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  8. Speaking Notes for the Director General Civil Aviation, Martin J. Eley, at the Helicopter Association of Canada Convention

Speaking Notes for the Director General Civil Aviation, Martin J. Eley, at the Helicopter Association of Canada Convention

VANCOUVER, B.C.
MARCH 26, 2011

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Good morning. I’d like to thank you for inviting me to speak to you today.

It is both a pleasure and an honour to have been asked to address you at this convention. The long-standing relationship between Transport Canada and the Helicopter Association of Canada stems from a mutual commitment to safety in your sector of aviation.

We at Transport Canada recognize and appreciate the importance of HAC’s contribution to the country’s business and economic development and we stand proud of your reputation for having a sophisticated, responsible and safe transportation system.

You deserve credit for all of the work you do in keeping the skies safe.

AVIATION SAFETY IN CANADA

Canada has one of the safest air transportation systems in the world – A fact recognized by the International Civil Aviation Organization. Last year, the total number of incidents was the lowest recorded figure in 10 years. In the last public confidence survey, 96 percent of Canadians expressed confidence in Canadian aviation. Those are numbers we can be proud of. What’s more, business is picking up after the economic slowdown. Air movements are at historical highs and continue to rise. 

During the last few years, our department has undergone fundamental changes in its approach. In our own efforts to rise up to many challenges, TCCA has been making a move towards being more strategic and planning for where we see our organization in the future. We are already receiving international recognition for the approach we are taking and the world would like to adopt many of the safety practices we are already years ahead in implementing.

The last decade has seen a shift toward our vision of an integrated and progressive civil aviation system that promotes a proactive safety culture. Air travel is safe and we want to keep it that way. To do that, we must continually seek out ways to further improve safety. The strategy that we have chosen is to adopt a systems approach for the proactive identification of risks to safety.

SAFETY MANAGEMENT SYSTEM

Over ten years ago, Transport Canada introduced Safety Management Systems or SMS to the Canadian aviation community. The goal: to develop a culture where every part of the community – regulator, operator, aviation personnel – assumes responsibility for aviation safety. It moves us from the 20th century system when decisions were largely made in response to an incident, to the 21st century where the benefits of using a proactive model are becoming increasingly clear. It is important to remember that SMS regulations are like any other regulations – Transport Canada puts them in place, operators comply and TC enforces them.

When an incident does occur, the Transportation Safety Board identifies causes and TC makes any necessary adjustments. But, reaction by definition means we are too late. From what we now know from experience, having an SMS in place further provides safety through proactive risk management and instills accountability. Most importantly, a systems approach provides an organization with the capacity to address safety issues before they lead to an incident.

For an SMS to be effective there has to be a willingness to change the way both the regulator and the industry conduct their business. Similarly, the transition to SMS has necessitated a change in the way we conduct our own business and an assessment of where the regulator is in respect to the development of its own internal safety culture.

Due to timing concerns raised by industry, TC elected to delay the implementation of safety management systems for small operators.  As part of its continuous improvement system, Civil Aviation has adjusted the implementation schedule to provide additional time to refine procedures, training and guidance material based on inspector and industry feedback.

Transport Canada plans to introduce the regulations for small operators in 2012.

TC has increased dialogue with industry organizations, such as yours, to discuss SMS requirements and to offer guidance as they develop their own tools to assist their members with implementation.

Flexibilities within our oversight program allow us to continually evaluate and adjust priorities to focus our attention on safety-critical issues. TC will continue to work with our partners in industry to improve our regulatory oversight program, inspection procedures and tools.         

Our focus is to promote a non-punitive reporting culture, encouraging corrective and preventative measures, and use the knowledge gained to make improvements across the industry.

This has been a real team effort. Inspectors in the field are providing us feedback and procedures, tools, training and guidance material are being refined. This is also a good example of our own management system at work – continuous improvement, collaboration, consultation, and standardization! We will apply what we have learned when introducing SMS regulations for smaller operators.

Thus far, it has been and continues to be a journey of lessons learned. We are working hard every day to refine our practices and evolve an already exceptional air safety system. As we move forward, we are seeking out areas where further improvement is necessary.

SMS is the global standard and our work has put us ahead of the world. I stand proud that our experiences can be used as a model for other authorities from around the world to follow as they implement their own safety management system initiatives.  

INDUSTRY ENGAGEMENT

Transport Canada supports the work that HAC has done to date to establish best practices and we recognize the work you’ve achieved in enhancing the existing Canadian Aviation Regulations and Standards.

The CARs represent the minimum acceptable level of safety for operations and therefore, best practices, by definition, should always enhance those established regulatory minima.

The Canadian Aviation Regulatory Advisory Council – or CARAC – provides an opportunity to bring issues forward that HAC wishes to incorporate into regulation, where all viewpoints can be solicited.

Speaking of CARAC, a topic that frequently comes up is how CARAC plans on catching up on the backlog of regulatory initiatives.

The fact of the matter is, we do currently have a backlog of regulatory files. These files need to be reassessed to ensure they are internationally harmonized, aligned with safety management system requirements, are still operationally and technologically current, and consistent with government direction.

Performance-based regulations are one of those government directions. We must assess the feasibility of going from prescriptive regulations to more performance-based regulations for any proposed regulatory amendment. Chances are that some prescriptive regulations will continue to exist in the CARs, given that in some cases, having it any other way would risk compromising aviation safety.

Some of the strategies we’re working on to improve and accelerate the regulatory consultation process are:

  • Streamlining regulatory priorities with Justice, but as well as with FAA and EASA as part of a cooperative regulatory plan;
  • Identifying, through risk assessments, the best possible tool to put a new initiative in place i.e. guidance, information letter, standard, regulation; and
  • Conducting risk assessments, strategic environmental assessments, and cost benefit analyses prior to consulting any proposal for regulatory amendment.

We recognize that our regulatory development process needs to continue to evolve with the increasing demands stemming from stakeholder needs.

Another popular topic of discussion is Flight Duty Time and Fatigue Risk Management Systems. Transport Canada takes flight crew fatigue management seriously and has strict safety regulations for flight time, flight duty time and rest periods that are compliant with international standards. We recognize that the helicopter industry has unique operation environment that is unlike many other air operations.

In order to ensure that these factors are being considered, TC established a Fatigue Risk Management Systems/Flight and Duty Time working group that includes members from industry to review the current regulations and, where appropriate, recommend amendments to the Canadian Aviation Regulations.

The working group will assess the feasibility of incorporating the ICAO’s non-mandatory recommended practices and recommended practices (SARPs) into the Canadian regulatory framework. In addition, the working group will also assess the feasibility of implementing an alternative regulatory framework in which individual operators could establish a fatigue management system that is more specific to their type of operations.

The objective of this initiative is to complement the prescriptive requirements on flight and duty time with a more flexible performance-based approach to fatigue management.

Fred is a member of this working group and I look forward to seeing their recommendations, which we expect to be tabled later this year.

As knowledge on fatigue issues increases with advances in research and scientific studies, modifications to regulations and standards will be made where necessary. Any proposed modifications will be made through the Canadian Aviation Regulation Advisory Council consultation process.

INTERNAL PRIORITIES

During the last hundred years of flight, technology has made a significant contribution to safety. While we cannot improve safety by technological improvements alone, it certainly does play a large role and will continue to make us safer.

Our department is ensuring that the regulatory structure supports evolving technology. Moving forward, TCCA will increasingly recognize new or improved technology to improve safety; a process that begins with determining the potential to reduce risk or improve business operations.

One of our key strategies will be to increase stakeholder confidence in our department’s certification process of new and innovative products and services. It is important that we create an environment that increasingly supports the aviation community’s development of new technologies in aircraft design, aircraft operations and other technical areas.

Given that international collaboration continues to be an ideal method of learning how other countries are increasing aviation safety, TCCA will also work with international partners to integrate global technologies that will evolve safety here at home.

In the past year, our department set out to determine strategies to improve safety. This led to an analysis of not only external factors, but also internal factors. From this analysis, several strategies emerged to carry forward aviation safety.

First off, we want to advance data-driven decision-making by expanding the data that fuels those decisions. To enhance our ability to detect risks, we want data systems that better integrate our data with that of other sources. To improve our ability to analyze intelligence and respond accordingly, our electronic systems will need to be more effective in gathering and consolidating data. The outcome will result in more informed decisions.

Secondly, we want to continuously improve our service delivery. Our department provides more than 100 services to the aviation community. As the demands change, we need to evolve as well, whether that translates to faster service or improved efficiency. Our goal is to increase the recipient’s satisfaction with these services, while hallmarking safety. To accomplish this, we must not only improve the delivery systems, but also find the right balance between speed and process.

Third, we will enhance our capacity to evaluate the aviation safety program. This means we will continually assess existing regulations, regulatory processes, standards, and surveillance procedures. To do this, we must continue to place emphasis on enhanced analysis of the findings from surveillance activities. This analysis will provide insight into our program: what’s working, what’s not, or what was working but no longer is. We must also enhance quality assurance assessments.

While we carry out these activities, the internal review asks us to assess the effects of our program not only on the industry and the public, but also on our employees. Are our employees equipped to execute new or existing activities as the environment changes? Do they have the necessary skills and competencies? TCCA needs to listen to any concerns that might arise and continually identify and address any gaps in the capabilities of the workforce and the organization’s structure. This is critical to the overall success of the aviation safety program.

Budgets are a regular subject in today’s economy. To ensure that our mandate is carried-out, my directorate has a human resources structure in place that allows program planners to allocate resources based on risk. The system provides the greatest safety benefit and ensures responsible, efficient and effective spending. In addition, flexibility within the structure allows priorities to be adjusted and resources to be reallocated to high-risk areas.

The structure makes it easier to identify the strength of each component of the safety system. Instead of weighing positions against one another, this system starts at the functional level to identify structural gaps that contribute to risk in the safety program. When we identify a risk area, we adjust staffing priorities. This integrated, systemic analysis allows for greater efficiency and makes it easier to target risk areas.

At the end of the day, the one constant in our business is change. Our ability to adapt to change, whether external or internal, will ultimately affect our success moving forward. We have to continuously improve on this in order to enhance our organizational dexterity. While we cannot predict a natural disaster, we can continuously evolve our ability to adapt.

EXTERNAL PRIORITIES

Safety is a shared responsibility – I’m sure that many of you can attest to that. Transport Canada wants to continue developing our working relationships with the aviation community to further this community’s trust and confidence in TC and the work we do.  

We recognize that the future of aviation in Canada requires a healthy working relationship and healthy discussions between industry and government.  We will increasingly seek out your innovative ideas to address issues and evolve aviation safety. We will also seek out ways to strengthen existing communication channels, expand safety promotional campaigns and adopt new media practices.

Building trust and confidence also calls for a commitment to addressing global challenges. As aircraft traffic and emissions continue to grow, our work together becomes even more important as we determine how to reduce the effects of aviation on the environment, while continuing to support global air movement demands. We will continually support and promote new alternative fuels, new engine and aircraft technologies to reduce emissions, and new operating procedures and air traffic strategies to reduce fuel consumption.

Furthermore, TC will continually seek out international consensus on the finest methods to reduce fuel burn while accommodating air traffic growth. This includes reducing emissions at the source: aircraft and engine design.

TCCA contributes to nearly all ICAO groups that study the need for new or revised international standards and recommended practices. Moving forward, Canada will continue to work with ICAO to help develop international standards.

We will expand our international engagement and seek out ways to provide multilateral, trilateral and bilateral leadership. We will continue harmonize safety practices with our two biggest international stakeholders: the United States and Europe.

The success of these activities will lead to the development of international safety agreements, the sharing of information and the further exchange of technology.

CLOSING

These internal and external priorities will chart the direction of our department.

As we finalize of our newest five year strategic plan, we must look back at the previous five years to review what we accomplished and what we believe should be carried forward for the coming years. The theme is one of continuous improvement – of safety, of the department, of our relationships with the aviation community, and of international engagement – and being ready to adapt and make changes when and where they are required. We are committed to this and committed to continuing Canada’s tradition as a leader in aviation safety.

The aviation community has risen to the challenge to make the business of flying safer than ever before and deserving of the trust that the Canadian public continues to put in the safety of air operations in Canada. I am proud of what we have achieved together.

Thank you and I look forward to answering your questions.

Date modified:
2011-11-16

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