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Assessments and Audits
Q5. How will Transport Canada deal with risk assessments, which could be subjective and may vary from
organization to organization?
Risk assessments should be the result of sound information collection, logical analysis and thoughtful
decision-making. Provided a risk assessment passes these tests, Transport Canada will accept it. If the risk
assessment is seriously flawed, Transport Canada will not accept it.
Risk assessments are inherently subjective, and that is not necessarily a bad thing. The variations may turn
out to be reasonable and acceptable. In any case, the outside limits are established by compliance. Clearly, a
decision to permit non-compliance with an existing requirement would be a violation in itself.
Short of actual non-compliance, even a decision to do nothing in a case where it might have been more a
prudent to take corrective action, is better than not to have evaluated the situation at all. At least, if the
problem has been documented, the company has established awareness. Also, failure to take reasonable action in
response to a real safety problem will be legitimate ground for a finding that the SMS is ineffective.
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