Simplified mechanism for occurrence processing in smaller organisations
It is understood, and it also stems from the Regulation 376/2014*, that the imposition on organisations of occurrence reporting obligations should be proportionate to the size of the organisation concerned and the scope of its activity. It should therefore be possible, in particular for smaller organisations, to decide to join or merge functions related to occurrence handling within the organisation, to share occurrence reporting tasks with other organisations of the same nature or to outsource the collection, evaluation, processing, analysis and storage of details of occurrences to specialised entities approved by the competent authorities of the Member States.
However, such entities should still comply with the protection and confidentiality principles established by Regulation 376/2014, and also, the outsourcing organisation should maintain appropriate control of the outsourced tasks and should be ultimately accountable and responsible for the application of the requirements prescribed by this Regulation 376/2014.
Article 6 of Regulation 376/2014 (Collection and storage of information) foresees that by agreement with the competent authority, i.e. Civil Aviation Agency of Latvia, small organisations may put in place a simplified mechanism for the collection, evaluation, processing, analysis and storage of details of occurrences. And it continues, stating that organisations may share those tasks with organisations of the same nature, while complying with the rules on confidentiality and protection pursuant to Regulation 376/2014.
With this material Civil Aviation Agency informs the organisations on:
Criteria to determine for which organisations a simplified mechanism would be appropriate and applicable, and
Guidelines on what a simplified mechanism is.
This material is based on International Collaboration Group’s (SM ICG) material advising SMS implementation for Small Organizations, bearing in mind that Occurrence reporting system is one of the cornerstones of an SMS.
Throughout this guidance, we consider an organization with between one and nineteen staff as a Small organization. For more information request Organisation’s Size and Complexity Assessment from LV CAA.
In general, Occurrence reporting system does not have to be complicated to be effective.
Before starting to implement your Occurrence reporting system, talk to your LV CAA to find out what is required for the size of your organization. Then carry out analysis to see what you have already versus what is required and see what is missing. As with any system, it is also important to remember that your Occurrence reporting system should be customized to reflect your organization and the operating environment.
How complex is the small organization?
It is not just the size of the organization that matters but the risk and complexity of the activity.
Complexity considerations include:
- Operating environment (mountainous terrain, arctic operations, offshore operations, etc.);
- Types of operations (passenger operations, cargo, aerial work, Emergency Medical Services, etc.);
- Fleet complexity, such as number of aircraft or aircraft types;
- Number of locations (bases);
- Maintenance organisations; number of ratings, types of product ratings, specialized work, technologies employed, number of customers and subcontractors;
- Types of products and parts designed/manufactured;
- Number of aircraft movements (aerodromes and Air Navigation Service Providers (ANSPs));
- Surrounding terrain and levels of equipment at aerodromes;
- Density and complexity of traffic for ANSPs;
- Extent of contracted activities; and
- Number of runways and taxiways at aerodromes.
* Regulation (EU) No 376/2014 of the European Parliament and The Council of 3 April 2014 on the reporting, analysis and follow-up of occurrences in civil aviation, amending Regulation (EU) No 996/2010 of the European Parliament and of the Council and repealing Directive 2003/42/EC of the European Parliament and of the Council and Commission Regulations (EC) No 1321/2007 and (EC) No 1330/2007.