VII. Components

Q7. 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?

It would be beneficial if contractors and their employees could be offered entry level training that could enable/facilitate their input to the certificated company's hazard reporting system, including the confidential one. This training could stimulate activity on the contractor's part to upgrade their own management system, to not only meet their individual client's requirements, but to be able to market themselves in the industry as being at least SMS-friendly, if not totally compliant.

While it cannot be mandatory for a company to include contractors and service providers in their SMS, their SMS has to factor in the risks associated with having persons other than employees accessing either aircraft or associated facilities. Even outsiders who have no contact with the airside at all can affect the overall safety picture. Some Canada Labour Code requirements, for example, include persons that have access to the workplace.

If a service provider does have a SMS (or the more likely International Organization for Standardization (ISO) or other quality system qualification) some collaboration could be possible to formally link the reporting systems or other functions. Any formal arrangement would require appropriate documentation in the SMS context at least.

It is unlikely, at least in the short term that any bilateral agreements addressing SMS per se will be forthcoming. That said, the Joint Aviation Authorities (JAA) [read European Aviation Safety Agency (EASA)] is further along than Transport Canada is in the implementation of their mandated quality systems, so it may well be easier for Canadian operators to demonstrate external collaboration with their SMS in the European context. Creative inclusiveness on the part of our operators will drive service providers to be proactive as a sound business decision.

Transport Canada has no regulatory authority outside of the Aeronautics Act and the Canadian Aviation Regulations (CARs), therefore, an entity without a Certificate will not have SMS mandated under the current regulatory framework.

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