The European Commission (EC) has published a roadmap for implementing a pan-European safety management system that, in theory, leverages existing state-level initiatives and suggests ways to create broader efforts to link them together. The document, technically a “communication” from the EC to the European Parliament, sets the stage by noting what has become an aviation industry maxim: keeping accident rates low is a noble goal, but keeping fatalities from accidents low will grow ever more challenging as the skies get busier.

“Whilst the current system for ensuring safety has been highly successful in the past, it appears to be reaching the limit of its effectiveness in driving down the accident rate,” the paper explained. “The Commission believes that we must, therefore, move from reaction to prevention by adopting a proactive approach to aviation safety, one that places emphasis on the systematic targeting of actions to address significant risks based upon the results of careful analysis of information gathered from across the [European] Union.”

The document lays out 10 action items, ranging from specifics such as how to create an effective occurrence reporting system to generalities like whether its plan should be codified in actual regulations. Much of the work calls for cooperation with EASA, and some of it—such as a requirement that EASA “regularly” update its European Aviation Safety Plan, first published in early 2011—calls on EASA to take action.

Much of the EC's focus is on occurrence reporting. While many European states have effective programs, some suffer from a lack of open reporting, which leads to some occurrences going unreported. “This problem raises the need for action in the area of the implementation of a 'just culture,'” the EC wrote. “Further work is required to encourage a culture of open reporting within the aviation industry and to support the development of an environment where individuals feel able to report safety significant events without the fear of reprisal.”

Even given the solid programs, a gap exists in pulling all of the data together and gleaning actionable information from it on a continental level. “Today we have the situation where some member states, EASA, Eurocontrol and others do their own analysis,” the EC said. “Whilst this is effective in enabling each player to address their own issues, there is potential for a great deal of duplication of effort which, more importantly, can hide a significant safety issue. An event that appears to be a 'one off' occurrence in one member state, when looked at across the Union as a whole, can point to a need for action.”

To remedy this, the EC will issue a proposal “to further develop safety analysis at [the] EU level.”

Another challenge in unifying occurrence reporting—and creating an effective, sustainable safety management system—is getting everyone working from the same set of classifications. “There is not yet a universally accepted risk assessment methodology in common use across the European Union for all the aviation domains which would enable a standardized approach and better priority setting to tackle those risks that pose the greatest threat to safety,” the EC noted. “This shortcoming will have to be overcome.”

The EC also identified the need to create a common set of standard performance indicators “covering all of the aviation domains.” EASA already has created some, such as a fatal accident rate based on 10 million flights, but more need to be established, with input from member states.

Another key part of a system safety approach that must be established for Europe: performance targets. Thanks to a 2010 regulation, work is underway in the air traffic management arena, but the rest of the industry must be covered as well—something that the EC acknowledged “will not be an easy task.”

The document underscored one point repeatedly: stakeholders will be consulted as part of making any major decisions. The EC also noted that while much of the plan is set forth without underlying regulations, it may be necessary to put some laws on the books to build and maintain what the EC envisions.

“It may be necessary, once further experience is gained and the effectiveness, or otherwise, of this approach becomes clear, to consider whether it is necessary to put the EU Aviation Safety Management System on a formal basis in order to ensure its continuing success,” the document noted.“The Commission will therefore monitor the progress made as the system develops and consider if specific regulatory action should be proposed to ensure the effectiveness of the system into the future.”