Pre-Flight

PRE-FLIGHT

An Ounce of Prevention…Parallels Between QMS and SMS Components

by Cliff Marshall, Technical Program Manager, Technical Program Evaluation and Co-ordination, Standards, Civil Aviation, Transport Canada

One of the critical things to consider as you begin the safety management system (SMS) implementation journey is that an SMS, as with any other management system, should be systematic and practical in design, comprehensive enough to adequately encompass all organizational functions, yet simple enough to use. Hence the reason each management system you introduce must reflect the unique size, complexity and character of your organization.

Although there are many similarities between an SMS and a quality management system (QMS)—they are both critical to the functioning of the organization—their outcomes are distinctly different. Quality, and its associated management system, focuses on the characteristics—typically expressed in terms of value—of its products, programs, or services, whereas SMS—with its focus on safety—is the minimization and management of operational risk related to human and organizational factors.

QMS integrates a set of policies, processes, and procedures required for managing structure, responsibilities, procedures, processes, and management resources to implement the principles and action lines needed to achieve the quality objectives of an organization. An SMS shares this structure; however, the focus is on safety objectives rather than product quality issues.

A QMS enables an organization to identify, measure, control, and improve the various core business processes that will ultimately lead to improved business performance through enhanced quality. Again, SMS parallels this continuous improvement philosophy and only differs by focusing on improving safety, not product quality. In an SMS, the quality assurance program (QAP) elements can be applied to human and organizational issues that may have an impact on safety. In the same way that a QAP measures quality and monitors compliance with the Canadian Aviation Regulations (CARs), its related Standards and the procedures utilized by the organization, the SMS measures safety within the organization. Expanding on this further, we can see that:

  • quality assurance data is utilized in planning and designing a process that can repeatedly produce a high-quality product or deliverable;
  • quality assurance provides confidence that if the process and procedures are followed properly, there is a high likelihood that the final product or deliverable will meet specifications. In other words, it reduces and prevents defects or errors in the final product or deliverable;
  • quality assurance activity helps to establish a sound and capable process.

The main components of a QMS are:

  • senior management’s active and positive commitment;
  • good two-way communication throughout the organization, which encourages a culture of initiative and improvement;
  • simple, efficient monitoring systems that enable all levels of management to identify bottlenecks and waste;
  • staff development, including training that provides the correct level of competence for each job and provides staff with opportunities to advance within the organization.

It is clear that there are parallels between QMS and SMS components. SMS is a systematic approach to the management of safety risks. Effective SMS and QMS both require all of the same components; however, the focus is markedly different. The SMS identifies hazards and manages attendant risks. It ensures the competency of the staff and promotes clear two-way communication. Both systems are compatible and, in Canada’s regulatory framework, provide the overarching components of the organization’s management systems that ensure compliance and manage the inherent operational risks. The benefits are measurable and afford the organization the ability to:

  • review business and safety goals, and assess how well the organization is meeting those goals;
  • identify processes that are unnecessary, inefficient or unsafe, and then remove or improve them;
  • review the organizational structure, clarifying managerial responsibilities;
  • improve internal communication, and business and process interfaces;
  • improve staff morale by identifying the importance of their output to the business, and by involving them in the review and improvement of their work.

Both of these systems serve valuable purposes and, when combined, give the organization the ability to identify quality lapses as well as the capability to identify human and organizational issues. Together, these two systems enhance flight safety, ensure compliance, and offer an enhanced approach to managing the business. The old adage applies: safety is good business!

COPA Corner: Checking NOTAMs

Canadian Owners and Pilots Association (COPA)

by Kevin Psutka, President and CEO, Canadian Owners and Pilots Association (COPA)

As I sat in front of my computer, studying the details in the 18-page Olympics NOTAM, I wondered how many pilots would miss the extensive restriction or prohibition on flying that would occur from January 29 to March 25, 2010. Then I recalled a commitment made to the editor of the Aviation Safety Letter (ASL) to write about the NOTAM system and the importance of checking NOTAMs. By the time this article appears in the ASL, hopefully all will have gone well with the Olympics and everyone will have understood and complied with the complicated security measures.

Canadian Aviation Regulation (CAR) 602.71 states that, “The pilot-in-command of an aircraft shall, before commencing a flight, be familiar with the available information that is appropriate to the intended flight.” This is a fairly broad catch-all statement that is open to interpretation as to how much information is sufficient. I suppose that one way to interpret this is that for your VFR romp around the patch you do not have to check anything (although that would be foolish), but if something goes wrong, you could be charged with a violation for not being prepared—which includes checking all NOTAMs that may affect your flight.

Some pilots never check NOTAMs because they assume that for their simple local flight there will be no restrictions or safety issues. After all, they have flown there hundreds of times before. While in years gone by this may have worked in most cases, we are now living in a more complicated world, with pop-up and sometimes extensive restrictions due to security concerns and an increasing number of airspace amendments to make better use of the limited airspace around our growing population centres.

In the “good old days” there were only two ways to check NOTAMs: visiting a flight service station (FSS) to sift through the hard copy listings, or contacting an FSS by phone or on the radio to ask them to scan the NOTAMs for ones that may affect you. This was a labour-intensive process, fraught with plenty of opportunities to miss something. As technology progressed, so did the ways to get at the information and, to some extent, the ways to sort through all of the data for what really mattered for the flight. Now, through NAV CANADA’s weather Web site, it is possible to receive only those NOTAMs that are for stations along and either side of your intended route. However, because of limitations in the NOTAM system, there is still a requirement to view several non-pertinent or relatively insignificant NOTAMs in order to find the really important ones.

COPA has been encouraging NAV CANADA to make more changes to its weather Web site to make the process of checking NOTAMs more practical. For example, the layout of the Web site sets one up for forgetting about the NOTAMs. Pilots typically check the weather first and then drill down for other information if it is suitable to fly. The NOTAMs tab in the on-line report is at the top of the page, making it necessary to go back up to the top of the page to get to this information—an opportunity to forget. Without going into a lot of technical detail, it is not a trivial matter to make some of the improvements, but we can expect a prioritized system that will help to make the critical information stand out.

With the use of acronyms, abbreviations and requirements to adhere to International Civil Aviation Organization (ICAO) convention, it sometimes feels like you need a Ph.D. to understand NOTAMs. To some extent, we are living with the limitations of teletype machines that prevented plain language and use of certain characters. Hopefully, we will move away from these limitations as time goes on.

As for flying in the U.S., if you think that our NOTAM system leaves a lot to be desired, Canada is far ahead of the U.S. in at least having all NOTAMs available in one place. In the U.S., again in part because of past protocols and ICAO conventions, you can miss important NOTAMs because they are considered as “local” and do not show up on some systems. It is important to talk to a flight service specialist to maximize the chances of having all of the NOTAMs that are applicable. The U.S. Federal Aviation Administration (FAA) has been saying for some time that they are fixing this problem with a redesign of the NOTAM system but, for now, be careful when going to the U.S.

For IFR flight, it is important to check NOTAMs frequently because critical items such as minimums for approaches can change without notice due to a variety of factors. But for VFR flight, the volume of NOTAMs that have little or no affect on safety, such as several concerning burned out lights on cell towers, can make it very tedious to find the really important ones. It is, however, worth the time to make that extra effort to find issues that may affect your flight. COPA will continue to work with the authorities to simplify and enhance the system. Now, more than ever, it is important to make that effort.

Right or Wrong, He’s the Boss

A cautionary tale by Garth Wallace

“I’ve been watching you with the students,” Hector said to me.
Hector was manager of a small-town flying school where I had recently started teaching. He was helping another instructor and me pull the three training airplanes out of the hangar.
“You’re doing a good job,” he continued, “but I have a few suggestions.”
I was surprised. I had been busy flying with Hector’s students for five days and rarely saw him. He came to work, helped get the airplanes ready, and then disappeared until the end of the day. He was chatty and friendly when around, but mostly he was out of sight and out of mind. This was the first time that he had said anything to indicate his role as manager.
Roger, the other instructor, stood behind him. He looked happy that I was the target of the “suggestions”.
“I noticed you do ground briefings with each student,” Hector said. “A little talk doesn’t hurt, but students learn better by doing. Don’t waste time on the jawing when you could be flying and giving the customers practical experience.”
I guessed that he was referring to the fact that flying was better revenue than briefing. His comments went against the teaching techniques that I had learned.
“I understand, Hector,” I said, “but students need a pre-flight briefing to make sure they are on track.”
“That’s okay, but don’t cut into the flying so much.”
“Okay,” I replied. I made a mental note to ignore what he had said.
“And another thing,” Hector continued, “I noticed you’re doing a walk-around inspection with the students on every flight. That’s another waste of flying time. It’s okay to show them the pre-flight but not each time. We check the aircraft in the morning, so the students don’t have to.”
Skipping the pre-flight inspection was new to me. “How are the students going to develop good habits,” I offered, “if they don’t practise things like the walk-around? I thought you said students learned better by doing?”
“I did, but that’s in the air, not on the ground. Just show them how to do the walk-around a couple of times, and that’s enough. If you let them do it every flight, they’ll leave the gas caps off or something like that. Besides, they’ll wear out things like the oil access door, and we’ll be replacing them all the time. Students learn best by example.”
I could think of several arguments against what the man was saying, but I decided they wouldn’t be worth it. “Whatever you say, Hector.”
“Just to show you,” he added, “I’ll fly with your first student this morning. But first, I’ll do a weather check.”
The clouds were low. There was no weather office or flight service station (FSS) at the airport. When the conditions looked marginal, we flew a circuit to see if it was good enough to fly.
Hector’s comments irked me. I suppose it was his sudden managerial spirit that got under my skin. He appeared to do no work and was rarely around. It was also significant that my first student was Gloria Simcoe, a 19-year-old university student.
Hector climbed into the first Cessna 152. I went back into the office. Gloria was waiting inside.
“Hi Gloria. Hector will fly with you this morning. He’s doing a weather check first. He shouldn’t be long.”
“OK.”
We both watched the airplane. Hector skipped the warm-up and pre-takeoff check, and he didn’t use the runway. He started the engine and took off on the ramp straight from the fuel pumps. The airplane roared past the office window and into the air.
I was as surprised as Gloria, but she spoke first. “Is he supposed to do that?”
“Ah, oh, sure,” I said. The incident had spiked the evil side of my brain. “We depart from the ramp all the time. We just make sure it’s into the wind and there’s no traffic. Have you never done it?”
“No, Hector never mentioned it.”
“Well, today is a good time to try it. Hector will have run the airplane, so it will be warm and you’ll know everything is working fine. If the weather is a go, skip your checks and blast off from the ramp.”
“OK, sounds like fun,” she said.
As if to stamp his approval on the idea, Hector landed on the ramp and parked the little Cessna near the office.
He strutted through the door like a peacock. “Good morning, Gloria,” he crooned in a musical voice. “The ceiling is high enough for circuits. We can practise those landings of yours. Ready to go?”
“Yes.”
“Good. No sense wasting time on the ground,” he added, looking my way. “The airplane awaits.”
I followed them out the door to help Roger fuel the rest of the fleet.
“Watch this,” I said to Roger, motioning toward Hector and Gloria. They were already climbing into the Cessna.
“Watch what?”
“You’ll see.”
“All I see is Hector helping Gloria with her seat belt,” he said.
“Watch them after she gets the airplane started.”
“OK.”
It was perfect. Hector relaxed and nodded toward us once the seat belts were on. Gloria started the Cessna, looked both ways and moved it forward a little to line up into the wind. Then she shoved the throttle to the firewall.
It took Hector about three seconds to realize what was happening. Another three seconds went by while he uncrossed his legs and got them on the rudder/brake pedals. By then, the aircraft was accelerating through 50 mph and Gloria was pulling back on the elevator control.
The airplane pitched forward as Hector slammed on the brakes. The main wheels locked, and the Cessna’s tires painted two black lines down the ramp with the engine still at full power. Eventually, he got her hand off the throttle and the airplane wiggled to a stop.
There was a long period while they sat there. The airplane was rocking a little from Hector’s gestures. He looked back at me. Even from that distance, I could tell he wasn’t smiling.
“Did you set her up?” Roger asked.
“Yup,” I replied.
I didn’t know Roger or Hector very well. I wasn’t sure how they would react to my little stunt, but it was too late now.
“I gave her a ‘monkey see, monkey do’ pep talk in the office while Hector was flying his weather check.”
“You’re a bugger,” he said with a laugh.
“Thank you,” I replied.
“Just be careful with Hector. He has a sense of humour, but occasionally he remembers to be the manager. You can push him too far.”
“Okay, thanks for the advice.”
Hector and Gloria turned the airplane around and taxied slowly to the runway for another takeoff.
I didn’t have a student, so I was in the office when they returned from the lesson.
Hector tried to sound authoritative. “We’ll book your next lesson,” he said to Gloria. “We’ll do more circuits, taking off from the runway.”

Plane taking off on the ramp straight from the fuel pumps
Hector started the engine and took off on the ramp
straight from the fuel pumps.

“OK, Hector,” Gloria replied. I think she was fighting back a smirk.
He motioned for me to join him in the back office. He closed the door.
“Gloria said you told her to take off from the ramp. What do you think you were doing?”
“She saw you do it, so I told her it was OK,” I replied.
“Well, you know it’s not!” he fumed. “I’m a professional pilot with lots of experience. She’s not. She might try that solo, and people could get killed.”
He might have been right about Gloria trying it on her own, but he was exaggerating the kill rate. The ramp was plenty long enough, and the airport was never busy.
“I put her up to it to illustrate that students might try anything they see us do. If you hot-dog around a flying school, it’s going to happen.” My argument didn’t come out as strong as it was in my mind.
“If we tell them not to, they won’t,” Hector said. His reply also sounded a little weak.
“Did you tell Gloria not to do touch-and-goes on the highway?” I asked.
“No, she knows better than to do that.”
“Did you tell her not to chase boats on the lake?”
“No, she wouldn’t do that, either.”
“How about aerobatics?”
“No, of course not.”
These were all things that Hector had bragged to Roger and me about doing.
“Gloria has no reason to think those are good ideas unless you tell her, like with taking off from the taxiway.”
“I disagree. I think students are influenced by what they see. If they see you flying upside down in the school airplanes, I bet they can hardly wait to try it.”
The exchange wasn’t going very well. We were both getting frustrated.
“Look,” Hector said with a sigh, “maybe we do things a little differently than where you’re from, but we haven’t had any problems. It’s my job to make sure the school is running well. This morning, I made a couple of small suggestions. If you don’t like what we do, you should be talking to me, not the customers.”
He was right about using the customers to make a point. I had gone too far. It was time to salvage my job.
“Hector, you’re right. I shouldn’t have told Gloria to depart from the ramp. I’m sorry. But I think we should set a good example in front of the students.”
“Fine,” he said, “we’ll do that. But you’re going to find that lots of pilots land and take off from the ramp here. This is not a big city airport.”
“OK, thanks for the warning. I’ll look both ways before crossing the ramp.”
“Good idea,” he said. The suggestion made him smile a little. “And don’t forget to check the sky before venturing onto the highway,” he added.
“OK,” I said, smiling back. “What about boating?”
That made him grin more. “Yeah, and don’t forget boating. If I ever catch you on the lake, I’ll buzz you for sure.”

Garth Wallace is a former flying instructor who lives near Ottawa, Ont. He has written 11 aviation books published by Happy Landings (www.happylandings.com). The latest is The Smile High Club. He can be contacted via e-mail at: garth@happylandings.com.

Canada Labour Code, Part II, Section 127.1: The Internal Complaint Resolution Process

by Martin Gravel, Aviation Occupational Health and Safety Officer, Aviation Occupational Health and Safety Program, Standards, Civil Aviation, Transport Canada

Introduction
The purpose of Part II of the Canada Labour Code (CCL)1 is “to prevent accidents and injury to health arising out of, linked with or occurring in the course of employment” at any workplace under federal jurisdiction. Employers and employees under federal jurisdiction2 must comply with it. Part II of the CLC describes rights and obligations related to occupational health and safety. Among the many rights, obligations, procedures, definitions, and processes set out in this Part of the CLC is the internal complaint resolution process (ICRP), which is used to resolve complaints related to occupational health and safety.

The purpose of this article is to inform the Canadian aviation community about the ICRP and encourage employers and employees to use it to resolve workplace-related complaints themselves without involving an occupational health and safety officer. The process applies when an employee thinks the employer may be violating provisions of CLC, Part II, or its related Regulations, or both, and makes a complaint. The ICRP thus pertains to both air operators and their employees.

The process may seem complex at first, but in fact it is not. The following summary of section 127.1 of the CLC explains how it works.

ICRP Steps
First and foremost, it is important to understand the ICRP steps to avoid unnecessarily involving an aviation occupational health and safety officer. If an employee and employer affected by a complaint request the involvement of such an officer too soon, the officer may require that the parties first follow the ICRP before he or she conducts an investigation. In other words, the parties must show that they have tried to resolve the matter internally before they refer it to an aviation occupational health and safety officer. The process calls for cooperation between employer and employee (or the latter’s representative). There are eight steps in the ICRP:

Step 1:
The employee makes a complaint to his/her supervisor, orally or in writing.


Step 2:
The employee and the supervisor attempt to resolve the complaint between them as soon as possible.


Step 3:
The employee or the supervisor may refer an unresolved complaint to a chairperson of the local workplace health and safety committee. The complaint is then investigated by two members of the committee, one representing employees and the other the employer.


Step 4:
The persons who investigate the complaint inform the employee and the employer in writing of the results of the investigation. They may recommend that the employer take corrective action relating to the situation that led to the complaint. If the persons who investigate the complaint conclude that the complaint is justified, the employer must inform them in writing and without delay of how and when the employer will resolve the matter.


Step 5:
If the persons who investigate the complaint conclude that a danger exists, the employer must immediately ensure that no employees use or operate the machine or thing in question, work in the place or perform the activity in question until the situation is rectified.


Step 6:
The employer or employee may refer a complaint to a health and safety officer in the following circumstances:

(a) where the employer does not agree with the results of the investigation;

(b) where the employer has failed to take action to resolve the matter or to inform the persons who investigated the complaint;

(c) where the persons who investigated the complaint cannot agree between themselves as to whether the complaint is justified.


Step 7:
The health and safety officer investigates the complaint.


Step 8:
On completion of the investigation, the health and safety officer:


(a) may issue directions to an employer or employee under subsection 145(1);


(b) may recommend that the employee and employer resolve the matter between themselves; or

(c) will issue directions if the officer concludes that a danger exists. If there is danger, the officer has the authority to direct that the necessary steps be taken or that something stop being done immediately, in accordance with subsection 145(2) of the CLC.

Conclusion
Parliament takes the view that the parties (the employer and the employees) are the ones who know the workplace best and are in a position to resolve any problems that may arise. In the field of aviation, it is the flight attendants, the pilots and the employers who know the most about occupational health and safety on board aircraft. The purpose of the CLC, and more particularly the ICRP, is to encourage employers and employees to work together to resolve problem situations that may arise from time to time. There is no doubt that complaint resolution will be much simplified if the ICRP steps outlined above are followed.

“The legislative framework establishes a process that allows for a graduated series of investigations to resolve workplace issues while maintaining employment safety. The process allows for the resolution of workplace health and safety issues in a more timely and efficient manner and reinforces the concept of the internal responsibility system.”3 It also reinforces the spirit of cooperation that needs to exist between employers and their employees, this being one of the main purposes of Part II of the CLC. As a matter of fact, when the CLC was last amended in 2000, Parliament sought to bring about a greater spirit of cooperation between employers and employees, and the ICRP is a perfect example of Parliament’s intention.

“The process provides the employer/supervisor with the opportunity to address and correct employee concerns without the need to involve the workplace health and safety committee, the health and safety representative or a health and safety officer.”4

Occupational health and safety is first and foremost a workplace issue. When it comes to a specific workplace, the experts are the people who work there.

For further information on occupational health and safety, visit Transport Canada’s Aviation Occupational Health and Safety Web site at www.tc.gc.ca/eng/civilaviation/standards/commerce-ohs-menu-2059.htm, and Human Resources and Skills Development Canada’s Labour Program Web site at www.hrsdc.gc.ca/eng/labour/health_safety/index.shtml.  

Decorative line

Canada Labour Code, R.S., 1985, ch. L-2, sections 127.1, 128, 129, 132, 145.
Internet: http://www.laws.justice.gc.ca/eng/acts/L-2/page-2.html.

The following definition appears in the CLC: “federal work, undertaking or business” means any work, undertaking or business that is within the legislative authority of Parliament, including: … (e) aerodromes, aircraft or a line of air transportation; Ibid, section 2.
Internet: http://www.laws.justice.gc.ca/eng/acts/L-2/page-1.html.

Human Resources and Skills Development Canada, Labour Program, Pamphlet 3—Internal Complaint Resolution Process, p.1. Internet: www.hrsdc.gc.ca/eng/labour/publications/health_safety/resolution.shtml.

Ibid.

Worth Watching—Again! The 26 Weather To Fly Video Vignettes

The 26 Weather To Fly vignettes, exploring the effects that weather (seasonal and otherwise) has on flying in Canada, have been available on the Transport Canada Web site in streaming video format
for many years now. These excellent vignettes are a must-watch
for any pilot.
View them today at http://www.tc.gc.ca/eng/civilaviation/publications/tp13876-5805.htm.
It's time well spent!

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