Friday, March 20, 2009

A phone call a little while back went something like this:

"Hey there Sulako, it's your friendly neighborhood Transport Canada Inspector."

"Ack! Umm, I mean Howdy."

"It looks like you are scheduled for a program validation sometime soon. Let's set one up."

//I take a moment to compose myself so my voice doesn't squeak.

"Okay. A program validation then. What is that? It sounds like an audit."

"No, we don't do audits any more, we do program validations. Basically we validate your SMS. Mostly by auditing you, as it turns out."

//I could hear the grin in his voice, matching the fear in mine.


"Even better Sully, it's a new kind of process and you guys are actually the first ones who will get to go through it."

"#%&@ my life."

"Sounds good Sully, see you next Tuesday at 8am."

Now it's kinda true - there is a difference in what Transport is looking for now when they show up at our office. Before when we'd get audited, they would show up and ask to see all our flight records. Then they'd randomly pick a pile of records and go through them to make sure all the paperwork was 100%. They'd spend hours checking our pilot exams and our flight plans, and poring over our weight and balances to make sure we weren't attempting to put 20 people into 10 seats and whatnot.

Now, the emphasis has changed to SMS, which stands for Safety Management System. It might look subtle, but to me it's a dramatic one. As an operator we are now being asked to put the systems in place to oversee ourselves, and a program validation checks to see if they are working.

For example, instead of being asked to show flight plans for flights, we are asked to show how we know the flight planning software is accurate and up-to-date. Instead of checking our pilot exams to make sure they are all filled out and haven't lapsed, they ask us what system we have in place to make sure all our exams are current and correct. For maintenance, instead of double-checking all our logbook entries for mistakes, they might ask how we intend to find any mistakes we make before they cause any harm.

The intent of this is to have operators regulate themselves - if an operator has a good SMS (safety management system) in place and they follow it, in theory Transport Canada should never have to step in and violate them for anything. Now I totally understand that this is a good idea, but in practice there is a pretty big weakness.

The weakness is that some operators tend to push the limits of safety in pursuit of money. Suppose a shady operator has all the required paperwork in their Ops Manual to indicate that they are perfectly capable of finding and fixing any safety deficiencies on their own. That's great, but what if they don't actually abide by the Ops Manuals? What if they consistently ask their pilots to fly overweight or for illegally long periods of time etc? If an operator doesn't want to address safety concerns then they will be pretty much on their own until something bad happens, like a crash.

Now I'm gonna sound all pompous here for a second, and I apologize in advance. In our operation, safety is a lot more important than money, and money is still pretty important. SMS will work for us because we genuinely want to minimize risk in all phases of flight, and we are willing to spend money to do so. But our situation is unique in that we have the luxury of being a financially secure flight department, and most operations depend on outside revenue for their survival. For those operations, this is going to set up a conflict of interest, where the same people pushing pilots will be responsible for overseeing themselves to make sure they don't push pilots.

It will be interesting to see how the shift to SMS turns out in Canada, and it'll take a few years before we have a better idea.

Anyway, the result of the conversation I had with the Transport guy was a morning spent with him going through a big long checklist and going through our Ops Manual to make sure we had each and every item on the checklist identified and addressed, like "In your Operations Manual, where are the procedures to ensure the flight crew are advised, prior to dispatch, of any aeroplane defects that have been deferred, (by Minimum Equipment List or any other means)".

Hooray! Our paperwork was perfect and we have everything that Transport wants to see, so I get to keep my job, at least until the next validation. A validation where they audit our self-auditing process to make sure we are auditing our audits in an appropriately audit-ful way. I certainly feel validated, don't you? :)


Aviatrix said...

Even if I didn't know you ran a tight ship, I would have known as soon as I read that you were the test case that everything would be fine. When the authorities are debuting a testing metric they always start with a subject they expect to be exemplary. The teacher marks the smart kid's exam first to help her spot any errors in the answer key, or reads the project from the expected best student first to determine a standard to hold the rest of the class to. You can be very proud of your operation and the esteem TC holds you in that you were the test case.

Keep it up!

Jim Mantle said...

Audit letters don't get any better than that.


Rhonda said...

That kind of reminds me of the ISO14001 (environmental management) certification process I went through a few years ago. Lots of checks that the procedures to protect the environment were in place and that the recording and cross-checks were in place and so on and so forth.

However they also spent some time directly with the operators to make sure that they had been trained on the procedures and followed them. And that's one thing that stood out to me as missing in your description here...

phil said...

have you ever seen a meta -pizza?