Air Safety Round Table: Haiyan Zhang
Haiyan Zhang is a member of Canadians for Accountability, whose mission is to advance integrity and accountability and to help and advocate for whistleblowers in all parts of our society.
I would like to thank Kirsten Stevens and the Honourable Dennis Bevington for inviting Canadians for Accountability to this round table.
Canadians for Accountability is a new organization created by a group of grassroots whistleblowers and accountability activists. Our mission is to advance integrity and accountability and to help and advocate for whistleblowers in all parts of our society.
Safety Management Systems is an issue which has had our attention for some time. Two years ago, Allan Cutler, our President, went on record with his concerns about SMS. He did so not only because of his own reservations, but also because he was asked to do so – by unions representing workers in the aviation industry.
What is it that concerns us about SMS? As a concept, we are not opposed to it. Rather, we feel that SMS in its current form fails the accountability test. We also believe that neither the industry nor Transport Canada is ready for it, and that if it moves forward, more lives will be lost to preventable accidents.
In practical terms, SMS relies on airline operators to set up systems of internal monitoring, reporting and correction for safety issues, rather than relying on Transport Canada inspections. It assumes that a safety culture will become part of an airline’s everyday practices.
This is a nice idea in theory, but order for performance-based regulatory frameworks like SMS to be effective several conditions must be met:
- The airline must already have a mature safety culture and a high degree of regulatory compliance
- The initial safety assessment for the operator must be conducted at arm's length as managers are unlikely to admit fault in their own operations
- There must be a safe environment for people to bring problems forward and have them dealt with in a transparent manner
- There must be no conflict of interest between oversight and the business end of operations
- Performance standards must be developed and measured by the regulator
- The regulator should have sufficient resources and expertise to properly inspect all aspects of operations
In addition, we feel that transparency is essential to such a system. The travelling public has the right to know whether an airline with which they want to fly has a history of safety problems.
We do not believe that SMS meets these conditions. In particular, it has no protection for employees who choose to report problems. While this might not be a problem in well-managed, responsible airlines where workplace intimidation does not exist, it is not the case everywhere.
We know this because we have been approached by two whistleblowers reporting dangerous practices in airlines. To our knowledge neither issue has been effectively addressed. Both employees were punished for speaking out, though.
Furthermore, there is ample evidence that poor safety cultures have led to other crashes in the past few years – notably in B.C. There is also evidence of Transport Canada’s unwillingness to act even when there are clear signs of problems.
Part of the problem is that SMS ignores human nature. A common thread through past crashes seems to be a conflict between business pressures and safety requirements – a conflict which was often decided in favour of business interests. Line managers faced with a delay sometimes succumb to temptation and cut corners. When nothing happens, they are inclined to try again.
Furthermore, we are sceptical of Transport Canada’s ability to ensure compliance with SMS. It admits that the success of SMS depends on a corporate culture wherein each individual contributes to and is responsible for safety, and where the reporting of safety concerns is actively encouraged. But how are these things measured? How does one measure culture?
Rather, it seems that Transport Canada is prepared to make a leap of faith. They appear to expect airline operators to become compliant, and that their inspectors will be able to detect a safety culture from a few interviews, an examination of documents and a periodic inspection. There has been no risk assessment of SMS – the idea is dismissed on their website as “superfluous”. There appears to no way to test the system used by any individual airline – to see if their system is catching everything.
Considering all these issues, and remembering that food safety was managed in a similar manner prior to the 2008 listeriosis outbreak, we do not think it an exaggeration to call SMS a disaster in the making.
Accordingly, Canadians for Accountability calls for SMS to be sent back to the drawing board, for a risk assessment to be conducted and for amendments to be made in consultation with accountability activists and the families of crash victims. This should be done in as transparent a manner as possible, including explanations on how the department will ensure that it has enough inspectors to do the job and that they have the required training. Only then, when the process has run its full course and all issues fully and adequately addressed, should he consider re-launching SMS for responsible and safe airline operators.