Considering the EASA Part 145 SMS & QMS Internal Reporting System following the introduction of NPA 2019-05 (C)

SofemaOnline takes a look at what SMS Internal Reporting Elements should be addressed in the context of the Organisational 145 SMS 

Reporting Systems should include the possibility of Voluntary and Confidential Elements, however, please note that an essential feature of a successful system is the willingness of the Employees to engage with the system. In fact, this becomes a key measure of an effective system.

Introduction

The overall purpose of the internal safety reporting scheme is to use the reported information to improve the level of the safety performance of the organisation, and not to attribute blame.

The scheme is an essential part of the overall monitoring function and should be complementary to the normal day-to-day procedures and ‘control’ systems; it is not intended to duplicate or supersede any of them.

The scheme is a tool to identify those instances in which routine procedures have failed or may fail.

The objectives of the EASA Part 145 Internal Reporting scheme are to: 

▪ Enable an assessment to be made of the safety implications of each relevant incident (errors, near-miss), safety issue and hazard reported, including previous similar issues, so that any necessary action can be initiated; and 

▪ Ensure that knowledge of relevant incidents, safety issues, and hazards is shared so that other persons and organisations may learn from them. 

Now Consider what EASA expects regarding Internal safety reporting scheme (AMC1 145.A.202)

a) Each internal safety reporting scheme should be confidential and enable and encourage free and frank reporting of any potentially safety-related occurrence, including incidents such as errors or near misses, safety issues and identified hazards. This will be facilitated by the establishment of a just culture.
b) The internal safety reporting scheme should contain the following elements:

1. Clearly identified aims and objectives with a demonstrable corporate commitment
2. A just culture policy as part of the safety policy, and related just culture implementation procedures
3. A process to:

i. Identify those reports which require investigation
ii. When so identified, investigate all the causal and contributing factors, including any technical, organisational, managerial, or human factors issues, and any other contributing factors related to the occurrence, incident, error or near-miss that was identified
iii. If adapted to the size and complexity of the organisation, analyse the collective data showing the trends and frequencies of the contributing factors

4. Appropriate corrective actions based on the findings of investigations
5. Initial and recurrent training for staff involved in internal investigations
6. Where relevant, the organisation should cooperate with the owner, operator or CAMO on occurrence investigations by exchanging relevant information to improve aviation safety

Functioning Elements of the internal safety reporting scheme should include:

▪ To ensure the confidentiality of the reporter
▪ Be closed-loop, to ensure that actions are taken internally to address any safety issues and hazards
▪ Feed into the recurrent training as defined in AMC5 145.A.30(e) whilst maintaining appropriate confidentiality

Enable feedback to be given to staff both on an individual and a more general basis to ensure their continued support of the safety reporting scheme.

Retention of Relevant Reports & Information

All safety reports that are judged to be reportable by the person submitting the report should be retained, as the significance of such reports may only become obvious at a later date.

Typical occurrences to be reported are those in which aviation safety was, or could have been endangered, or which could have led to an unsafe condition.

Note - If in the view of the reporter, an occurrence did not endanger aviation safety but, if it was repeated in different but likely circumstances, would create an unsafe situation that could lead to an accident or serious incident, then a report should be made.

What is judged to be reportable on one class of product, part, or appliance may not be the same for another, and the absence or presence of a single factor, organisational, human, or technical, can transform an occurrence into an accident or serious incident?

The collection and analysis of timely, appropriate and accurate data will allow the organisation to react to the information that it receives, and to take the necessary action. 

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