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Transport Canada to Implement new State Safety Program (SSP) Requirements

Set out below is a link to a notice from Transport Canada on training for the new State Safety Program requirements. HAC concerns stem from the fact that part of the industry (CAR 702, 703, 704) – while they have been encouraged to implement SMS, Transport Canada has been unable to implement a regulatory requirement for SMS at for the last 11 years.  At the same time FRMS is coming – using SMS principles and systems as its foundation. The airline-style SMS in place today, and the airline-centric FRMS that is under development are simply beyond the reach of small operators. Just as it will be very difficult to establish a compliant SMS in the absence of a regulation, it will also be difficult to establish a compliant FRMS without a compliant SMS. 

And now, Transport Canada is apparently compelled to establish an SSP, using safety risk management principles – which will undoubtedly flow down to industry when no one really understands what is required from a regulatory perspective for an SMS that is the foundation for it all. It’s like starting to build a house without a foundation. And now we keep adding floors, just to torture the analogy. Everybody inside Transport Canada and industry THINKS they know what an SMS, is. The problem is, they are often thinking about different things.  If TC ever develops SMS regulations for smaller operators – “scalable for the size and complexity”, the industry will be faced with untangling their own home-brew SMS – developed voluntarily with the advice of their inspectors and consultants - only to have to re-build a new system in the image of the new regulations, if the regulations ever happen. A costly and time consuming exercise. In the meantime, the confusion will cripple the process of establishing an FRMS for smaller operators and make TC’s new SSP considerably more difficult to implement for the regulator and industry. 

At some point HAC believes that senior management needs to ask staff how this house can continue to be built without a foundation – since TC seems to be intent on building a skyscraper.  Don’t misunderstand me. HAC has been a supporter of SMS since its inception, but TC is making it more and more difficult for smaller operators; the regulator; and the cause of safety, to benefit. 

HAC believes, at its heart, the problem is that Transport Canada seems to have time and resources to develop regulations for the CAR 705 segment of the industry, but not to make the necessary changes to them in a sensitive way, so that they “fit” small operators. I include the new Fatigue Management Regulations, FRMS, and SMS in this class.

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