Industry Self-management

Phil Croucher · March 23, 2007

I should add that my comments above do not necessarily apply to Canada - it's a worldwide industry problem. I've known examiners in Europe who have not even been in the aircraft when they've signed somebody off. I must say that whenever I've had a checkride from TC it's always been dead straight down the line and to a good standard. The same is not true of other countries.

Phil

Helilog56 · March 23, 2007

After readiing the HAC "proposal", the chances of "that" (those) concept(s) ever becoming reality.......slim to none.

I could come up with 26 pages of replies to as many point's made.....but everyone would fall asleep..... :rolleyes:

John Moore · March 23, 2007

Here are some thoughts on the conclusions of the Helicopter AOC Industry Self-Management Feasibility Study.

1. Statistically the Canadian safety oversight system has been cruising steadily for the last 20 years.

The argument can be advanced that the accident rate, rather than being stagnant should be improving.

2. H-AOC Industry Self-management could be like installing a hydrid engine that would increase the cruise speed of the system and considerably improve its efficiency.

What does this mean? It is a senseless analogy.

3. The helicopter industry is a homogeneous and highly competitive sub-sector of commercial aviation.

Homogeneity can be detrimental. If there is too much conformity, diverstiy suffers. Perhaps “cut throat” should be substituted for “highy competitive”.

4. The Helicopter Association of Canada has unparalleled operator membership and consonant respect, which makes it extraordinarily well placed to assume responsibility and accountability for industry self-management.

I am sure parallels can be found here. Considering the intimate relationship between HAC and Canadian helicopter operators, HAC is poorly placed to assume both responsibility and accountability.

5. The Canadian helicopter industry caters to very sophisticated, exclusive-use, industrial customers who demand a high degree of safety and service reliability.

Some may be sophisticated but they are in the minority. Consider tree planters and drillers. I have never once encountered a user who questioned a pilot’s decision for instance those regarding weather or aircraft loading. They assume that if the pilot says it is OK or attempts to do it, it must be safe.

6. Competitive dynamics can be used to promote safety without the level of direct government oversight that would be required by conventional wisdom.

If competitive dynamics works so well, why is HAC needed to promote it?

7. The Canadian helicopter industry, in general, has a positive safety culture.

Is forty-two consecutive fourteen hour days safe? Is trying to get a job done in half-mile visibility safe? Is guessing at the gross take-off weight of a helicopter safe?

8. The needs, issues and concerns inherent to the concept of industry self-management can be resolved.

If so, list and address them now.

9. CBAA experience demonstrates that HAC, under the supervision of its Board of

Directors/membership, can replace TCCA as the organization responsible for establishing

commercial helicopter service standards and for the issuance/cancellation of AOCs, amendments, operations specifications, approval of manuals, and the management of audits and SMS.

As has been ponted out, the members of CBAA are not in competition with each other whereas members of HAC most certainly are.

10. If HAC becomes a Designated Organization it would be: accountable to the Minister for H-AOC management in compliance with the Aeronautics Act; subject to administrative monetary penalties; and in extreme circumstances the Association’s certification could be suspended/cancelled.

If a large part of the compliance with CARS is invested in HAC and they prove incapable of managing the task, what sort of mayhem will ensue between the time HAC is fired and another organization appointed?

11. Under industry self-management operator issues relative to H-AOCs would be resolved entirely within the Association while TCCA issues relative to any operator’s AOC would be resolved between the TCCA Headquarters and the Association.

This just seems like another layer of bureaucracy which will complicate matters.

12. Under Industry Self-management TCCA should continue to develop and enforce regulations while the Association must continue to represent members who have a legitimate defence.

This is the definition of conflict of interest.

13. Taking on AOC Management will not change the mission, goals and other roles of the Association.

Again, almost by definition it will change all three.

14. If the Association manages H-AOC it must continue to advocate for the helicopter industry and represent operators in all matters of concern to them.

It sounds like HAC must be the prosecution, the defence and the judge.

15. The Association will in no way be subject to TCCA tutelage in the management of the H-AOC Program.

This is unfortunate as TCCA must be experts at this after all these years.

16. Sharing of responsibility for safety management could promote greater dialogue and mutual respect between HAC and TCCA, thus enhancing the HAC’s ability to advocate in favour of the industry.

Why is this not happening now?

17. Focused data analysis could allow powerful market forces to be directed toward more stringent oversight, making Industry Self-management equivalent to SMS.

If industry self-management is equivalent to SMS, why bother to complicate matters by having both?

18. A partnership between TCCA and industry could marry the strengths of government and industry to serve:

public expectations in regard to safe, effective and affordable services;

taxpayer demands for cost effective safety oversight;

operators’ desire to have a regulatory system more in tune with the realities of the helicopter industry; and

a safety management model based “partnership and pride” in safety management rather than “blame and shame”.

For one thing “blame and shame” works quite well. There must be consequences for error. Blame and shame is preferable to fines or jail sentences.

19. The cost of helicopter safety management under a TCCA/HAC partnership would be

counterbalanced by direct savings not to mention efficiencies and other ensuing benefits.

What efficiencies? What ensuing benefits?

20. Although transfer to an Industry Self-management model would require transitional government funding, and perhaps continued financial support by TCCA for independent auditing, taxpayers would rapidly recoup the investment and then reap sustained dividends.

Some hard numbers have to be put on things like this. One can not just wave one’s arm and say everything will be all right.

21. Should Industry Self-management not live up to industry expectations the Association could always forfeit its designation.

If this happens, chaos will result.

22. Given the Treasury Board objective for modernizing safety management, if HAC does not embrace Industry Self-management some other, less representative organization, may be called upon to do so.

The largest constituency of the helicopter industry, namely pilots and engineers, are not represented in any way. This is one of my biggest objections to this whole potential fiasco .

John Moore · March 23, 2007