The Objective of Safety Reporting
The objective of safety reporting is to contribute to the improvement of air safety by ensuring that all information on safety related events are identified, collected, collated and analyzed, allowing the proactive identification of safety risks and the subsequent targeting of these risks to mitigate any possible undesired outcome.
Occurrence Reporting Regulations
Occurrence reporting in Europe is now subject to EU Regulation (namely Regulation (EU) 376/2014) and this regulation includes provisions for reporting to the competent authority in each EU member State using two separate types of reports, Mandatory Occurrence Reports (MOR) and Voluntary Occurrence Reports (VOR). This regulation supersedes the previous EC Directive 2003/42/EC and as such is applicable in each EU member State without the need for transposition in national legislation. Detailed guidance material issued by the European Commission on the implementation of this regulation may be found here.
Note that existing EU implementing regulations issued pursuant to the EASA Basic Regulation (Regulation (EC) 216/2008) also impose obligations on certain organisations to establish occurrence reporting systems. Even though both sets of regulations must be complied with, this should not give rise to two parallel reporting systems, and Regulation (EC) No 216/2008 and its implementing regulations, should be seen as complementary to Regulation (EC) 376/2014.
The European Commission has also established the list of occurrences that must be mandatorily reported to the competent authority of each EU member State. This list is found in Commission Implementing Regulation (EU) 2015/1018.
Mandatory Occurrence Reports
The new regulation imposes additional reporting requirements above the previous EC Directive and thus the existing IAA MOR reporting templates have been amended accordingly. Approved organisations who currently use the templates provided by the IAA (eg as part of the Safety Management System (SMS) processes) should contact their assigned IAA inspector to obtain the revised version of this template (if not already done) or they may download the SOTS FORM 1. Guidance instructions on completing this form for compatibility with ADREP/ECCAIRS format is also provided.
To ensure a common EU approach the European Commission has also developed an on-line occurrence reporting portal and associated reporting forms on http://www.aviationreporting.eu. This on-line option may be used as an alternative to the IAA SOTS Form 1, however it is particularly recommended for use by smaller organisations or persons (eg GA pilots) that may have only occasional need to submit occurrence reports under this regulation. Occurrence reports filed on this site will not be reviewed by the EC but will be forwarded directly to the IAA.
Voluntary Occurrence Reports
The new regulation provides also for the establishment of a Voluntary Occurrence Reporting (VOR) system. This system accommodates reports from organisations or individuals for occurrences that are not included in the mandatory occurrence list (ie per Regulation (EU) 2015/2018) but which the organisation or individual feels should be reported nonetheless. It may also be used by individuals within organisations who feel that their safety concerns are not being dealt with sufficiently within their own organisation’s SMS. The template for the VOR is exactly the same as for the MOR however as it is voluntary the information requested in many of the specified technical fields may be considered non-mandatory for completion. As above voluntary reports may be submitted using the IAA SOTS FORM 1 or on http://www.aviationreporting.eu
Confidential Reporting System
Notwithstanding the EU regulatory framework discussed above the IAA has established an independent confidential reporting system. This system is designed for use by organisations and individuals not subject to the EU regulations referenced above, such as pilots of uncertified light sports aircraft, RPAS/drone operators, airline passengers and the general public. Aviation professionals are not excluded from using the confidential reporting system however they must also ensure that they comply with the regulations discussed above. The confidential reporting form may be found here
Other Reporting Forms
Other Specific Reporting forms used by the IAA include
IAA action on occurrence reports
The IAA, as competent authority, is also subject to certain obligations in respect of mandatory and voluntary occurrence reports submitted on foot of Regulation (EU) 376/2014, including the classification and analysis of reports, and sharing of safety information with EC/EASA, other EU member States, regulated entities and the public, with due consideration of the strict data protection provisions contained in the regulations. Notwithstanding the regulatory framework the IAA applies the following principles in respect of all occurrence reports:
- The IAA values all occurrence reports equally, whether they are reported under the regulatory framework as mandatory or voluntary occurrence reports, or whether they are reported outside the regulatory framework as confidential reports.
- All occurrence reports are subject to initial risk assessment and the level of investigation the IAA performs on individual occurrence reports is based on that assessment (the higher the risk the greater the concern).
- The IAA is fully supportive of and will abide by the principles of just culture and data protection enshrined in the regulatory framework.
- The IAA will take a balanced view in its investigation of reports received from individuals, where such reports concern perceived actions, or inaction, by the organisation within which the individual works.