Significant Public Reports by QualaTech

"Broadly, the Safety Case is the documented assurance (i.e. argument and supporting evidence) of the achievement and maintenance of safety. It is primarily the means by which those who are accountable for service provision or projects assure that those services or projects are delivering [or will deliver] and will continue to deliver, an acceptable level of safety.

As The Honourable Lawrence Cannon (Minister of Transport, Infrastructure and communications) stated: “… an organisation’s culture is demonstrated by what people do; decisions, actions and behaviour tell us something about the values of the organisation”.
Since Transport Canada is also the owner and operator of YWH, their responsibility and accountability is arguably greater to the general public, than that of a non-government agency. ...."

Keith Green - President QualaTech Aero Consulting Ltd.

FORWARD

The Union of Canadian Transportation Employees (UCTE), the Public Service Alliance of Canada (PSAC), along with our members, are committed to ensuring Canada has one of the best and safest air transportation systems in the world. UCTE members help maintain and support Canada’s airport infrastructure as Transport Canada staff and as Airport and Aircraft Rescue and Fire Fighting (ARFF) crews. Our members are trained, engaged and constantly monitoring airport activity.

Over many years, our members have reported multiple aviation related concerns (many reoccurring) to UCTE. The frequency and magnitude of these reports can no longer be ignored given they are a strong indicator that the Transport Canada Civil Aviation (TCCA) Regulatory system – specific to Aircraft and Airport Rescue and Fire Fighting at Canadian airports - is in need of an immediate and independent review. Our members report substantial non-alignment of the Canadian Aviation Regulations (CARs) regarding ARFF services with respect to international standards promulgated by the ICAO and agreed to by Canada.

To validate the accuracy of reported concerns, UCTE commissioned an independent consultancy to undertake an objective analysis of the Canadian Regulations (applicable to ARFF) to ICAO Standards under Annex 14 – Aerodromes. UCTE is now able to confirm via substantiated evidence that Canada is remiss under Article 38 of the Convention, specific to the publication of Differences (Annex 15) relating to Annex 14 and the subsequent conformity and implementation of certain agreed Standards pursuant to the CARs, Part III, Subparts 2 and 3.

Transport Canada has failed to ensure the level of RFF services (pursuant to Annex 14 Standards) at a large number of Canadian airports has been met. Accordingly, the Canadian Government’s regulatory framework, which “imposes public duties on Transport Canada”, has been jeopardized in respect to safeguarding the Canadian general public and decreasing risk to the aviation industry alike; irrespective of how some airport owners and operators (TCCA also owns and operates Airports) are allegedly complacent with the status quo.

What does this mean for Canadians who live in a country where safe air travel is an accepted expectation – even a right? Quite simply, it means during an accident occurring at a non-designated airport, a person, passenger, crewmember or even an airport worker’s trust and faith in being rescued before being burned or asphyxiated (this is no place to soften the consequence) is gravelly misplaced. Evidence suggests many Canadian airports are “less protective” than other contracting state aerodromes, principally because the vast majority of other contracting states prescribe more rigorously to Annex 14 Standards: specifically those applicable to Chapter 9 of the Annex.

In a real life situation when an aircraft is involved in an accident or incident at a nondesignated Canadian airport, there is a very high probability RFF will take longer to reach, abate and rescue victims than most of the other 192 contracting states. When surrounded by flame, smoke and other life threatening perils, every second counts. Why is it then, not every Canadian can expect the same level of RFF Service, or ultimately, the same right to be rescued just because their local - often a Municipal Airport – is excluded under the CARs for dedicated ARFF and has subsequently to rely on local municipal and/or volunteer firefighting services, often located a long way from the airport in terms of distance, time and suffering? Are not all Canadians equally entitled to the same level of protection regardless of the departure or destination point? CUTE believes they are.

A primary concern of the UCTE is not to unduly alarm Canadians; however, everyone who travels by air should be aware of the inherent risks. It is UCTE’s intent to inform the Government of Canada and TCCA over the many concerns identified within the analysis (not just the above example) so that change can be effected at the highest level.

Only then will the Government of Canada be able to honestly assure Canadians, along with the other 192 States, that we do have one of the best aviation systems in the world.  However, to accomplish this, Canada must first uphold all obligations to the ICAO and Canadians alike; change and improvement cannot be enabled until this basic action occurs.

The Union of Canadian Transportation Employees collectively believes all Canadians have the right to expect and to receive the safest air travel possible. To this end, CUTE continues the work already commenced. Nevertheless, given the analysis results, UCTE strongly proposes that a formal review specific to ARFF at Canadian airports is undertaken by an autonomous Commission empowered with the authority to ensure recommendations as may be set out by the Commission are enabled and not evaded, as so often the outcome.

Teresa Eschuk

National President

Union of Canadian Transportation Employees

A UCTE and PSAC funded project to determine the ‘differences’ between Part III of the Canadian Aviation Regulations, specific to the International Civil Aviation Organisation Standards and Recommended Practices as promulgated under Annex 14 Volume 1 – Ninth Edition.