Components

Q2.  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?

One of the concepts of SMS is a free and uninhibited reporting culture that encourages information to be collected and not used against the reporter in cases of unpremeditated and inadvertent violations.

The purpose of Transport Canada inspecting records is not to penalize the organization. Rather, TC inspects to confirm that the organization has responded appropriately to the problems reported.

With regard to the likelihood of competitors learning of problems, in normal circumstances Transport Canada will not make copies, except in the extremely rare circumstances where they are needed as evidence of deliberate wrongdoing. Since the information will not be taken into Transport Canada records, it will not be liable to requests under the Access to Information legislation. In addition, forthcoming changes to the Aeronautics Act will specifically exempt such information, even if it should find its way into TC records.

This exemption applies not merely to the content of the records, but also to information on a more macro level, such as the number of reports submitted on a given topic. A large number of reports is not necessarily an indicator of a problem, but may well be an indicator of a healthy safety culture. Of far more importance than the total number of reports, is the absence of recurrent reports on a particular topic, once the necessary corrective action has been implemented.

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