Sofema Aviation Services (www.sassofia.com) Considers roles and responsibilities related to the obligation to report occurrences both externally and internally.
CAMO.A.160 Occurrence reporting
Introduction - Regulation (EU) 2019/1383 identifies the obligation to implement an occurrence reporting system that meets the requirements defined in Regulation (EU) No 376/2014 and Implementing Regulation (EU) 2015/1018.
Note concerning reporting within the CAMO Environment:
Authors Comment - Whilst 2015/1018 essentially re-iterates the reportable events which have been identified for many years and found in AMC 20-8 the obligation to comply with 376/2014 identifies a number of significant obligations concerning reporter confidence and protection of information as well as disidentification of reporters.
So let’s take a look at how we could perform an Audit of the Internal Reporting System within an Operators Management System.
Consider First the Background Regulatory Obligations and to note that we need in this case to comply with both 965/2012 and 376/2014 (Proposed Audit Items are identified as AI-N)
AMC1 ORO.GEN.200(a)(2) Management system COMPLEX OPERATORS - SAFETY POLICY
(a) The safety policy should:
(4) Include safety reporting principles. AI-1
(b) The safety policy should include a commitment:
(5) Not to blame someone for reporting something which would not have been otherwise detected. AI-2
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.
Effective safety reporting of hazards by operational personnel is an important cornerstone of the management of safety. Therefore, an operational environment in which operational personnel have been trained and are constantly encouraged to report hazards is the prerequisite for effective safety reporting.
The ICAO requirements require that aviation service providers develop and maintain, within the scope of their SMS, a formal process for collecting, recording, acting on and generating feedback about hazards in operations. The process shall be based on a combination of reactive, proactive and predictive methods of safety data collection.
Best Practice Considerations
Consider the following as best practice objectives regarding the delivery of an optimize and effective Safety Management System.
ICAO Annex 19 defines safety as ‘the state in which risks associated with aviation activities, related to, or in direct support of the operation of aircraft, are reduced and controlled to an acceptable level’ and safety performance as ‘a service provider’s safety achievement as defined by its safety performance targets and safety performance indicators’.
Challenges to Establish Confidence in Safety Performance?
Whilst it is usual for safety metrics to focus on serious incidents and accidents it is also possible to gain a false impression regarding the overall level of safety due in part to a system with a low number of high consequence negative outcomes, means the low frequency of such outcomes may give the wrong impression that your system is safe.
Sofema Aviation Service www.sassofia.com looks at SMS reporting from the EASA perspective
What do we mean by Safety Occurrence Reporting?
We use the term Safety Occurrence to identify as a collective term which is used to embrace all events which have, or could have significance in the context of aviation safety.
Events identified may in fact range from minor events which are deemed to have a potential for an impact on safety through to incidents or events that should be reported to more serious events including serious incidents and accidents.
Building a Reporting Culture
The willingness to report, safety related exposures is a significant measure when we are considering the effectiveness of Safety Management System.
One of the biggest barriers to an effective Safety Management System (SMS) depends on the willingness of the employees to engage with the organisational system and for the managers to support such a program in a positive and tolerant way.
Without the willingness to engage with the Safety Management System (SMS) the level of data capture will lead to the creation of barriers.
Full engagement by the Management Team is an essential first step on the journey and without doubt. If we are going to maintain a healthy safety management systems (SMS) we require an open process of hazard reporting which allows us to understand the exposure and to reduce the operational risk.
How we are impact the various organisational barriers is in turn impacted by cultural and other behaviours which are often routed in mistrust.
Well firstly to understand the difference between Reactive Driven reporting and Proactive Driven Reporting. With the former clearly something has happened and we need to communicate with the authorities to advise them regarding what has happened. With the latter we have a situation whereby we are trying to proactively identify hazards and exposures where the risk may be considered a salient feature.
By identifying and measuring the risk in a meaningful way we can proceed to develop a greater understanding and as a consequence create appropriate mitigations which can lessen the exposure to the underling risk.
Creating the process
Step 1 then is to have an internal reporting system which meets the company’s needs – the focus should ideally be on the gathering of information (our SMS is heavily reliant on Data) rather than the complexity of the submitted documentation – often simple is better. We are trying to provide a simple mechanism which we will then encourage people to use in a meaningful way. A simpler system removes one of the barriers to avoid reporting (complaints that it is too bureaucratic).
1. To reduce our accident and incident rate on a continuous basis so that we see an improvement year on year 2. To identify latent exposures which can adversely impact us, and to develop mitigations before they become a problem
To ensure the best possible oversight, we need to make sure that our reporting processes within both our QMS & SMS are effective, to do this we need to ensure we have good reporting systems and effective data capture.
The Data gathered through internal and external audits together with other information will provide a sound indication for the management as to whether we are achieving our objectives.
Surveys can also provide a significant insight into the actual perception felt by the staff, and measure the effectiveness of the communications processes.
