This report should in no way be interpreted as an assessment of the industry participants’ compliance with developing Transport Canada Civil Aviation Safety Management Systems.

Acknowledgements

This project’s success is the result of the dedication, hard work and unreserved participation of our sixteen industry partners, their employees and Transport Canada’s team members. A list of companies and Transport Canada participants is available in Appendices B and C.

Table of Contents

Executive Summary
Purpose
Background
Project Details
Recommendations
Appendix A – Terms of Reference
Appendix B – Industry Partners
Appendix C – Transport Canada Team Members
Appendix D—Complexity Charts

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Executive Summary

In response to industry observations regarding the implementation of safety management systems (SMS) in small operations and as part of Transport Canada’s continuous improvement process, the SMS Small Operator Pilot Project (SMS SOP) was established in May of 2005. The goal of this project was to evaluate the guidance material, tools and implementation processes developed by Transport Canada (TC). 

From a large group of volunteers, the pilot project comprised sixteen enterprises from across Canada. The enterprises ranged in size from one person, single certificate operations, to a fifty-employee, multi-certificate organization. The certificate holders were given a condensed timeline of one year to implement SMS. The compressed timeline presented a greater challenge to the participant companies than would be experienced by companies following the intended three year phased implementation schedule.

Results from the project indicate that SMS can be successfully implemented and become a positive addition to small operations.  However, the industry–TC project team identified the need to continue to develop and/or update infrastructure in the following areas:

• implementation procedures;
• guidance material;
• data management; and
• training.

Full details on these items can be found in the Recommendations section of this report.

Purpose

In accordance with the SMS SOP Project terms of reference, this report represents the final project deliverable. It provides information on SMS SOP project activities, including recommendations. The report and its recommendations pertain to Canadian Aviation Regulation Subparts 406, 573, 702, 703 and 704.

Background

During the September 2004 Joint-Part V/VII SMS Canadian Aviation Regulation Advisory Council (CARAC) meeting, industry stakeholders expressed concern regarding the application of SMS to smaller air operators and aircraft maintenance organizations (AMOs). Transport Canada Civil Aviation (TCCA) then committed to establish a trial implementation of SMS with selected small operators to validate TCCA assumptions, recommend changes where applicable and provide a foundation for the next phase of implementation.

Project Details

On January 27, 2005, members of the Part V and Part VII CARAC technical committee were invited to name companies interested in voluntarily participating in the project. A total of 16 companies were selected from those that volunteered. These 16 companies (Appendix B) represent a broad distribution of certificate types, company complexity and regional diversity.

To achieve the CARAC mandate, a regionally-based, headquarters-managed project team was selected (Appendix C) and terms of reference (Appendix A) were developed to outline project objectives, accountability, etc.

The project objectives:

• Identify a cross-section of small air operators, flight training units and AMOs, taking into account such factors as: number of employees, aircraft types and/or ratings, scope and types of operation and operating environment;
• Review implementation strategies for the currently proposed regulations for small companies and make recommendations regarding any required changes;
• Evaluate the tools and guidance material on SMS developed by TCCA and document any recommended changes;
• Evaluate the current implementation plan for SMS and document any recommended changes;
• Provide a written report within a practical timeframe to allow project recommendations to be considered.

All objectives were met during the course of the project.

In consulting with TCCA’s Regulatory Affairs division, it was determined that final project recommendations would be required by the end of October 2006. In order to meet this deadline, the team, in cooperation with its industry partners, suggested that a 4-phase implementation process would be optimal, mirroring the one detailed in TC’s Safety Management System Implementation Procedures Guide (TP 14343). However, for the purpose of this project, the phases were to extend over one year and one month, rather than three years and three months.

Project start and finish dates were fixed, but completion dates for individual phases remained flexible. As a result, companies progressed through the process at different rates. This allowed the team to assess how small operators might actually implement SMS.

One of the first issues confronting the team was to define what constitutes a “small operator”. It became apparent that the term is a misnomer. What was needed was a means to measure an organization’s complexity. The original list of industry volunteers consisted of operations ranging in size from one-person to several hundred employees. In order to manage such a diverse group the team initially classified the companies according to the Partsof the Canadian Aviation Regulations and then identified several complexity factors for each. By applying a weighting calculation (Appendix D, Chart 1) to the complexity factors, a means to quantify the qualitative term “small operator” was developed. This resulted in Chart 2 (Appendix D), which shows the complexity scoring of participant companies from across the country. This chart demonstrates a wide distribution across a range of small operations.¹

The TC team held an initial meeting on May 10, 2005, in Toronto, followed by regularly-conducted teleconferences and face-to-face meetings in Calgary, Halifax, Montreal and Ottawa. Industry partners and TC team members also maintained regular communication through face-to-face meetings and telephone or email. In addition to day-to-day project contact, two industry–TC teleconferences were held on July 19 and 20, to ensure industry partners were given the opportunity to discuss the project directly with all TC representatives. Industry participants who were unable to attend the teleconferences were provided with a written copy of the questions that had been raised, allowing an alternative opportunity for them to communicate their comments. Additionally, to raise awareness of the project and ensure that companies, industry associations and government employees had opportunity to be heard; SMS SOP project team members participated in a number of industry and government conferences across the country throughout the duration of the project.

The project indicates that an SMS can be successfully implemented in a small operation and become a positive addition. The following are some of the comments received from industry partners at the conclusion of the project:

• “SMS has resulted in identified savings of $35,000 in the past year”.
• “SMS will definitely make our company more safety-aware”.
• “Everyone is currently working in separate silos; this system is pulling all groups together and will thus increase overall safety”.
• “Two major sections will benefit from this system: First is the actual organization and second are the students that will be briefed on SMS and made aware of it as they enter the system”.
• “We recognized benefits to the improved working conditions for the employees”.
• “We used SMS to integrate other programs such as health, safety, and environment programs into our organization, thus bringing our company up to Canadian codes”.

The industry–TC team also identified that the SMS infrastructure, as it is today, is designed for large operations and that further adaptation of the infrastructure for small operations is required. Details of those areas and associated recommendations can be found in the Recommendations section of this report.

¹ Two interim project reports providing additional project details were produced. They can be viewed on TCCA’s SMS internet site at: http://www.tc.gc.ca/CivilAviation/SMS/menu.htm

Recommendations

The SMS SOP project demonstrated that a safety management system could be successfully implemented in and become a positive addition to a small operation. However, the industry–TC project team also identified the need to continue to adapt SMS infrastructure in the areas outlined below.

Note: Recommendations do not necessarily appear in order of priority.

For more information on this report or the SMS Small Operator Pilot Project, please contact:

J.A. Brad Fowles
Project Manager, Safety Management Systems, Small Operator Pilot Project
Transport Canada, Civil Aviation
613‑998‑5321| facsimile 613‑998-7416 | TTY 613‑990-4500
E-mail: fowlesb@tc.gc.ca
330 Sparks Street
Ottawa ON  K1A 0N5