SMS - Flawed or Fabulous?

The acronym SMS - which stands for safety management systems - has become a standard term in the Canadian aviation vocabulary. Depending upon who you speak with or what aspect of SMS you are covering, it is either a wonderful and great addition to the aviation operational structure or could be laying the groundwork for potential disaster.

What is SMS?

According to the Canadian Council for Aviation and Aerospace (CCAA), SMS is “an integrated set of work practices, beliefs and procedures for monitoring, supporting, and improving the quality of safety and human performance in an organization. SMS assists organizations in recognizing the potential for errors, and establishes robust defenses to prevent them from causing injury or accident.” What the CCAA correctly identify is that SMS is about people and a companywide commitment is key they say to the successful SMS implementation.  It's only through the collective efforts of all members of an organization that SMS will successfully manage human error and safety programs effectively. What SMS is supposed to do is shift the focus from managing safety to as the CCAA best put it,  “managing safely”.

In Transport Canada's (TC) vision, SMS will be implemented in all regulated civil aviation organizations in this country by the year 2015. The TC website states “today the majority of Canada's aviation industry operates with SMS policies, processes, procedures and systems in place, including Canada's largest passenger air carriers. In fact, SMS covers more than 90% of passenger kilometers.” As of October 2011 TC stated that for the remainder the industry (that is those who do not have an SMS in place yet), SMS will be implemented over a three-year phased in period. This will begin after the SMS regulations for the sectors not currently under the system come into force. For small operators, TC has adjusted its SMS implementation schedule to provide additional time to refine procedures training and guidance material based on inspector and industry feedback.

SMS is supposed to help companies identify safety risks before they become bigger problems. As we move forward SMS is becoming the global standard. Canada has led the world and ICAO have taken this country's lead and helped define it as a process and system to be implemented around the world. In November of last year the Air Line Pilots Association International (ALPA) - the world's largest nongovernment aviation safety organization - stated “SMS programs ensure continuing safety bike and binding the appropriate levels of incentive for front-line employee reporting, internal auditing and regulatory oversight.” According to the association's president, Capt. Dan Adamus, “Canada is a world leader in adopting SMS programs in its Marine rail and aviation industries and ALPA is proud to be part of that effort.”

Critics are cautious about being identified – in fear for their jobs or recrimination. But that said they do make some good points. One transport Canada manager stated to me privately that while SMS is a great tool, it should not be the only tool in the box. It should be one of the series designed to promote and assist in safe aircraft operations. And SMS should not be implemented in a manner to replaces the human oversight that many operators require. As another person from TC said, for those who operate properly and in a conscientious manner SMS will be the right tool to help them manage and operate their businesses properly. However for those who with a mindset or predisposition to operate outside of the rules, SMS could allow such folks to get away with things that they otherwise would not.

According to the online site fairwhistleblower.ca (FAIR), when implemented properly such systems (SMS) can ensure greater consistency and reliability of operations. However according to FAIR, the experience of many is that these systems have often not lived up to their promise. They cite sloppily implemented and/or aggressively profit driven organizational cultures that come into conflict with the fundamental aim or intention of the system. As a case in point they quote the 2008 incident when the US air carrier Southwest Airlines was found to have skimped on vital airframe inspections that were designed to detect metal fatigue. Dozens of uninspected and affected airplanes flew in some cases over a period of months. It was only when the FAA inspectors went “public” with the information that they had found cracks in these aircraft that the problems then got fixed. FAIR point out that SMS is often characterized as letting the fox guard the hen house. “Industry insiders such as pilots mechanics inspectors air-traffic controllers have all been especially vocal about what they see as a progressive degradation of air safety in Canada” the group says.

In reality SMS is here and not going away anytime soon. You can choose to work with the process, learn how to operate properly within it, and make it part of your corporate culture in a positive way, or you can fight an uphill battle. As the SMS system itself shows, the process is one built upon refinement and change over time. Experience allows input and refinement based on both positive and negative experiences.

Our throw away society . . .

But the aviation industry is not as bad as the consumer media would have us believe!

Our humidifier was not working. The repairman advised it was going to cost just a few dollars shy of what the whole unit was new. So my decision - repair or replace? The unit is only four years old, properly maintained and was the best you could buy at the time. Needless to say I was not amused.

But this is just the tip of a bigger issue. They just don’t build things like they used to. Take the “white goods” you have at home - fridge, stove, washer and dryer, washing machine and even microwave. Retailers say the days of buying appliances for 15 or 20 years are gone. The average warranty is one year and according to experts you can expect six years to maybe eight before you either fix or throw away – because once again the cost to repair vs. replace makes it attractive to do so.

We have a throw away mentality. Our friends who are into environmentally responsible will tell us, we are our own worst enemies. Our landfills are rapidly getting full with things that do not break down. And we continue to add to the pile.

What about the aviation industry? Are we really all that bad for the environment? After some review and discussions the conclusion I came to was no. Emissions arguments aside, we are better members of society than say the auto industry or “white goods” manufacturers in my view. 

An aircraft comes from the factory with the ability to improve, enhance and develop many times and in many ways over the life of the airframe. From the avionics suite, the entertainment components, the galley, and even the engine and related systems, every part can to be maintained and up rated. That adds life and usability to the whole aircraft increases use over a longer period of time – vs. replacing and scarpping.

Commercial aircraft manufacturers are becoming increasingly responsible for the “cradle to grave” aspect of an aircraft. They build them with a view to how the aircraft can or will be taken apart and disposed of when it is finished its job. According to numbers from IATA, some 12,000 commercial aircraft are on the order books to be delivered by the year 2020. At the same time the Aircraft Fleet Recycling Association (AFRA) tells us that 12,000 aircraft could be scrapped in the next 20 years. By the year 2016, AFRA should have the ability to recycle 90% of an aircraft. That number currently stands in the 80% to 85% at most which is up from less than 50% of a few years ago. Even the airlines - Air France in particular - are increasingly taking an ownership position in the disposal of their retired aircraft.  They now take it upon themselves to play a role in the dismantling and parting out of the components once it is out of service.

 

The hardest parts of an aircraft to recycle come from the cabin – mostly the interior fit and finish. Experts feel the latest aircraft will not necessarily be any easier to recycle.  The reasons lie in the materials being used.  Newer aircraft are lighter and more fuel-efficient due in part to carbon fiber and composite materials. While disposal of these products is far less energy intensive - hence less expensive to recycle - the facilities that are able to do such at present are few and far between. It will be a number of years before a Boeing 787 hits the scrapyard and accordingly one would expect that by that time, the processes and systems to recycle carbon fiber will be as common as those we have today for aluminum.

Some small operators do exist today to help. Take Toronto based Electronics Recycling Services (ERS). They have a line of machines that runs over 3200 linear feet and will take old avionics, cabin entertainment systems and components and reduce it to reusable materials. The handle plastics recovery (granulation of mix materials that are not recoverable via other methods for reuse as fillers for Plastic Lumber Manufacturing Line), an Electrostatic Separation to recover Copper, Lead, Zinc, and Tin plus shredding of all types of electronics, ferrous material separation and aluminum separation can be accomplished by them. They boast that over 90% of what comes in ends up reused in some other manufacturing. While they are growing, they are still a small part of the scrapping system today. More like them need to come along – and soon.

Aircraft have a usable life of 25 to 30 years on average. Automobiles get replaced every 5 to 10 years. There are far fewer airplanes than there are cars, fridges, washing machines and such going to the scrapyards. And with 90% of the aircraft being recycled, aviation is not a bad member of society. We certainly do not contribute anywhere near the amount of others to the ongoing “garbage” pile from humanity.

News TAWS Regulations finally in place.

News TAWS Regulations finally in place.

In early July of 2012, Transport Canada (TC) issued the long expected and final amendments to the CARs (Canadian Aviation Regulations) requiring the installation of TAWS (Terrain Awareness Warning Systems). In brief, these new regulations apply to virtually all commercial air taxi, commuter and/or airline operations as well as larger turbine-powered private aircraft. The applicable CARs are Subparts 703, 704 and 705 as well as high-end 604. TAWS has long been a requirement in the US and other parts of the world.

These rules were drafted over a decade ago, and were originally intended to have had a harmonized implementation with FAA TAWS rulemaking in 2005! The TSB (Transportation Safety Board) has been suggesting, recommending, generally demanding, and virtually begging that the CARs be changed since March of 1995. In a Government of Canada Press release dated December 2, 2011, current Transport Minister Denis Lebel is quoted as saying “Transport Canada is committed to the continuous improvement of aviation safety”. “Our government will continue strengthening aviation safety for Canadians.” “Using TAWS will significantly reduce the risk of airplane crashes with land, water or obstacles.” Apparently after the most recent spate of Controlled Flight Into Terrain (CFIT) accidents and the resulting body count Transport Canada wants to be seen to be springing into action!

According to information from TC in the regulatory change documents for TAWS, the number of CFIT incidents tracked from 1977 to 2009 was the main driver for this new regulation. During that period 35 airworthy aeroplanes were flown into the ground while under pilot control. The CFIT accidents resulted in 100 fatalities and 46 serious injuries during that reporting period. Unfortunately a recent rash of incidents (including a 737) since then has driven those numbers significantly higher.

We had the technology. Aviation safety was just being tied up in a bureaucracy and politics! And as one person stated to the media earlier this year – “sometime people have to die before things change”. In this case apparently a lot of people had to die.

So why has it taken so long to make this proven Safety Technology mandatory in Canada?

The answer is of course bureaucracy and politics - and the problem really is systemic…..read on!

As always there were prominent alphabet advocacy groups and no doubt large organizations objecting to any mandate that would compel their members or companies to spend money. That said, CARAC records indicate that all of these dissents were dispositioned in a typical CARAC timeframe and process. The bottom line is that it really came down to the priorities of TC management of the day……or shall I say misplaced priorities.

Enter the newly appointed Director-General of Civil Aviation at Transport Canada (2002 to 2009) and the TAWS & TCAS NPA’s were simply put on a shelf - indefinitely. Originally the TAWS and TCAS (Collision Avoidance System) NPA’s were “bundled” together. They were both ready for introduction over a decade ago.  In hindsight it appears clear that implementation of such (even proven) technological Safety Systems was not a part of his agenda, and was not going to happen on his watch.

The TC agenda under under this DG was totally focused on SMS (Safety Management Systems) and the belief that this theoretical and paper-driven “systems” approach would be the catalyst for further improvements in aviation safety. While Chairman of the Board of the Aircraft Electronics Association, my associate Barry Aylward, (of Kitchener Aero and Mid-Canada Mod Center) dubbed SMS the “Sadly Misguided Strategy”. It appears that he may very well have been dead accurate……no pun intended!

In shelving those NPA’s Transport Canada Civil Aviation gambled with the lives of Canadians – assuming the risk that there would be no CFIT accidents and no mid-air collisions in Canada during the time those regulations were languishing on the shelf. Well, they were only half-right - there were no mid-air collisions. Although there were a lot of close calls!

In 2006, the TorStar Newspaper Group did an exposé series of articles on Aviation Safety. They investigated more than 800 incidents between 2001 and 2005 in which Canadian planes came dangerously close to one another. More than 80,000 passengers were put at risk in those incidents, according to the study conducted by The Toronto Star, Hamilton Spectator, and The Record of Waterloo Region.

When the (political) smoke cleared, Transport Canada “unbundled” the TCAS NPA’s from the TAWS NPA’s, and propelled the TCAS rules into play in the fall of 2006.  TAWS NPA’s remained on the shelf however, as CFIT had not been (yet) subject to the same media scrutiny. The Transport Minister of the day issued a Press Release very similarly worded to the one just issued by Minister Lebel, wherein the Government of Canada postured itself as springing into action (a decade or so later) to ensure the safety of the Canadian traveling public! Apparently the Torstar series of articles forced political action by the Minister, no doubt to the dismay of Transport Canada’s senior management of the day. 

And the beat goes on…….

We are still waiting for Transport Canada to spring into action and propel the long-awaited NPA’s for UHF ELT’s into legislation. These too have been mired in politics, and I have to wonder what the body count may be by the time these potentially lifesaving devices are finally made mandatory in the Canadian fleet?

Transport Canada is morally bankrupt here. They have only ever acted politically. They have absolutely ignored proven safety technologies in favor of SMS. The Merlin Preuss era has proven to be a virtual reign of terror for the traveling public in Canada. And while senior TC bureaucrats were busy traveling around the world to SMS conferences at public expense, actively trying to portray Transport Canada as the model Regulatory Authority within ICAO, the reality could not have been much farther removed from that ideal.

Transport Canada and its senior management have blood on their hands. It can also be argued that SMS has blood on its hands…..or at least that Transport Canada’s myopic focus on SMS certainly does!            As one TC employee recently said to me, “SMS is but one tool in the box. It should not be the entire box. Some of us are just as frustrated as the aviation community in trying to do the job we know should be done”.

Bureaucracy, Politics and Aviation Safety make poor bedfellows. I submit that it is time for a total RESET….