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Who’s Auditing the Auditors?

Periodically, I get my ear chewed off by an operator. Most of us in the industry are passionate about what we do, so I genuinely appreciate it when I get a call from a member who takes the time to speak plainly about an issue that is important to them. It could be about the pilot-shortage, or Flight & Duty Times – or in this case, about SMS, and a trend in our industry, to use third-party Auditors – some with a questionable pedigree. The following will summarize concerns about some Auditors and their use of SMS that were raised with me, recently.

Most operators actually appreciate a good audit – if the auditor is qualified, and the audit is carried out fairly. Sometimes, however, the third-party Auditor comes with questionable qualifications, and they understand little about our industry segment. They may not even have a background in flight operations or maintenance, at all.

While many operators believe in and understand the principles of SMS, some Auditors “make it up as they go along”.  Some auditors are motivated to make Findings that are not based on evidence. Some make up standards that are beyond the reach of small operators. It was never intended to be one-size-fits-all.  Part of the “promise” of SMS was that it would be “scalable for the size and complexity of the operator”. As it is, Transport Canada cannot deliver on that promise to the Aerial Work, Air Taxi and Commuter communities.  Audited companies cannot even point to a regulatory standard, to determine what standard should be applicable. There are many who claim they understand what, and how SMS should be implemented. Some claim that, if “One Check Ride is safe, then two Check Rides is better” “If an 8-hour flying day is safe, then 4 hours is twice as safe”. Some have claimed that Flight Pay or Productivity Bonuses are unsafe because they will drive pilots to fly beyond safe limits – to push the weather, or to fly below fuel reserves, or continue flight with unserviceabilities, or to fly fatigued. In the absence of data or a Canadian regulatory standard, some Auditors will claim that the EASA standard for IFR operations and multi-engine operations is the Gold standard that should apply to Canadian SE operations.  Some customers, through their Auditors, impose a requirement that no aircraft should be “older than seven years”. A complex SMS is only relevant to larger companies – for the rest of the industry, it only serves as a distraction, and a paper exercise – and it becomes counterproductive to safety. 

The regulator, if they believe that SMS is so important, should stop making reference to SMS, until they can find a way to truly make it scalable to the size and complexity of a small operator, and put it in to regulation.

Finally, SMS should be based on real data, and science, and evidence, and operational experience. Our industry should band together through HAC to urge our customers to hire Auditors with real experience, and an understanding of our industry. As it is, some auditors are just making it more costly for operators and our customers – without adding any value. If Transport Canada completes their part of the bargain, then operators will be held to account for the SMS system that they designed – and Transport Canada approved, in accordance with the regulations. Then the experienced Auditors will only make reference to its requirements in the context of an Operators COM – and the TSB will only make reference to it in this context, too. That’s the way the system should work. What’s more, HAC should develop an HAC Audit Template, that will serve as a guide to what a reasonable and prudent operator is doing in our industry.

HAC welcomes the views of its members on this subject. Please contact fred.jones@h-a-c.ca or on his cell at (613) 884-1422.