Canadian Aviation Executives Safety Network

RDIMS 1318191

Safety Management Systems Small Operator Pilot Implementation Project

Phase 1 Status Report

Civil Aviation

Winter 2006

RDIMS 1318191

Table of Contents

Purpose 2

Background 2

Team Members 2

Phased In Approach 3

Complexity Chart 3

Timelines 4

Team Meetings 5

Issue Tracking Form 6

Participant Companies 7

Industry Associations Represented 7

Aerodromes and Air Navigation Branch Involvement 7

Initial Observations For Ongoing Analysis 8

Appendix A: Project Terms of Reference (TOR) 9

Purpose

This status report provides information on program activities being undertaken by the Safety Management Systems (SMS), Small Operator Pilot (SMS SOP) Project Team.

Background

During the Joint-Part V/VII SMS Canadian Aviation Regulation Advisory Council (CARAC) meeting held in September 2004, industry expressed concern regarding the application of SMS to smaller air operators and Aircraft Maintenance Organizations (AMOs). Transport Canada offered to establish a trial implementation of SMS with selected small operators to validate Transport Canada Civil Aviation’s (TCCA) current assumptions, recommend change where applicable, and provide a foundation for the next phase of implementation.

A Regionally based Project Team was selected and Terms of Reference (TOR) were developed to outline the projects objectives, accountabilities, etc.

The TOR is attached as appendix A and also available to Transport Canada employees using the department’s Records, Document and Information Management System (RDIMS) under reference number 1225906 (French version 1271250).

The projects objectives are:

(a) Identify a cross-section of small air operators, flight training units and AMOs, taking into account such factors as, number of employees, aircraft types and/or ratings, scope and types of operation and operating environment;

(b) Review implementation strategies for the currently proposed regulations for small companies and make recommendations regarding any required changes;

(d) Evaluate the current implementation plan for SMS and document any recommended changes;

(e) Provide a written report within a practical timeframe to allow project recommendations to be considered.

Team Members

Headquarters

§ Don Sherritt

§ Brad Fowles

Atlantic

§ Kim Trethewey

§ Mike Doiron

Quebec

§ Jean-Marie Richard

§ Yves Tarissan

Ontario

§ Rick Houle

§ Mark Dixon

PNR

§ Fred D’Amico

§ Dan Stelman

Pacific

§ Dick Murray

§ Danielle Rehm

Please note that the Project Team has access to additional Regional and Headquarters expertise as needed.

Phased In Approach

In consultation with TCCA’s Regulatory Affairs division it was determined that final project recommendations would be required by October 31, 2006. In order to meet this deadline, the Team, in cooperation with industry representatives, determined that a 4 Phase implementation process mirroring the one detailed in the SMS Implementation Procedures Guide (TP 14343) was required. However, for the purpose of the pilot project, the phases extend over a year and 1 month (as depicted in Chart 1) rather than 3 years and 3 months.

Chart 1

Complexity Chart

One of the first issues confronting the Team was what constitutes a small operator. To illustrate the issue, the original list of industry volunteers ranged in size from 1-person operations to companies with several hundred employees.

To address this issue the Team initially separated the companies by the parts of the Canadian Aviation Regulations (CAR) and then identified several complexity factors for each part. By applying a weighting calculation (Chart 2) to the complexity factors, a means to quantify the qualitative term small operator was developed.

This resulted in Chart 3, which shows the complexity of actual participant companies selected from across the country. Chart 3 shows a good distribution across the range of small companies.

Chart 2 (RDIMS 1314234)

Chart 3

Timelines

Due to extremely heavy workload for some of our industry partners during the summer months, it was decided that we would be able to meet the set project start/finish dates but could not guarantee meeting individual phase completion timelines. Forcing small operators to follow a fixed timeline for each phase presented several problems. The main issue involves the potential introduction of a hazard into the system if we asked them to take on extra duties during their busiest time of year. As a result, companies will progress through the process at slightly different rates. We have all started at the same point and will cross the finish line together.

An MS Project file was developed (Chart 4) to track project milestones. This file has been incorporated into the broader TCCA SMS project plan. In addition to this master plan each Region maintains plans for individual pilot projects.

Small Operator Pilot Project

Implementation Plan

July 20, 2005

Resources and Assignments / Target Finish Date
Terms of Reference approved by Project Sponsor / Completed
Participant list reviewed by representative industry association / Completed
Participating organizations identified / Completed
Implement Phase I / Completed
Regional update to Project Manager - end of Phase I / Completed
Implement Phase II / Underway
Implement Phase III / Thu 12/01/05
Regional update to Project Manager - end of Phase II / Wed 12/14/05
Regional interim report to Project Manager / Tue 1/17/06
Project Manager interim report to Project Sponsor / Tue 1/31/06
Implement Phase IV / Mon 4/03/06
Regional update to Project Manager - end of Phase III / Fri 4/14/06
Regional final report to Project Manager / Mon 8/14/06
All participants wrap up meeting – full team / Mon 8/21/06
Project Manager Final Report to Project Sponsor / Fri 9/15/06
Project complete / Fri 9/15/06

Chart 4 (RDIMS 1297595)

Team Meetings

The Team’s first meeting was face-to-face on May 10th at the SMS Information Session in Toronto. Subsequently, during project start-up, meetings were held via teleconference once per week and have now been changed to once every 2 weeks. Meeting minutes are prepared and available in RDIMS. In addition to the continuing teleconferences we held a second face-to-face meeting on October 11, 2005 concurrent with the SMS Information Session in Calgary and have a third face-to-face meeting scheduled for April27, 2006 in Halifax following the Canadian Aviation Safety Seminar (CASS).

Issue Tracking Form

Action items are tracked with the “SMS SOP Decision Record Status Report” which is updated in RDIMS after each Team meeting. Chart 5 shows the July 19th version of the form.

05.05.31.4 / Regional Project Plans / All Regions / May 31 – Al Regions to develop and submit project plans to Brad.- open
June 9 – Quebec has provided a first draft plan, all other Regions have not – open
June 20 – Regions to continue providing updated plans.
July 5 – No change.
July 19 – No change. /

All Regions

1225701 FR

1225702 EN

05.06.20.2 / Performance Measures / All Regions / June 20- Teams to develop and share performance measures.
July 5 – No change.
July 19 – No change. /

All Regions

1241433 EN 1253167 FR

05.07.05.1 / Release of SMS SOP industry partner names. / Brad Fowles - NCR / July 5 – Brad to canvas Regional Teams to determine if industry partners will approve the release of their names.
July 19 – S. Ross will provide update after August 10th meeting with K/W. Mark to provide update to Brad. /

Brad Fowles - NCR

1256213 EN French to follow.

05.07.05.2 / Update of Waterloo/Wellington SMS implementation project. / Brad Fowles - NCR / July 5 – Mark to update Team on status of Waterloo/Wellington SMS impl. project. /

Mark Dixon - Ontario

1256213 EN French to follow.

Chart 5 (RDIMS 1226102)

Participant Companies

The following companies have been selected from those who volunteered for the project. Each company has agreed to have its name released in association with the SMS SOP project.

Atlantic

§ Moncton Flight College

Quebec

§ Max Aviation

§ C.Q.F.A. (Centre québécois de formation aéronautique)

§ Essential Turbines

Ontario

§ Niagara Helicopters

§ Air Bravo

§ Kawartha Lakes Flight Centre

Prairie and Northern Region

§ Gillam Air

§ DSE Aircraft Limited

§ Universal Aero Engines Limited

§ Mitchinson Flying Service

§ Western Propeller

§ Guardian Helicopters

Pacific

§ Inland Air Charter Limited

§ Talon Helicopters Limited

§ Suncoast Aviation Limited

Industry Associations Represented

Participant companies are members of the following industry associations:

§ Air Transport Association of Canada (ATAC)

§ Canadian Aviation Maintenance Council (CAMC)

§ Canadian Association of Aviation Distributors and Maintenance Organizations (CAADMO)

§ Helicopter Association of Canada (HAC)

Aerodromes and Air Navigation Branch Involvement

During the first meetings held to establish the SMS SOP project in April 2005 it was agreed that involvement of Aerodromes and Air Navigation Branch (A&AN) in the project was desirable and that we would do everything possible to facilitate their participation. Since then the project manager has held several meetings with A&AN’s Director, Acting Director, Chiefs and their respective SMS staff to address their issues and assist them in participating in the SMS SOP project. A&AN’s participation has been discussed at several Team meetings and we have reiterated our encouragement and ability to accommodate them when they are ready.

Initial Observations For Ongoing Analysis

This section is a summary of issues identified by the SMS SOP Team for ongoing analysis.

Monitor timeline available for Phase 1 implementation. Initial information suggests a longer timeline may be desirable. For example, increase from 90 to 180 days for small operators. This proposed change would increase the overall implementation time for small operators by 90 days.

Assess need for Transport Canada to develop a standardized information session or workshop on SMS implementation for small operators. Building on the last two successful Transport Canada SMS information sessions, this program should be portable so that delivery can occur when and where needed. To facilitate accessibility and small operator participation, consideration should be given to making the program available in multiple formats. For example, a PowerPoint presentation could be available in print, on CD or the web.

Assess the need for Transport Canada to develop additional guidelines detailing how the current assessment criteria should be applied to small operators. Using examples of safety management systems gathered through the SMS SOP project will assist in achieving this goal.

Transport Canada should continue to capture useable performance measurement examples from aviation and other operations that would assist in developing sound measurement tools for small operations.

The SMS SOP team should continue to monitor publications such as TP13739, TP 13881, TP14135, TP 14343 and TP 14326 as well as the regulations and take appropriate actions to harmonize incompatible information.

Transport Canada to capture examples of enhanced/improved management efficiencies resulting from SMS implementation that may be of interest to small operators. For example, Moncton Flight College claims direct savings of $35,000.00 plus a 27% saving (lower than industry average) on insurance premiums as a result of SMS Implementation.

For more information on this report or the SMS Small Operator Project, please contact:

J.A. Brad Fowles
Project Manager, Safety Management Systems, Small Operator Pilot Project

Transport Canada Civil Aviation

(613) 998-5321| facsimile (613) 998-7416 | TTY (613) 990-4500

E-mail address:

330 Sparks Street

Ottawa ON K1A 0N5

Safety Management Systems Small Operator Pilot Implementation Project

Phase 1 Status Report page 8

RDIMS 1318191

Appendix A: Project Terms of Reference (TOR) – June 2005

Safety Management Systems Small Operator Pilot Implementation Project

Phase 1 Status Report page 8

Terms of Reference – SMS Small Operator Pilot Implementation Project

Revision History

Version / Date / Description / Author
Initial Draft / May 11, 2005 / Initial Draft of Terms of Reference sent to Team for comments / B. Fowles
2nd Draft / June 1, 2005 / All received Team revisions included / B. Fowles
3rd Draft / June 7, 2005 / Revised to included information from Joint CARAC Part V and Part VII CASO Technical Committee DR – September 13 – 16 and November 9, 2004 and subsequent January 27, 2005 letter to industry. / B. Fowles
Final Version (V2.5) / June 9, 2005 / TOR’s signed by Mr. Don Sherritt. / B. Fowles
Final Version (V2.5) / June 9, 2005 / TOR’s sent to translation. / B. Fowles
Final Version (V2.5) / June 9, 2005 / TOR’s delivered electronically to SMS SOP Team. / B. Fowles
Final Version (V2.8) / June 14, 2005 / As a result of the June 9 Team meeting a wording change was made to 7.3.1 (g) (a) to more closesly reflect the objective stated in 5.0 (b). / B. Fowles