TCCA issues NPA for new SMS rules


Transport Canada Civil Aviation has published the notice of proposed amendment that lays out the proposal to change the safety management system requirements for the aviation industry. While Canadian aviation businesses have had SMS requirements in place for some time, they have not covered the complete industry. The current requirements are scattered throughout the CARs and only apply to a few specific certificate holders.

The main objectives of this regulatory change are to:

  1. Align the CARs with the ICAO requirements (Annex 19).
  2. Strengthen Canada’s position as a world leader in SMS.
  3. Improve the readability of the CARs and simplify requirements.
  4. Support Canadian organizations in their global competitiveness.

This last point is mostly related to the fact that many other countries are requiring Canadian manufacturers to have an approved SMS program in order to import their products. It has become a roadblock in some countries when obtaining type certificate validations. 

TCCA recognizes that a cornerstone of a good SMS program is the quality assurance program, which is currently required for most certificate holders. The QAP requirements vary in the different Parts of the CARs. TCCA intends to address this by providing more performance-based requirements for the QAP consistent across the CARs

Currently, the Canadian SMS requirements contain six components, which are published in various Parts of the CARs with inconsistent terminology. To better align the Canadian requirements to ICAO annex 19, the proposal is to reduce the six components of the current SMS program into four divisions in CAR Part 1. The basic elements will be the same, but the wording will be refined and clarified.

The NPA proposes three options, but TCCA is strongly recommending one of them. The preferred option is to rewrite the SMS requirements as noted above and add the requirement for SMS to manufacturers and design holders for the first part of implementation. Then a second part (with no timeline provided) would add SMS to all other certificate holders (all AMOs and all commercial operations). The second option would only be to introduce the first part as noted previously. The third option is essentially status quo and clean up a few items.

TCCA has conducted significant industry consultation, and it appears the majority of certificate holders agree with the preferred option. The objections mainly come to the timeline and when SMS would need to be in place. This is part of the reason for the two-part approach.

The proposal has four phases of SMS implementation and two classes of certificate holders, which are set up with specific timelines to ease in the SMS program. The first phase is the appointment of the accountable executive, gap analysis and the planning stage. The second phase is the development of the processes. The third is implementing the processes, and the fourth is the audit to show the organization is meeting the implemented SMS program.

Level A companies are small, less-than-20-people organizations, and the timeline to implement the four phases of the SMS program are: From the in-force date of the regulation, there are six-month, 12-month, 18-month and 24-month periods respectively for each phase. Level B companies are those larger than 20 people, and the timing is eight, 16, 24 and 36 months for each of the four phases. These two levels and different timing recognizes the differential effort to put a system in place and speaks to the “right-sizing” of the system. Smaller organizations will not need the same level of detail as larger ones.

This is a step in the right direction for TCCA and will allow the completion of the vision that was started in 2003. The wording in the proposal has some idiosyncrasies that deserve the industry's attention.

The due date for comments is rather short – March 4. Unfortunately, TCCA has chosen the short process for this NPA and has allowed only 60 days for comments with the NPA being issued in early January. The reasoning behind this short comment period is the level of consultations already conducted. To read the NPA, click here.



Contact Kevin Bruce, AEA director of engineering and certification, by email at

Contact Ric Peri, AEA vice president of government and industry affairs, by email at or by phone at 202-589-1144.