Introduction:
The International Association Machinists and Aerospace Workers, represents about 50,000 members across the country of which about 16,000 come from the aviation sector, and about 7,000 are technicians working in the aircraft maintenance industry in Canada.
The IAM is the largest union in the air transport sector in Canada, and in North America, and we have represented Canadian air transport workers for almost 70 years.
We represent technicians at Air Canada, Air Transat, MTU Maintenance Canada, Bombardier, Land Mark Aviation, Bearskin Lake Air Services, Innotech Aviation Inc, and Piedmont Hawthorne Aviation. We also represent workers who perform aviation support functions at companies such as Skycharter, Air Consol Aviation Services Ltd, Air Labrador, Allied Aviation Inc, Irving Aviation, PLH Aviation Services, and Consolidated Aviation Fueling.
We welcome the opportunity to present the views of Canadian air transport workers to the Standing Committee.
We have a number of concerns with Bill C-6, amending the Aeronautics Act, including Safety Management Systems (SMS) (Clause 12), outsourcing of work to other countries, security clearances, fatigue (Clause 8), and privatization of Transport Canada functions.
Safety Management Systems
When the Canadian air transport sector was deregulated in the mid-1980s, we were assured that economic deregulation would never lead to the deregulation of safety. Since that time, however, there has been a steady move to weaken Transport Canada’s regulatory capacity. SMS is the newest step. Transport Canada will simply approve a company’s system, and leave the monitoring and control to internal corporate procedures.
We have seen, most clearly in the Air Ontario crash in Dryden, Ontario, that corporations facing economic pressures cannot be relied upon. Without constant and effective public regulation, corporations will constantly push the limits of safe operations, at growing risk to the traveling public.
While the government’s intention to download the regulation and monitoring of safety to the private sector is dangerous, we are particularly concerned about the use of SMS in foreign repair stations. If the effective monitoring by Transport Canada of SMS in Canada is problematic, it is even more unlikely at foreign worksites.
The introduction of SMS will also undermine the current whistleblower process, which affords some protection to employees reporting unsafe work practices. If a carrier or service company has no responsibility beyond meeting the terms of its own SMS, who can a concerned employee report to?
Outsourcing of Canadian Work:
Aircraft maintenance is a highly-skilled occupation and a growing industry. It provides excellent job opportunities today and for future generations. Unfortunately, it is an industry which is being threatened by short sighted actions of some Canadian companies and Government inaction.
As an example, Air Canada is breaking up its airline and increasing its foreign outsourcing. The flagship Canadian carrier recently purchased 80% of Aeroman TACAS, an aircraft maintenance facility in El Salvador, and has announced major expansion plans. Air Canada is clearly planning to send a large part of Air Canada’s future heavy maintenance work to El Salvador, and to compete with Canadians for other maintenance work from Canada and elsewhere, from this low-wage site.
This is a major threat to the future of the aviation maintenance industry in Canada, with potentially dire consequences for Canadian employment and skills, education infrastructure. As we noted above, there will also be consequences for aviation safety. Will foreign workers be subject to the same security clearance requirements as Canadian workers?
Fatigue:
Clause 8 of Bill C-6 allows for the setting of clear standards on hours of work for workers in this sector, including those performing maintenance.
Fatigue is a real concern for Aircraft Technicians. Excessive hours can increase the likelihood of errors, and undermines safety.
While Transport Canada has for many years studied worker fatigue, and has reviewed processes and legislation developed in other countries, it does not seem to be committed to move forward in this area.
There are many ways to address issue of fatigue. Countries such as Australia have taken the lead on this issue and developed a framework to address it properly. We believe that Transport Canada should be moving ahead quickly to set firm industry standards to deal with the problem of fatigue and safety.
Privatization of Transport Canada Functions:
We are concerned that Bill C-6 will allow Transport Canada to privatize its key regulatory functions, with a serious impact on effectiveness and accountability.
Transport Canada is actively pursuing downloading the issuance of Aircraft Maintenance Engineer (AME) licenses to private sector bodies. AME license-holders are the individuals who are qualified to certify an aircraft’s airworthiness. We believe that the issuance, inspection and control of AME licenses must remain with Transport Canada.
The issuance of AME licenses to aircraft technicians, inspections and audits performed by Transport Canada Inspectors, and others should be left in the hands of the regulator, in order to ensure the highest safety standards, and to ensure it is done without the influence of corporate agendas. Safety should not be sacrificed regardless of budgets, and corporate and investors needs.
Conclusion:
We are concerned that Bill C-6 will facilitate Transport Canada’s relinquishing of a large part of its safety oversight role, further dismantling the checks and controls that have led to this country’s excellent aviation safety record.
We believe that air safety cannot be left to private companies, the marketplace, and the profit-making imperative.
We believe that it is imperative for safety, economic and social reasons, that the government act to keep maintenance work in Canada.
Respectfully Submitted,
Dave Ritchie
General Vice President
Cc: Carlos DaCosta, Airline Coordinator, IAMAW
Lou Erlichman, Research Director, IAMAW
Jim Coller, President DL 140, IAMAW
