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David Wilson, Stantec (formerly Jacques Whitford) Roger Barker, ISR

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1 David Wilson, Stantec (formerly Jacques Whitford) Roger Barker, ISR
Design, Development and Delivery of Safety Management System Training to Transport Canada: Six Years and Counting David Wilson, Stantec (formerly Jacques Whitford) Roger Barker, ISR

2 Outline The Mandate The Plan Course Design and Development
Transport Canada’s Start Point Inclusion of International and Audit Content Course Delivery Institutional Challenges Regional Challenges Internal vs. External Reaction

3 The Mandate “The broad objectives of the SMS course are:
For Delegated Officers (DOs) and Management to develop a detailed understanding of SMS, thereby instilling confidence and obtaining buy-in to TC’s SMS program For DOs to develop the skills necessary to execute their mandates in the assessment of SMS”

4 Aviation mission and vision
To develop and administer policies and regulations for the safest civil aviation system for Canada and Canadians using a systems approach to managing risks Continuous improvement High level of public confidence Flight 2005: A Civil Aviation Framework for Canada

5 Evolution of Safety Management
0.0 0.5 1.0 1.5 2.0 2.5 3.0 Safe Environment Safety Awareness Safe Person in Safe Environment Supervision Driven Team Driven Behavior INCIDENT RATE Command & Control Programs Management Systems Command and Control Supervision driven – management is in charge and directs actions of employees A reactive approach to safety within an organization Authoritative approach No feedback loop or input from operators, i.e. dictatorship for safe practices No standards across the board, and No specific SOPs, to verify effectiveness

6 Towards Zero... …is the condition to which risks are managed to acceptable levels. Workplace Safety Standards For System Safety, this is the definition to which we work (which drives safety intelligence)

7 TC Requirements “Aviation organizations should establish and maintain a safety management system that conforms to all of the requirements of applicable Canadian Aviation Regulations (CARs) and Standards” Transport Canada’s new vision: To develop and administer policies and regulations for the safest civil aviation system for Canada and Canadians using a systems approach to managing risks This is the driving force behind the regulation of SMS in the Canadian aviation industry. It is recognized that the systems approach to safety management is necessary in order to bring the aviation industry further down the curve to zero incidents. TC will take this approach internally with the implementation of their own Integrated Management System (IMS) in Civil Aviation “The performance goals, the processes, and the accompanying cultural changes necessary for a successful IMS are, for all intensive purposes, the same as those of a sound SMS” (Flight 2010 – TP14469) The Canadian Aviation Regulations are a compilation of regulatory requirements designed to enhance safety and the competitiveness of the Canadian aviation industry. They correspond to the broad areas of aviation which Transport Canada Civil Aviation is mandated to regulate (e.g. personnel licensing, airworthiness, commercial air services, etc.).[1] under the Aeronautics Act. The existing powers as set out in the Act provide for the making and repealing of regulations. There are 9 parts to the CARs I General Provisions II Aircraft Identification and Registration and Operation of a Leased Aircraft by a NON-registered owner III Aerodromes and Airports IV Personnel Licensing and Training V Airworthiness Aircraft Certification (AC) Maintenance & Manufacturing (M&M) VI General Operating and Flight Rules VII Commercial Air Services VIII Air Navigation Services IX Repeals and Coming into Force The CAR’s contain two types of provisions: Offence-creating provisions outline both "what to do" and "what not to do". Non-compliance is a violation and can result in judicial or administrative action Administrative provisions address the obligations and authorities of the Minister and delegated officials Standard publications have been incorporated by reference in the CARs. Some standards are grouped together into Chapters. Advisory Materials are recommended procedures or guidance material which provides information on a regulation or a standard. [1] Excerpted from the Transport Canada website: SMS is being incorporated into the CARs through implementation of amendments to the regulations - Notices of Proposed Amendments (NPA) The NPA Order of operations… Review for approval by CARAC Technical Committee and Civil Aviation Regulatory Committee (CARC) Department of Justice for legal review and drafting Gazette I for public comment After public comments are dealt with, final edits are made Gazette II (in force) The proposed schedule is to have the SMS file come into force in 2004 [[i]] SMS provisions will apply initially to International airports and provisions for smaller airports will be introduced gradually. As an interim step, all certified airports will be required to name their accountable executive and to provide human factors training to personnel. The requirement for a non-punitive reporting policy will also be included. [2,[ii]] John Maxwell advised that Transport Canada is aiming to meet the ICAO deadline of November 24, 2005 which requires all certified aerodromes have a safety management system (SMS) in operation. - Careful this only applies to airports not necessarily operators – CC CARC has put a new procedure in place to ensure a consistent approach to SMS across all Technical Committees. All future NPAs dealing with SMS will be reviewed by a Steering Committee of Executive Directors prior to being tabled at Technical Committee meetings Sources: [[i]] CARAC Technical Committee Meeting Record of Decisions – December 12, 2002 [[ii]] CARAC Aerodromes and Airports Technical Committee Meeting (Part III) February 20 – 21,

8 TC Requirements There are 9 parts to the CARs: General Provisions
Aircraft Identification and Registration and Operation of a Leased Aircraft by a NON-registered owner Aerodromes and Airports Personnel Licensing and Training Airworthiness Aircraft Certification (AC) Maintenance & Manufacturing (M&M) General Operating and Flight Rules Commercial Air Services Air Navigation Services Repeals and Coming into Force Transport Canada’s new vision: To develop and administer policies and regulations for the safest civil aviation system for Canada and Canadians using a systems approach to managing risks This is the driving force behind the regulation of SMS in the Canadian aviation industry. It is recognized that the systems approach to safety management is necessary in order to bring the aviation industry further down the curve to zero incidents. TC will take this approach internally with the implementation of their own Integrated Management System (IMS) in Civil Aviation “The performance goals, the processes, and the accompanying cultural changes necessary for a successful IMS are, for all intensive purposes, the same as those of a sound SMS” (Flight 2010 – TP14469) The Canadian Aviation Regulations are a compilation of regulatory requirements designed to enhance safety and the competitiveness of the Canadian aviation industry. They correspond to the broad areas of aviation which Transport Canada Civil Aviation is mandated to regulate (e.g. personnel licensing, airworthiness, commercial air services, etc.).[1] under the Aeronautics Act. The existing powers as set out in the Act provide for the making and repealing of regulations. There are 9 parts to the CARs I General Provisions II Aircraft Identification and Registration and Operation of a Leased Aircraft by a NON-registered owner III Aerodromes and Airports IV Personnel Licensing and Training V Airworthiness Aircraft Certification (AC) Maintenance & Manufacturing (M&M) VI General Operating and Flight Rules VII Commercial Air Services VIII Air Navigation Services IX Repeals and Coming into Force The CAR’s contain two types of provisions: Offence-creating provisions outline both "what to do" and "what not to do". Non-compliance is a violation and can result in judicial or administrative action Administrative provisions address the obligations and authorities of the Minister and delegated officials Standard publications have been incorporated by reference in the CARs. Some standards are grouped together into Chapters. Advisory Materials are recommended procedures or guidance material which provides information on a regulation or a standard. [1] Excerpted from the Transport Canada website: SMS is being incorporated into the CARs through implementation of amendments to the regulations - Notices of Proposed Amendments (NPA) The NPA Order of operations… Review for approval by CARAC Technical Committee and Civil Aviation Regulatory Committee (CARC) Department of Justice for legal review and drafting Gazette I for public comment After public comments are dealt with, final edits are made Gazette II (in force) The proposed schedule is to have the SMS file come into force in 2004 [[i]] SMS provisions will apply initially to International airports and provisions for smaller airports will be introduced gradually. As an interim step, all certified airports will be required to name their accountable executive and to provide human factors training to personnel. The requirement for a non-punitive reporting policy will also be included. [2,[ii]] John Maxwell advised that Transport Canada is aiming to meet the ICAO deadline of November 24, 2005 which requires all certified aerodromes have a safety management system (SMS) in operation. - Careful this only applies to airports not necessarily operators – CC CARC has put a new procedure in place to ensure a consistent approach to SMS across all Technical Committees. All future NPAs dealing with SMS will be reviewed by a Steering Committee of Executive Directors prior to being tabled at Technical Committee meetings Sources: [[i]] CARAC Technical Committee Meeting Record of Decisions – December 12, 2002 [[ii]] CARAC Aerodromes and Airports Technical Committee Meeting (Part III) February 20 – 21,

9 The Plan Phase 1: Analysis
Deliverable 1: Training Needs Analysis, Learning Strategy, Final Work Plan and Background Update Phase 2: Evaluation and Design for CBA and AMM Deliverable 2: Course Syllabus, Course Materials Phase 3: Pilot Course Deliverable 3: Pilot Course, Course Evaluation Phase 4: Course Delivery to CBA and AMM Deliverable 4: CBA Course, AMM Course

10 The Plan cont’d Phase 5: Validation of Course Delivery to CBA and AMM
Deliverable 5: Confirmed Assessment Protocol, Course Validation Optional Phase 6: Adaptation for Other Functional Branches Deliverable 6: Adapted Course(s) Optional Phase 7: Course Delivery to Other Functional Branches Deliverable 7: Other Functional Branch Course(s) Optional Phase 8: Validation of Course Delivery to Other Functional Branches Deliverable 8: Course Validation(s)

11 Course Design Definition of the target population
Identification of the SMS knowledge level of target audience Review of CARs and notices of proposed amendments (NPAs) to CARs relating to SMS Review all applicable national and international (e.g., UK, Australia and GAIN) aviation SMS policies and guidelines Assessment of the existing safety culture within the target audience

12 Safety Metrics Assessment
Survey-based tool from sub-consultant Distributed internally to approx DOs: 150 replies Intent was to identify: Internal issues/barriers within TC Issues/barriers external to TC (customer, industry, etc.)

13 Training Needs Assessment
Front line staff were fully aware of their needs and challenges Different measures are required to measure safety and SMS; The interdependencies of attitude, behaviour, and motivation cannot be ignored Inspectors need practical demonstration of a functioning SMS from the ground up, If support, guidance, and structural leadership from management are not forthcoming (as happened with Risk Management training), then SMS training will fail.

14 Global Review of TC SMS Global references:
OHSAS18001 GAIN CASA Australia - Guide to Aviation SMS SMS for Commercial Air Transport Operations - Guide to Implementation (UK) OGP Checklist for an audit of safety management Resulting additions to the TC model: Continuous Improvement Feedback Annual Management Review of the SMS Contractors must meet safety standards which do not impinge on the SMS of the organisation Inter and Intra-company Safety Performance Comparison

15 1. Safety Management Plan 6. Emergency Preparedness
Safety Policy Non-punitive Safety Reporting Policy Roles, Responsibilities & Employee Involvement Communication Safety Planning, Objectives & Goals Performance Measurement Management Review The TC SMS Model 2. Document Management Identification & Maintenance of Applicable Regulations SMS Documentation Records Management 3. Safety Oversight Reactive Processes Proactive Processes Investigation and Analysis Risk Management 4. Training 5. Quality Assurance 6. Emergency Preparedness

16 Course Development Addressing Gaps: Audit Approach
Approach to Assessing SMS: Assessors vs. Inspectors The TC SMS Model vs. Plan-Do-Check-Act

17 Course Delivery Initial 4-day course (‘03-’04)
19 deliveries V2: 4-day course (’04-’05) 18 deliveries V3: 3-day course (’05-’09) 15 deliveries (eLearning course starts in fall ‘09) 2-day awareness course 2-day multi-model course ½ day refresher course

18 3-day Course Content History of SMS Introduction to TC SMS
SMS Elements Safety Management Plan Documentation Safety Oversight QA, Training, EPR Safety Performance Measurement Safety Culture Implementation of SMS SMS Evaluation Guide Process to Assess Industry SMS Completing the Assessment

19 The Assessment should get to the “Real” Issues !!

20 Addition of Broader Audit Approach
DOs used to inspections and checklist-driven audits ‘Process’ vs. ‘procedure’ view not well differentiated: had to get up out of the trees No methodology for producing defensible, quantified assessments of SMS: development of the SMS Assessment Process

21 SMS Assessment Process
Pre-Assessment On-Site Observations Post Assessment and Follow Up

22 Assessment Criteria

23 Plugging the Holes with PDCA
Gaps in management system elements identified in course design were not addressed until V2/V3 of the course: Management review Proactive process (risk management) Some backlash from attendees as a result, however intent was to arm DOs as best possible to allow them to engage industry

24 Institutional Challenges
SMS needs a Paradigm shift within aviation from : DOs are responsible for aviation safety responsible for operator’s actions and take accountability for them Operators must get all actions approved by TC Audits of operators are only done by DOs and the operators cannot be trusted to do carry out internal ones themselves Conflict of interest in the "old way of doing things"

25 Regional Challenges Different degrees of involvement and engagement by Regional Directors Regional cultural differences: adversarial vs. partner approaches from POIs/PMIs

26 Internal vs. External Reaction
Within TC: Sounds good in theory Are we prepared to back this up? How does this system scale from large to small? Will TC really enforce the SMS CARS?

27 Internal vs. External Reaction cont’d
Within industry: Larger operators/AMOs/airports: we do this now (but may lack some rigour…) Hazard analysis and identifying risk significant activities often a weakness Smaller operators: what is it exactly that you want me to do (and when exactly do I get to make a living…)?

28 In Conclusion Training of TC Civil Aviation a major undertaking (time, personnel, cost) Paradigm shift just now starting to show broadly in TC Communicate, communicate, communicate: can it ever be enough? We see senior managers taking more of a lead, and see that aviation experts are needing to become more proficient in management

29 In Conclusion cont’d SMS is about risk control - the loop of hazard-risk-objectives-measures-audit-management review drives a big shift in the way management perceive their roles and forces communication into the organizations Tough part awaits: small operators Grateful to have been able to play a role

30 Questions


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