AMC1 ORGH.GEN.165 Safety reporting system

CONTENT, USAGE, CHARACTERISTICS OF THE SAFETY REPORTING SYSTEM

(a) The GH organisation’s reporting system should be adequate for the size of the organisation; it should be kept simple and include details on what, how, where and when to report.

(b) The reports should meet the requirements of point ORGH.GEN.160 on occurrence reporting in terms of time, format and information to be reported. The GH organisation should provide the means of and format for reporting when this is not established by the relevant authorities under point ORGH.GEN.160.

(c) The reporting system should:

(1) ensure confidentiality, and enable and encourage non‑punitive, free and frank reporting of any potentially safety‑related occurrence or risk, including incidents such as errors or near misses, safety issues and identified hazards;

(2) provide acknowledgement to the reporter of the successful submission of the report — for small organisations, verbal acknowledgement may be sufficient.

(d) The reporting system, including internal safety reporting, should clearly express the purpose and objectives. The organisation should do the following.

(1) Contain procedures to implement a just culture.

(2) Identify those reports that require investigation and determine whether the event reported qualifies for reporting under points (b) and (c) of point ORGH.GEN.160. A small GH organisation should seek advice from its competent authority on this matter.

(3) Investigate the causal and contributing factors related to the occurrence, incident, error or near-miss event that was identified, including technical, organisational, managerial and human factors. The aim should be to understand what happened and how it happened and to prevent or reduce the probability and/or consequences of future recurrence. Complex organisations should analyse the collective data showing the trends and frequencies of the contributing factors.

(4) Take the necessary corrective actions based on the results of the investigation, to address the root cause of the event and to disseminate knowledge of relevant incidents and accidents and of actions taken to the employees concerned.

(5) Ensure, where relevant, cooperation with the aircraft operator and the aerodrome operator on occurrence investigations by exchanging relevant information to improve ground and flight safety.

(6) Participate in the investigation conducted by the aerodrome operator or the aircraft operator, as appropriate, where the organisation is directly affected by the event or the proposed mitigation measures.

(7) Ensure that the findings of investigations feed into the relevant recurrent training while maintaining the required confidentiality.

(e) Access to reports submitted should be restricted to personnel responsible for processing, storing and analysing them. A small GH organisation may apply a more flexible approach to this restriction, appropriate to its organisational structure.