't happen again, and in fact even proving the effectiveness of our solutions. This is all on top of traditional surveillance activity.
I just want to be clear. We can only speak to the facts and the experience that we have as operators, and we have a deeper and more meaningful oversight experience with Transport Canada than we have in the past.
:
There are two points to that.
WestJet currently is operating under exemption for one in 50 in Canada. Actually, one in 50 has been used in Canada under exemption for many years in 50-seat aircraft. Aircraft certified under regulation in Canada are certified to one in 50; that's the international standard.
When we speak of Australia, we looked very closely at all regulatory jurisdictions. Although Australia may have regulations on the books for one in 36, they were the ones, as a regulatory environment, that set the stage for exemptions. Most carriers in Australia are operating under a one-in-50 exemption, which is the international standard.
Going back to safety management systems, the entire intent before you make change.... We have a saying at WestJet, “We do it with our people, not to them”. To the questions about incorporating the front line and their thoughts about it, our flight attendants were actively involved in this adoption of change at WestJet.
When we looked a step further, safety systems required to make decisions based on strong amounts of data, across the world there are only two regulatory jurisdictions not operating under one in 50. That was, to your point, Canada and Australia. We had reams and reams of data and lots of airlines to go to to validate the safety of the change. That's been proven, as we've been operating in Canada at equivalent level of safety, since October 2013, under one in 50.
Thank you to our witnesses here today.
To start with, I just want to state very clearly for the record, in regard to Ms. Morin's questioning, actually we invited CUPE to join us at our meetings here and they refused to attend. If this issue was foremost in their minds, it's kind of strange that they would not be here to bring forward their viewpoint.
However, I want to turn to the witnesses that we do have here today. I want to talk about the transportation of dangerous goods. Mr. Wilson, WestJet does not transport dangerous goods, but I believe some of the other airlines do.
I'm just wondering what your parameters are for that. How do you assess the dangerous good? I'm assuming you also look, rather than just at the dangerous good itself, but also at how it's contained, how it's packaged, and how you contain that within the aircraft. Could you expand on that a little bit? Give us some sense of how you decide what dangerous good you're going to transport, and also how you work within the context of it with your employees and with your staff as to how that has to be contained, both within the containment of the unit itself, but also on the plane.
That question is for anybody.
:
I'll take a go at this.
IATA publishes a very comprehensive manual relative to the transportation of dangerous goods. It's about two and a half inches thick, and gives a very detailed description of what is permitted on board a passenger aircraft, what is permitted on an all-cargo aircraft, and how it's to be packaged. It provides all of the technical and scientific details specific to the product that's permitted to be transported based on the rules of transportation.
That publication is used as a training program for our employees. Some of our employees are in the field of accepting the dangerous good. Others are in the field of handling that dangerous good, in terms of boarding the dangerous good on board an aircraft, and others, in terms of responding, should there be an event associated with that good.... Depending on the role of the employee, they are provided comprehensive training that is reviewed by Transport Canada. They not only review the program, but they will often sit in and actually observe the training sessions. That manual is used to describe.... I'll give you an example.
Radioactive isotopes that are used in the medical industry are routinely shipped to various research centres and hospitals across the country and across the world. Sometimes radioactive items can only be placed in some very specific areas of an aircraft cargo compartment. Our loading instructions detail to the employees where they're placed, how far away from the passenger, and how they're handled. They are labelled. They are documented. The flight crew know they're being carried on board. Further, flight crew have on board the aircraft a very detailed protocol on how to respond should there be an incident involving that dangerous good. It's a checklist that the flight crew use.
Across the spectrum, depending on the role and responsibility of the employee, there's exhaustive training that is conducted.
:
I'll also give you an opportunity to.... Oh, he has left the room at the moment. Mr. Sullivan had a question and I didn't get a chance to rebut. I wouldn't mind taking that opportunity, as well.
First and foremost, if you look at an international standard, one in 50 very much is an equivalent standard to one in 40.
To the discussion around the doors, in particular, I'll use the Boeing 737-600 as an example. It holds only 119 guests, or passengers—guests is a WestJet vernacular. Whether it was one in 40 or one in 50, it's still required to carry three flight attendants. Of course, there would still be a door without a flight attendant; however, being a narrow-body aircraft, it has been proven time and time again that's not an issue.
In a lot of ways we find that we actually have better staffing on board the aircraft, because one in 40 allowed it a flexibility piece. You could have an aircraft with four doors, and if you wanted only 80 passengers on board, you'd only be required, under one in 40, to have two attendants. One in 50 takes that operating flexibility away, and it always requires that an aircraft dispatch appropriately, with the correct number of flight attendants at all times. One fewer flight attendant has no means for that aircraft to move. That's why we basically are very comfortable saying it's an equivalent level of safety.
It looks slightly different, but there's no reduction in safety barriers or margins, or else WestJet would not have entertained it whatsoever. On behalf of our 2,600 hard-working flight attendants, I strongly suggest they would have a stake in that game, too, and that's our comfort from that, sir.
I'm sorry, but I got a little off topic. If that did not answer the question and you'd like me to restate something, I'd be happy to put that framework back into it.
:
Perfect. Thank you, Chair.
Just to answer Mr. Komarnicki's question with respect to the survey, it was done with inspectors, employees of Transport Canada, who actually enforce Canada's air safety regulations so when these people, 85% of them, say air travellers are exposed to higher risk....
Here we are as regulators trying to make sure the system in place is the safest one. I think we all agree, and I'm sure the airline industries also agree on that. That's why we have questions, especially when we saw what happened on rail safety. Obviously you have followed what happened in Lac-Mégantic. There were faults in the system. SMS is the same thing. We heard from railway companies saying it's the safest thing, but when we looked at it, we realized it was meant to be another layer. I think you all mentioned it. It was meant to be an additional protective layer, but what we've seen on the ground is that there are problems with respect to inspections.
I talked about the facts. There is the fact that we have fewer inspectors with Transport Canada to look at some of the issues. I don't necessarily agree that Transport Canada has done everything and even more than it's supposed to. Even the Auditor General has said that.
When we come back to SMS, for instance, and when we look at the change of ratio—we spoke about it today for flight attendant ratio—are flight attendants being involved in the SMS that would come after that? You say, yes, but when I was there and Mike Sullivan was there at CARAC, I don't think we heard any flight attendant say that would increase safety. That's my concern.
You say you're working with the employees, but then we hear about the employees not being satisfied and saying there is a higher risk. That's why we ask questions.
For instance for the reduced flight attendants ratio, how involved are the flight attendants in terms of...?