Addressing CAR 107 Requirements

Below is a detailed description of how SMS Pro (asms-pro.com), a web-based aviation Safety Management System (SMS) software, addresses the Canadian Aviation Regulations (CAR) 107 requirements for aviation service providers. Each CAR 107 requirement is mapped to SMS Pro’s capabilities, with specific modules identified where applicable, based on information from the SMS Pro website and related sources. The response also notes any potential limitations where SMS Pro may not fully address a requirement.

1. Safety Policy and Objectives (CAR 107.03)
   • Requirement: Establish a safety policy signed by the accountable executive, appoint an accountable executive, develop SMS documentation, set safety goals, and conduct periodic policy reviews.
   • SMS Pro Capability: SMS Pro provides tools to document and manage the safety policy, ensuring it is accessible to all stakeholders via a centralized online portal. It supports the accountable executive’s role by allowing policy updates and tracking responsibilities. The software includes templates for safety goals and objectives, aligned with Transport Canada’s requirements, and automates reminders for periodic reviews.
   • Modules Used:
     • Policies & Procedures: Stores and manages the safety policy, ensuring it is auditable and accessible.
     • Safety Goals & Objectives: Tracks safety goals and performance indicators, with reporting capabilities for reviews.
     • Document Management: Centralizes SMS documentation, including policies and procedures, with version control.
   • Source: SMS Pro’s policy and documentation tools align with Transport Canada’s Phase 2 gap analysis requirements (asms-pro.com).
2. Safety Risk Management (SRM) (CAR 107.03(1)(b))
   • Requirement: Implement processes for hazard identification, risk assessment, mitigation, and maintain a risk register with ongoing monitoring.
   • SMS Pro Capability: SMS Pro offers robust SRM tools, including web-based hazard reporting forms that ensure mandatory fields are completed, streamlining data collection. It includes a risk matrix and risk register compliant with Transport Canada standards, supporting both proactive (e.g., audits) and reactive (e.g., incident reports) risk management. The system tracks mitigation measures and monitors their effectiveness.
   • Modules Used:
     • Hazard Reporting: Enables employees to submit hazards via web or mobile app, with automated notifications.
     • Risk Management: Manages risk assessments, mitigation plans, and maintains a risk register.
     • Issue Manager: Tracks and resolves safety issues, ensuring mitigation actions are documented.
   • Source: SMS Pro’s risk management software is designed for ICAO and Transport Canada compliance (asms-pro.com).
3. Safety Assurance (CAR 107.03(1)(c))
   • Requirement: Monitor SMS performance with safety performance indicators (SPIs), conduct audits/inspections, perform management reviews, implement corrective actions, and maintain records.
   • SMS Pro Capability: SMS Pro includes auditing and inspection tools to monitor SMS performance, with customizable SPIs for tracking safety metrics. It generates reports and dashboards for management reviews and supports corrective action tracking with automated notifications. All activities are recorded in an auditable database.
   • Modules Used:
     • Auditing Suite: Facilitates internal audits and inspections, with checklists aligned with CAR 107.
     • Performance Monitoring: Tracks SPIs and generates safety performance reports.
     • Corrective Action Tracking: Manages non-conformities and corrective actions, ensuring timely resolution.
     • Reporting & Dashboards: Provides data visualization for management reviews.
   • Source: SMS Pro’s auditing and performance monitoring tools meet Transport Canada’s safety assurance requirements (asms-pro.com).
4. Safety Promotion (CAR 107.03(1)(d))
   • Requirement: Provide SMS training, promote safety communication, establish non-punitive reporting, and enhance safety awareness.
   • SMS Pro Capability: SMS Pro supports safety promotion through training management tools, safety communication portals, and non-punitive reporting systems. It enables organizations to distribute safety newsletters, briefings, and updates, fostering a positive safety culture. Employees can submit reports confidentially via web or mobile interfaces.
   • Modules Used:
     • Training Manager: Tracks employee SMS training completion and schedules recurrent training.
     • Safety Communications: Distributes safety newsletters, bulletins, and briefings.
     • Hazard Reporting: Supports confidential, non-punitive reporting to encourage safety feedback.
     • Safety Portal: Provides a centralized platform for safety awareness and communication.
   • Source: SMS Pro’s safety promotion tools enhance safety culture, aligning with ICAO’s four pillars (asms-pro.com).
5. SMS Documentation and Record-Keeping (CAR 107.03(1)(e))
   • Requirement: Maintain an SMS manual, ensure documentation accessibility, retain auditable records, and conduct gap analyses.
   • SMS Pro Capability: SMS Pro centralizes all SMS documentation in a cloud-based database, replacing inefficient spreadsheets with a robust system. It includes templates for gap analyses and implementation plans, ensuring compliance with Transport Canada’s requirements. Documentation is accessible to authorized personnel and auditable, with version control and automated review reminders.
   • Modules Used:
     • Document Management: Stores SMS manuals, policies, and procedures with version control.
     • Gap Analysis Tool: Provides checklists and templates for compliance with CAR 107.
     • Record-Keeping: Maintains auditable records of all SMS activities.
   • Source: SMS Pro’s documentation tools address Transport Canada’s gap analysis and record-keeping requirements (asms-pro.com).
6. Emergency Response Planning (CAR 107.03(1)(f))
   • Requirement: Develop and maintain an emergency response plan (ERP), conduct drills, and update the plan regularly.
   • SMS Pro Capability: The industry-specific templates provide pre-configured frameworks that guide operators in creating ERPs aligned with their operational scope (e.g., CAR 705 airlines, CAR 573 AMOs, or CAR 406 flight schools). These templates cover key elements such as emergency roles, communication protocols, incident response procedures, and coordination with external agencies (e.g., Transport Canada, local authorities).

     This module manages the creation, storage, and updating of ERPs, leveraging Gordon Dupont’s industry-specific templates to ensure compliance with Transport Canada’s requirements. It supports drill planning, documentation, and corrective action tracking.

   • Modules Used:
     • Emergency Response Planning: Manages ERP documentation, drills, and updates.
     • Document Management: Stores ERP documents for accessibility and audit readiness.
   • Source: SMS Pro supports ERP requirements, based on a templated approach created by Gordon Dupont, creator of the Dirty Dozen Human Factors (asms-pro.com).
7. Quality Assurance Integration (CAR 107.03(1)(g))
   • Requirement: Integrate quality assurance processes into the SMS to ensure compliance and continuous improvement.
   • SMS Pro Capability: SMS Pro integrates quality assurance through auditing and performance monitoring tools, ensuring SMS processes align with regulatory standards. It supports continuous improvement by tracking audit findings and corrective actions, linking quality assurance to safety outcomes.
   • Modules Used:
     • Auditing Suite: Conducts quality assurance audits integrated with SMS processes.
     • Corrective Action Tracking: Links quality assurance findings to corrective actions.
     • Performance Monitoring: Ensures quality assurance contributes to SMS effectiveness.
   • Source: SMS Pro’s auditing tools support quality assurance integration (asms-pro.com).
8. Specific Requirements for Small Operators (CAR 107.02, 107.04)
   • Requirement: Implement a scaled SMS proportionate to the organization’s size and complexity, addressing all components.
   • SMS Pro Capability: SMS Pro offers scalable solutions tailored for small operators, with simplified modules and cost-effective pricing. Its user-friendly interface and offline reporting capabilities support smaller organizations with limited resources, ensuring compliance with CAR 107’s scaled requirements.
   • Modules Used:
     • Hazard Reporting: Simplified reporting for small operators, with offline capabilities.
     • Document Management: Scaled documentation for smaller SMS manuals.
     • Training Manager: Manages training for small teams.
     • Gap Analysis Tool: Supports simplified gap analyses for small operators.
   • Source: SMS Pro addresses challenges for small providers, as noted in its support for budget-conscious implementations (asms-pro.com).
9. Implementation and Compliance (CAR 107.02, 107.04)
   • Requirement: Develop and implement the SMS within Transport Canada’s timeframe, ensure compliance during audits, and maintain accountability.
   • SMS Pro Capability: SMS Pro supports phased SMS implementation with gap analysis templates, checklists, and implementation plans aligned with Transport Canada’s four-phase approach (initiation, planning, implementation, maintenance). It ensures audit readiness with comprehensive documentation and reporting tools, supporting accountability through role-based access for the accountable executive and safety manager.
   • Modules Used:
     • Gap Analysis Tool: Facilitates compliance with Transport Canada’s implementation phases.
     • Document Management: Ensures auditable documentation for compliance.
     • Reporting & Dashboards: Provides audit-ready reports for Transport Canada inspections.
     • Role-Based Access: Supports accountability by assigning roles to the accountable executive and safety manager.
   • Source: SMS Pro’s compliance tools are designed for Transport Canada and ICAO standards (asms-pro.com).
10. Exemptions and Applicability (CAR 107.01, 107.02)
    • Requirement: Ensure SMS applies to certificate holders (e.g., AMOs, air operators, airports) with exemptions for specific small operations.
    • SMS Pro Capability: SMS Pro is designed to support all applicable certificate holders under CAR 107, including AMOs, air operators (CAR 705), airports, and ATS providers. Its flexible modules adapt to different operational scopes, and it provides guidance for exemptions (e.g., single-person operations under CAR 604).
    • Modules Used:
      • Document Management: Customizes SMS documentation for applicable certificate types.
      • Gap Analysis Tool: Identifies exemptions and tailors SMS to regulatory scope.
      • Role-Based Access: Configures access for different certificate holder roles.
    • Source: SMS Pro’s applicability to various certificate holders is noted on asms-pro.com.

Potential Limitations

While SMS Pro addresses most CAR 107 requirements comprehensively, the following areas may present challenges or require additional resources:

1. Offline Capabilities for Remote Operations:
   • Issue: CAR 107 requires SMS functionality in all operational environments, including remote areas with limited internet (e.g., northern Canada). SMS Pro’s offline reporting and auditing capabilities are limited to specific modules (e.g., hazard reporting, flight risk assessments, audit checklists), and real-time functions may require internet access.
   • Impact: Small operators in remote regions may need supplementary processes for full compliance.
   • Source: SMS Pro’s offline capabilities are noted but not universal (asms-pro.com).
2. Customization for Complex Operations:
   • Issue: Large operators (e.g., CAR 705 airlines) may require highly customized SMS processes. SMS Pro’s standardized modules may need additional configuration or third-party integration to meet bespoke needs. SMS Pro offers API integrations for ECCAIRS, NASA ASRS, ASIAS and CASS, but customized APIs require additional investments.
   • Impact: Complex organizations may require external support for full customization and incur additional software integration fees.
   • Source: SMS Pro’s focus on broad applicability may limit bespoke solutions (asms-pro.com).
3. Human Resource Dependency:
   • Issue: CAR 107 requires trained personnel, including a dedicated safety manager. SMS Pro automates many tasks but cannot replace human oversight for data interpretation, decision-making, or safety culture development.
   • Impact: Small operators with limited staff may struggle to meet human resource requirements.
   • Source: Small operator challenges with human resources are noted (asms-pro.com).
4. Cost for Small Operators:
   • Issue: While SMS Pro is cost-effective, subscription costs may still challenge very small operators, especially with training or support needs. CAR 107 requires SMS regardless of budget.
   • Impact: Small operators may need to prioritize modules, delaying full implementation. SMS Pro offers a free version for very small operators under ten employees with five user accounts.
   • Source: Budget challenges for small operators are noted (asms-pro.com).

Conclusion

SMS Pro effectively addresses CAR 107 requirements through its comprehensive suite of modules, including Policies & Procedures, Hazard Reporting, Risk Management, Auditing, Performance Monitoring, Corrective Action Tracking, Training Manager, Safety Communications, Document Management, Gap Analysis Tool, Emergency Response Planning, Reporting & Dashboards, and Role-Based Access. These tools support safety policy management, risk management, safety assurance, safety promotion, documentation, emergency planning, quality assurance, and compliance for both large and small operators. The software’s cloud-based platform, user-friendly interface, and scalability make it particularly suitable for meeting Transport Canada’s SMS requirements, with templates and automation streamlining compliance.

However, limitations such as partial offline capabilities, customization needs for complex operations, dependency on human resources, and cost considerations for small operators may require supplementary processes or resources to ensure full compliance. Operators should verify SMS Pro’s alignment with their specific operational needs and consult Transport Canada for audit readiness.

For pricing or subscription details, visit https://www.asms-pro.com/Pricing.aspx, as specific cost information is not provided here.

Note: This response was created for a Canadian SMS consultant and is based on publicly available information from asms-pro.com and critically evaluated sources, aligned with the current date of May 31, 2025. Operators should confirm with Northwest Data Solutions and Transport Canada for any feature updates or regulatory changes.