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 Slow progress on addressing TSB recommendations

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Actions taken to fix long-standing, high-risk safety deficiencies in the air, marine, and rail modes of transportation have been too few and too slow.


The situation

Since its creation in 1990, the Transportation Safety Board of Canada (TSB) has issued 598 recommendations aimed at fixing systemic safety deficiencies in the modes of transportation under federal jurisdiction. Some recommendations were made to industry or provincial authorities, but the vast majority were directed to Transport Canada as the regulator. In some cases, although the minister agreed with the recommendation, the department did not take sufficient or timely action.

Outstanding TSB recommendations

At October 2018, 62 recommendations (more than 10% of all TSB recommendations) that were issued more than 10 years ago still had not been fully addressed.Footnote 1 There are various reasons for the slow implementation of recommendations, including protracted studies; delays in publishing regulations; changes in course of action; lack of consensus among stakeholders; voluntary rather than mandatory measures, which also create uneven safety standards; jurisdictional issues; and the need to harmonize standards across jurisdictions.

As the table below shows, the lack of progress is more pronounced in the air and marine sectors. There are also old recommendations on most of the current Watchlist issues and for other important safety deficiencies. For example:

Table 1. Total outstanding TSB recommendations 10 years or older at October 2018
Mode Active Dormant Age Total
10 years old to
less than 15 years old
15 years old to
less than 20 years old
20 years old
or older
Aviation 19 26* 13 17 15 45*
Marine 12** 0 4 2 6 12**
Rail 3 2 1 3 1 5
Total 34 28  18 22 22 62


Delays compound issues and risks

When timely actions are not taken on TSB recommendations, safety deficiencies persist and continue to pose a risk for the safety of people, property, and the environment. For example:

In issuing a recommendation, the Board generally takes into account the relevant international standards. Long delays in taking action increase the likelihood of falling behind international standards and perpetuate any existing gaps. This has been the case, in particular, for cockpit voice recorders and runway end safety areas.

Finally, if the underlying regulatory process does not change, undue delays will likely persist and increase the backlog of old outstanding recommendations.

Actions taken

Raising the issue

The slow response to recommendations was first highlighted as part of Watchlist 2016. At that time, the Chair of the TSB reached out to the Minister of Transport, who welcomed the Watchlist in a statement indicating that the safety of the transportation system is a top priority.Footnote 12 Since then, TSB senior officials have continued to raise the issue at numerous outreach events and during several parliamentary appearances.

Slow and partial response

In 2017–18, Transport Canada agreed to collaborate with the TSB to review and update its responses to all old recommendations. Some encouraging progress was made, but the Department missed some key timelines and requirements for the submission of updates.  Based on this initial effort and the TSB's own research, the number of active recommendations outstanding for more than 10 years dropped from 52 in 2016 to 34 in October 2018. On the other hand, the number of old dormant recommendations increased slightly from 27 to 28.

Most of the progress achieved since 2016 is due to changes in the operating environment or voluntary actions taken by industry. Transport Canada has made limited progress on regulatory actions. Furthermore, Transport Canada and central agencies have not undertaken the necessary actions to improve and accelerate the regulatory process for implementing responses to safety recommendations.

Actions required

This issue will remain on the Watchlist until the following measures have been taken: