EASA Aviation SMS Reporting Mechanisms

Comments by Steve Bentley MD Sofema Aviation Services www.sassofia.com

Introduction

As a precursor to the introduction of Regulation 376/2014 EASA identified shortcomings related to Aviation Occurrence Reporting and proposed in 2010 a new regulation which in compliance with ICAO objectives moved the focus from a ‘reactive’ system to a pro-active, risk and evidence based system.  It also acknowledges that safety occurrence data is vital to allow for the timely identification and management of potential safety hazards and acts upon this before these hazards turn into an actual accident. 

EASA introduced EU Regulation 376/2014, (repealing EU directive 2003/42/EC), which came into force on 15th Nov 2015. The regulation provides additional safeguards to address the lack of protection of the reporters, the lack of harmonisation in the occurrence data collection and integration (leading to low quality reports and incomplete information), as well as insufficient requirements regarding safety analysis and the resulting recommendations.

Considering the No 1 Challenge

Under reporting could be considered one of the biggest challenges to an effective SMS reporting system. Whilst we all recognise that the sharing of safety information is more than essential to an effective aviation system we are also aware of the amount of under-reporting of safety incidents.

We may also be part of the problem! Consider when was your last safety report!

The Root of the Issue

The fear of prosecution or reprisals at the company level after reporting an event is still ever present and serves as a continuous discouragement for people to engage with a voluntary reporting regime. (The fix incidentally is very much “top down” means it should be led by senior management.)

The consequence of under reporting hampers the effectiveness of the SMS with a range of negative outcomes including insufficient occurrence reporting, as well as reduced ability to deliver safety improvements.

Next Steps

The new EU Occurrence Reporting Regulation 376/2014 sets a new framework to both encourage and protect safety reporting by all aviation professionals.

Effective from 15 Nov 2015, the legislation requires aviation organisations in the EU to develop adopt and maintain a proactive “Just Culture”

The objective is to facilitate the collection of key safety data and other relevant information and to ensure that all information is protected.

The best approach for proactive prevention is one that encourages the reporting of and learning from mistakes. To do this pilots, air traffic controllers and all other aviation safety-professionals must be able to share information about any errors or mishaps in an environment based on trust, one which neither entails blame nor leads to ungrounded prosecution.

Just Culture principles and behaviour should be evident within each company, including a ‘whistle-blowing’ (Confidential) mechanism on which individuals can rely on in case this Just Culture principle has been violated. 

EASA’s Role in Occurrence Reporting

a) Safety occurrences collected will be transmitted to Member States’ competent authorities and to EASA.

b) All occurrences collected by Member States (MS), organizations and EASA are aggregated into the European Central Repository (ECR), and EASA and MS have access to all data and information contained the ECR database.

c) EASA and MS analyse (and exchange) the information contained in the ECR, and they do so ‘collaboratively’ within the ‘Network of Aviation Safety Analysts’; the Network is chaired, prepared and organized by EASA (This analysis complements what is done at national level, e.g. by identifying possible safety problems and key risk areas at European level, and by informing the European Aviation Safety Program (prepared by the Commission) and the European Aviation Safety Plan (prepared by EASA).

d) EASA (as well as MS and Commission) are bound by strict confidentiality requirements related to the safety information and the reporters of such information.

e) EASA advises the Commission (and MS) in the so-called ‘EASA Committee’, which will cover matters related to occurrence reporting.

Sofema Aviation Services www.sassofia.com  and our sister company SofemaOnline www.sofemaonline.com provide classroom and online training for regulatory and vocational training fully compliant with EASA requirements. For more information please email office@sassofia.com or online@sassofia.com