2.8To what entity shall I report occurrences?

2.8 To what entity shall I report occurrences? The Regulation gives persons subject to the MOR obligation the following reporting channels (Article 4(6)): The mandatory reporting system of the organisation which employs them or contracts or uses their services, or The mandatory system of the Member State of establishment or of the competent authority of their organisation, or by the State which issued, validated or converted the pilot’s licence or The mandatory system of EASA.

This is notably consistent with the integration of occurrence data into the safety management system of an organisation. The reporting through the system of a Member States is understood as the one to be used in the absence of any organisation or in situation where the reporter is not confident in the reporting system of an organisation certified or approved by that Member State. The reporting through the mandatory system of EASA is understood as the one to be used by organisations for which EASA is the competent authority or in situation where the reporter is not confident in the reporting system of an organisation certified or approved by EASA. Whereas the most direct reporting channel should be preferred (the organisation’s reporting system) and even promoted, it is understood that direct reporting to a competent authority by a person employed by an organisation or whose services are contracted or used by this organisation is not prevented. Indeed, situations may occur where reporters are not confident in the reporting system of their organisations and may wish to use another reporting channel. This is consistent with the objective of fostering a ‘Just Culture’ which is pursued by Regulation 376/2014. It aims, in particular, at ensuring confidence of aviation professionals in occurrence reporting systems and encourages them to reports any relevant safety information with a view to contribute to the enhancement of aviation safety and accidents prevention. It should be highlighted that the choice of a reporting system should be exclusive. Indeed the use of ‘‘or’’ in Article 4(6) indicates that only one report is required to be made by the reporter and that an occurrence should not lead to multiple reports from the reporter. It is therefore understood, in accordance with the Regulation, that a reporter should not report an occurrence to his/her organisation and report it as well to a Member State and/or to EASA. This is without prejudice to other reporting obligations contained in other legal acts (see also section 2.6).