One comment that was expressed at the majority of the industry consultation sessions was that the participants appreciated being able to tell Transport Canada, in person, what they think. The aviation industry hasn't had this opportunity very often and would like to see more of these sessions. If more informal meetings like this one were held, the working relationship between
Transport Canada and the aviation industry would improve, more information would be passed among the participants, interpretations of the regulations could be provided and misinterpretations of the regulations could be resolved. Agenda items could be submitted by the industry to discuss specific problems of interest to them. These meetings would also provide Transport Canada inspectors with more insight into the Air Taxi industry's operating practices and difficulties.
SR 56 - Recommend Transport Canada facilitate information sessions to provide a forum for the exchange of ideas and information between Transport Canada and the Air Taxi industry.
IA 56 - Recommend air operators, pilots, AMEs, Air Traffic Control/Flight Service Station personnel actively participate in these sessions. Recommend air operators support their employees' participation in these sessions.
The SECURITAS program run by the Transportation Safety Board provides a method for members of the aviation community to confidentially submit information about incidents or potentially unsafe acts or conditions. It was criticized as not providing feedback to the people who submit information and also not providing information to Transport Canada System Safety. The Federal Aviation Administration (FAA) has established the Aviation Safety Reporting System (ASRS) that is being administered by the National Aeronautics and Space Administration (NASA). The program allows people to report incidents, occurrences and potentially unsafe acts confidentially and with impunity, except in cases of an aircraft accident or criminal activity. Valuable information can be gathered to identify where resources should be allocated for accident prevention programs and also provide information about industry operating practices.
SR 57 - Recommend Transport Canada establish a confidential reporting system for safety concerns and regulatory infractions modeled after the NASA Aviation Safety Reporting System (ASRS).
Transport Canada's audit and inspection methodology was criticized as not being sufficiently operations-oriented and not occurring frequently enough. Inspections and audits that check only the paperwork don't give a true perspective of the actual operation. As an example, since aircraft inspections are done in a stationary aircraft rather than when the aircraft is in flight, the inspector can only confirm that the instruments are installed, not that they are functioning. If Civil Aviation inspectors performed "inflight" inspections, especially now that industry has more delegated authority to perform pilot proficiency checks, it would provide Transport Canada with a better understanding of operating conditions, operational practices and pressures. Inflight inspections should be conducted in both single- and multi-engine aircraft.
SR 58 - Recommend Transport Canada conduct more operations-oriented audits and inspections.
SR 59 - Recommend Transport Canada conduct in-flight inspections in Air Taxi aircraft.
Transport Canada was criticized for providing sufficient notice of an upcoming audit that the operator had time to get the paperwork in order before the auditors arrive. Less notice would give Transport Canada a better indication of the air operator's actual operation. Also, more random inspections should be done, especially during the operators' busy season. Pilots commented that Transport Canada inspectors rarely conduct inspections on job sites, that the inspections are limited to ramp inspections or audits. Non-compliance with the regulations was thought to occur more frequently in areas removed from main airports where inspectors are less likely to conduct random inspections. There is also the perception that regulatory compliance is not applied uniformly among operators and that some operators have an obvious disregard for the regulations but Transport Canada is either unaware or chooses to overlook this.
SR 60 - Recommend Transport Canada conduct more random audits and inspections.
SR 61 - Recommend Transport Canada provide more regulatory compliance presence, especially in northern and remote areas.
Transport Canada was also criticized for not conducting follow up of audit findings. When audit findings are not rectified by the air operator, the unsatisfactory operating condition continues and often the deficiencies are noted in the subsequent audit.
SR 62 - Recommend Transport Canada ensure all audit follow-up is completed.
IA 62 - Recommend air operators ensure all audit findings are rectified.
Air Taxi operators and pilots feel that air carrier inspectors do not have the appropriate background to understand VFR issues and issues that are specific to certain operations or regions. For example, the west coast operators and pilots felt that there was no one in Commercial and Business Aviation, Pacific Region who had recent experience in the unique operating conditions of west coast float operations. All Transport Canada inspectors must possess an Airline Transport Pilot Licence in order to qualify for the position. Often this means that the inspector has not been flying in VFR operations for some time before being hired by Transport Canada. The same comments were received from operators and pilots throughout the other Regions. It was suggested that Transport Canada should have inspectors on staff with strong VFR backgrounds who could deal sensitively with VFR issues. Many negative comments were received about Transport Canada hiring inspectors with no commercial operating experience.
SR 63 - Recommend Transport Canada Regional Commercial and Business Aviation inspector personnel are more representative of the demographics of the aviation industry.
The attitude of some Transport Canada air carrier inspectors was criticized as being arrogant and uncooperative. A more cooperative attitude between inspectors and the industry will enhance the working relationship and eliminate the "we vs. they" mentality. Since they are part of the aviation system, air carrier inspectors should be perceived as being approachable and a good resource for information, not just as the regulator who is interested in catching pilots and operators who are breaking regulations. Industry has no recourse if they are concerned about a particular inspector's behaviour.
SR 64 - Recommend Transport Canada establish a conflict resolution program where members of the aviation industry can confidentially report problems with individual Civil Aviation inspectors.
Air operators are most often not aware of exemptions to the CARs or CASS that have been issued to other air operators. Often the air operator spends time determining how to comply with the regulation, time that could be spent involved in other tasks if the operator knew an exemption was available. The de-identified text of exemptions issued to air operators should be available to ensure air operators across Canada are being treated equitably. An exemption may also make the operation more efficient and save the operator money. If a sufficient number of the same exemption are issued, Transport Canada should consider including the conditions of the exemption in the CARs or CASS.
SR 65 - Recommend Transport Canada publish on the Internet and in hard copy an inventory of exemptions that have been issued to air operators.
SR 66 - Recommend Transport Canada analyse all exemptions issued to air operators to determine if any should be revoked and the conditions of those exemptions included in the Canadian Aviation Regulations or Canadian Aviation Regulations Standards.
Not all helicopter pilots wear a helmet even though there is considerable evidence that helmets can prevent serious injury or death in the event of an accident. Many pilots who are not used to wearing helmets complain that they are heavy, hot, uncomfortable and cause fatigue. Pilots are more likely to wear helmets if they are used to wearing one from the time they start flying. It takes time for people to get used to wearing safety equipment as was evident in the phase-in of helmets with hockey players and the phase-in of the seat belt laws. Now, almost without exception, all hockey players are wearing helmets and people are buckling up as a matter of habit. Often passengers in helicopters will have some sort of protective headgear with them, such as a hard hat, that they use while they are working. Passengers should be advised to wear this protective headgear if it is available.
SR 67 - Recommend Transport Canada continue to promote in the Aviation Safety Vortex newsletter the safety benefits of helicopter pilots wearing helmets, especially in aerial work operations, and promote flight training units to encourage student pilots to wear helmets.
IA 67 - Recommend that helicopter air operators, especially aerial work operators, encourage their pilots to wear helmets, that commercial helicopter pilots wear helmets and that flight training units encourage student helicopter pilots to wear helmets.
SR 68 - Recommend Transport Canada promote customer education to encourage passengers who have protective headgear to wear it while in the helicopter.
IA 68 - Recommend air operators and pilots encourage passengers who have protective headgear to wear it while in the helicopter.
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