Regulation (EU) 376/2014 (sometimes known as Occurrence Reporting Regulation) (ORR) is about more than simply reporting occurrences. It also focuses on the essential need of analysis and the development of follow-up and mitigation’s.
The Concept of European Wide Mandatory Occurrence Reporting has been with us since 2003 (Ref Directive 2003/42/EC) This has now been updated and superseded by Regulation (EU) 376/2014.
Implementing Regulation (EU) 2015/1018 identifies the basic criteria by which reports should be based (of course this is not exclusive).
We know that often Incidents and events are precursors to accidents and should also understand the importance of gathering and managing Safety Information and other Data sources.
EASA in line with the “teaching” of ICAO understands the need for reactive reporting systems to be complemented by proactive systems which focus on accident prevention activities based on the analysis of all relevant safety information.
Most of us are able to explain the basic meaning of Just Culture – However it is very difficult in practice to embed Just Culture throughout the organisation and to move away from the bigger the damage the greater the punishment situation.
Whilst the focus is on Mandatory Report EASA also recognizes Voluntary and Confidential Reporting.
Organisations have an ongoing challenge to ensure that employees will never by punished for reporting a hazard and that any discipline will be in keeping with the actuality of the role of the person in connection with the event not the gravity of the event. (Remember that a hazard is simply something that has the potential to cause harm) The Risk is how likely it will and the mitigation is what we do to fix it !
An essential element of a successful system is to ensure the viability as well as availability of a feedback system to ensure all stakeholders are regularly informed regarding any actions which are taken under or as a result of the occurrence reporting systems.
What do organisation’s need to do now?
To ensure the development of an effective reporting process throughout the business and from any subcontractors who are also involved in service delivery.
To ensure adequate communication and training is available so that everyone involved is essentially “competent” to fulfill the required role of reporting. Never assume knowledge!
To break down barriers which inhibit the effective reporting driven by organisational cultural issues and barriers.
To have the competence (within the organisation) to evaluate the data to determine the root cause and to develop appropriate mitigation’s.
Sofema Aviation Services www.sassofia.com offers a range of regulatory and vocational training including Maintenance Error Management System training for staff and Instructors as well as a range of Safety Management System Implementation and ongoing management courses.
For further details please email: office@sassofia.com