Here are some typical questions and answers regarding the implementation of safety management systems in civil aviation organizations. If you still have questions about SMS implementation, please send them to us.

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I. Regulations and Exemptions

1. How does a SMS differ from traditional safety control methods?
    
2. Is SMS a return to prescriptive regulation?
    
3. Will the Transportation of Dangerous Goods Regulations be amended to facilitate SMS?
    
4. If most of the elements of a SMS already exist in most companies, why is Transport Canada requiring that companies implement this new system?
    
5. What is the relationship between Canadian Aviation Regulation 706 and Canadian Aviation Regulation 573 when the certificate holder is the same?
    
6. To what level must an organization document its SMS processes?
    
7. What are the requirements to be followed by an air operator that is not the holder of an Approved Maintenance Organization (AMO) Certificate?
    
8. When will the 705 Operators and Aircraft Maintenance Organizations receive their exemption letters for safety management systems (SMS)?
    
9. The recent update to Standard (Std) 573.06 of the Canadian Aviation Regulations (CARs) introduces training requirements related to safety management systems (SMS) (Std 573.06 (8)). While some of the training requirements were in place previously (e.g. Human Factors), there are some more specific requirements now being identified. CAR 107 specifies that SMS only applies to AMOs that can perform maintenance accomplished on aircraft operated under Subpart 705 of the CARs. The exemption only applies to AMOs that can perform maintenance accomplished on aircraft operated under Subpart 705 of the CARs.
   
   Is Std 573.06(8) applicable to all AMOs?
    
10. If there is an election called and parliament dissolves how will this impact the anticipated dates of regulatory promulgation?
    
    
11. What is most significant about the finalized Canadian regulatory amendments related to SMS on June 15, 2005? Are Transport Canada’s regulations and guidance material fully in place, or will further amendments/additions occur in 2006?
    
    
12. If an organization is the holder of more that one certificate, is the SMS for the whole organization (all certificates) under control of the Person Responsible for Maintenance?
    
    
13. What is the status of an Air Operator Certificate (AOC) or an Aircraft Maintenance Organization (AMO) certificate when an enterprise that meets the eligibility criteria for the safety management system (SMS) implementation exemption has voluntarily surrendered their certificate?
    
    
14. Does the Canadian Aviation Regulation 573.04(4) requirement mean, in effect, that only a maintenance specialist may hold the position of SMS manager in a dual certificate organization?
    

II. Accountable Executive

1. Who is the Accountable Executive?
    
2. How are the responsibilities divided between the Accountable Executive and the existing key personnel?
    
3. What are the legal implications associated with the designation as an Accountable Executive?
    
4. Does Subpart 6, Accountable Executive, apply to manufacturers?
    
5. Is a president the same as a chief executive officer if the company only has one or the other?
    
6. Who is the Accountable Executive of a government air service?
    
7. In Transport Canada’s guidance material entitled Implementation Procedures Guide for Air Operators and Approved Maintenance Organizations (TP 14343) there is an “Accountable Executive Selection Flow Chart”. One of the questions in the diamond asks if a board of directors controls the organization. What does controlled mean?
    
8. The board of directors represents the shareholders and often the chairman of the board is the majority shareholder. Should this person be the accountable executive?
    
9. To provide assurance to the accountable executives that this position will not involve the risk of personal liability, what applicable statutory or regulatory reference is available to substantiate the statement that any action taken against the accountable executive will not result in personal liability and that action is taken against the organization?
   
   
10. In a June 2005 news release, The Honourable Jean-C. Lapierre, Minister of Transport, said that no two safety management systems are alike because each SMS is tailored by the individual company to its policies, management and employee practices.
    
    Why is the requirement to appoint an accountable executive non-negotiable despite the interest in flexibility?
    
    
11. At what level of detail does the accountable executive really have to be involved during an SMS assessment? To what extent are front-line personnel expected to understand and use SMS terminology to frame explanations of their roles and activities?
    
    
12. Does the accountable executive change when a company goes in receivership and a receiver is appointed with personnel and financial control of the company? Is the receiver the new accountable executive?

III. Implementation

1. What is the plan for implementation of SMS?
    
2. When will SMS implementation begin?
    
3. What are the main challenges in implementing a SMS and how long will it take to implement?
   
   
4. In a speech at the Global Aviation Information Network (GAIN) World Conference in September 2004, Merlin Preuss, Director General, Civil Aviation, Transport Canada said that basic principles of SMS seem simple, but that implementing them involves overcoming resistance to change (especially cultural change), scepticism and misunderstanding of concepts. He said then that Transport Canada was applying lessons learned while implementing SMS requirements for various categories of operators.
   
   How has Transport Canada continued to experience such resistance in 2005? What are some specific examples of related challenges that Transport Canada has overcome, and persistent challenges, in working with Canadian operators?

IV. Enforcement

1. Is there an enforcement program as part of SMS to provide a deterrent to unsafe practices and non-conformances?
    
2. What will Transport Canada's response be when they are advised an employee of a certificate holder has been disciplined (fired) for reporting safety issues?
   
   
3. How does the requirement for Principal Inspectors to oversee internal incident reporting align with the notion that SMS should allow Transport Canada to shift the focus from direct operational oversight to assessment of organizational systems?

V. Assessments and Audits

1. How will the effectiveness of an individual organization’s SMS be assessed?
    
2. Will SMS replace Transport Canada audits?
    
3. How will SMS affect the size and nature of Transport Canada audits?
    
4. With the introduction of SMS, who is responsible for performing the risk analysis?
    
5. How will Transport Canada deal with risk assessments, which could be subjective and may vary from organization to organization.
    
6. Will safety management system assessments be exempt from Access to Information and Privacy (ATIP) requests?
    
7. What process will be in place if an organisation does not agree with their rating/score?
   
   
8. How far has Transport Canada progressed in the development of systems and training that enable inspectors to act/intervene at the operator’s system level rather than the operational level, and why is this retraining so important?
   
   
9. How does Transport Canada ensure that SMS assessments do not become either oversimplified or subject to wide variations caused by subjective judgment of assessors?
   
   
10. At what level of detail does the accountable executive really have to be involved during an SMS assessment? To what extent are front-line personnel expected to understand and use SMS terminology to frame explanations of their roles and activities? This is a duplicate of question 11 under Accountable Executive.
    
    
11. What does an operator gain from scoring bonus points in the Canadian SMS assessment method?

VI. Benefits

1. Will SMS be affordable to industry organizations who may be struggling economically, particularly for the small operators?
    
2. How can SMS be applied to a small operation and how can the costs be justified?
    
3. What is Transport Canada’s response to a small operator who has operated for many years without accidents or serious incidents? Why should such an operator, with a perfectly clean record, have to implement SMS?
    
4. Under SMS, will Transport Canada Inspectors have fewer opportunities to evaluate industry’s ability to provide safe, efficient transportation?
    
5. With the introduction of SMS, is Transport Canada relying on industry to monitor and correct problems?
    
6. Once SMS is implemented, how will Transport Canada explain the industry self-auditing and self-reporting to the traveling public?
    
7. Once SMS is implemented what mechanisms will be used to evaluate its contribution to aviation safety?
    
8. How can the safety target goals within Flight 2005 be met when the implementation of SMS, as indicated in Flight 2005, will not be completed by 2005?
   
   
9. Can you elaborate on Transport Canada’s concern about a future lack of sufficient technical personnel in civil aviation to conduct conventional oversight activities, and reasons for your confidence in SMS as the solution?
   
   
10. Have operators shown the positive link between safety and efficiency? Do operators typically have to modify their financial accounting systems to track SMS-derived safety improvements to the bottom line?

VII. Components

1. What is meant by a reporting culture?
    
2. Why should an organization willingly allow the regulator to learn of mistakes through the organization’s internal data collection? What is to stop the company from covering up to avoid repercussions? Also what prevents competitors from eventually hearing about the problems?
    
3. What role does risk analysis have with respect to reporting?
    
4. Will the Aeronautics Act, Access to Information Act and/or Privacy Act require amendments to ensure the non-disclosure of sensitive information?
   
   
5. How important is the degree of freedom given to operators in Canada to implement SMS (versus more prescriptive requirements)? Does Transport Canada nevertheless discourage copying of another operator’s basic safety policy (or similar practices) among operators?
   
   
6. Transport Canada is among organizations that show emergency-response plans as a basic element of SMS. Why was this included, and why has a similar link between SMS and aviation security been omitted?
   
   
7. How does a company include service providers (i.e. contract baggage handling) in their SMS?  Is it mandatory for a company to include contractors and service providers in their SMS?  Contractors and service providers can include both foreign and domestic (i.e. contract cleaners, meal providers etc.), so will there be any bilateral agreements? Will SMS be mandated for aviation service providers?
   
   
8. One of the components of the SMS is quality assurance, which is required in Phase 4. Would a small operator under subpart 704 be expected to have a program such as Threat and Error Management (TEM) or Line Oriented Safety Audit (LOSA) in place for flight operations quality assurance?
   
   
9. What are Transport Canada's expectations with regard to the documentation requirements of 705.152(2) and 573.31(2), where the organization has chosen to adopt an overarching corporate safety management system (SMS) Manual?

VIII. International Leadership

1. How is Transport Canada playing a world leadership role in implementing safety management systems?
   
   
2. Why would you anticipate that SMS gradually would have a positive effect globally despite the diversity of cultures and operational practices, and how does the Canadian experience to date support this expectation?
   
   
3. In what ways has Transport Canada been open to assisting other civil aviation authorities and non-Canadian operators to adapt/replicate your SMS concepts, best practices and training programs (proactively or on request)?
   
   
4. In your opinion, can operators and civil aviation authorities in developing (low-resource) countries also accelerate improvements in their safety performance and otherwise benefit by adopting SMS?

IX. General

1. Are there any precedents for SMS in other countries and/or industries?
    
2. What support will Transport Canada provide to assist operators in implementing SMS?
    
3. How will SMS impact the day-to-day work of Transport Canada inspectors?
    
4. Does not all this emphasis on the system tend to dilute the need for individuals to be responsible for their actions?
    
5. Has the adoption of the SMS program itself undergone a risk assessment?
    
6. If the system fails what can Transport Canada do about it? For example a company may have an SMS, but nevertheless suffers an accident. Let’s say a pilot loses control during an IFR approach. Does Transport Canada fault the SMS? Is this a pilot error? In fact, has anything really changed in the way we deal with the situation?
    
7. There are a number of courses being offered through training organizations on the subject of safety management systems (SMS). Does Transport Canada have a list of training organizations and courses that fulfill the training requirements outlined in the Canadian Aviation Regulations (CARs)?