The European Union Aviation Safety Agency (EASA) has published its latest report examining the relationship between civil aviation safety and socio-economic factors, as required under Article 89 of the EASA Basic Regulation. Focusing on certain safety-critical personnel, including flight crew, cabin crew and operational control centre (OCC) staff, the study drew on academic literature, occurrence reporting data, operator information and worker surveys to assess how working conditions and employment structures may influence aviation safety.
The ETF played an active role throughout this process, sharing the worker survey with our affiliates across Europe and raising concerns directly with EASA during the stakeholder consultation phase.
Fatigue and communication issues identified as key safety precursors
Among the report’s most significant findings is the identification of aircrew fatigue and communication issues as the most consistent safety precursors across the available evidence. At the same time, the study acknowledges important limitations in the occurrence reporting data held within the European Central Repository (ECR), particularly when it comes to capturing the complex organisational and socio-economic factors that can shape safety outcomes. EASA also recognises that worker surveys provide an important complementary source of information – frontline experiences that are not simply perception, but vital and often-hidden pieces of safety evidence which help to reveal concerns not visible through occurrence reports alone.
The report further highlights differences between operational and business models, including low-cost carrier (LCC) and wet-lease (ACMI) operations. Nevertheless, its headline conclusion states that no major aviation safety concern or direct systemic causal relationship between socio-economic factors and adverse safety outcomes was identified within the scope of the study – a headline finding which we believe understates the significance of the evidence.
The limitations of occurrence reporting
While ETF welcomes the publication of the report and notes that it represents a clear improvement on both the initial draft and the previous 2021 edition, we urge caution about this conclusion. The absence of a demonstrated direct causal relationship should not be interpreted as evidence that risks do not exist. In aviation, the visibility of a problem often depends on whether workers feel able and willing to report it.
This is particularly relevant when considering occurrence reporting data. Workers may be discouraged from reporting safety concerns for a variety of reasons, including fear of repercussions, a lack of trust in the reporting system, uncertainty about what should be reported or a perception that reporting will not lead to meaningful action. In increasingly fragmented and cross-border employment structures, especially within ACMI operations, these doubts can become even more pronounced. Within weaker reporting cultures, an absence of reports may reflect underreporting rather than an absence of risk.
Fatigue requires further action
The report’s findings on fatigue are especially important. Fatigue emerges as one of the clearest and most consistent indicators across the evidence base, reinforcing concerns that have been raised for many years. ETF believes these findings should be concretely used to inform EASA’s ongoing work under the BIS15 “Aircrew Fatigue” initiative and broader safety programmes.
Particular attention should be paid to issues such as cumulative fatigue, roster instability, the repeated use of maximum Flight Duty Periods (FDPs) and gaps in standby coverage. ETF also continues to raise concerns about the frequent use of commanders’ discretion, which can mask duty time extensions contributing to fatigue and limit the view of authorities over wider operational patterns. Equally important is ensuring that Fatigue Risk Management systems are delivering meaningful results in practice rather than simply being compliant on paper.
Strengthening reporting culture and just culture
The report also underlines the importance of Regulation (EU) No 376/2014, the European framework governing occurrence reporting, analysis and follow-up in civil aviation. At the heart of the regulation lies the principle of Just Culture, which seeks to ensure that workers can report safety concerns without fear of punishment.
For ETF, achieving the objectives of Regulation 376 requires more than awareness campaigns and safety promotion activities alone. It necessitates active oversight by competent authorities, robust confidential reporting mechanisms and a willingness to address fear-based reporting cultures wherever they exist. Our concerns about reporting practices in certain operations and across some Member States greatly limit the effectiveness of safety reporting as a tool for identifying and addressing concerns.
Wet-lease operations demand closer scrutiny
The findings are equally relevant for wet-lease operations, which bring together several factors that can complicate safety oversight. Highly mobile crews, complex cross-border employment arrangements and unclear responsibilities for safety management can make it more difficult to identify trends and ensure accountability. These operational models present challenges for regulators and national authorities, reinforcing the need for enhanced and continuous monitoring.
Turning findings into action
Looking ahead, ETF believes the report should serve as a starting point rather than an end point. The findings provide a strong basis for targeted follow-up actions, particularly in the areas of fatigue management, reporting culture and oversight effectiveness. They also highlight the need for closer cooperation between aviation safety authorities and labour authorities, improved monitoring of socio-economic indicators and greater attention to the specific risks associated with different business models. Strengthening confidential reporting systems, promoting Just Culture principles and improving consistency among national aviation authorities will all be essential if the sector is to gain a more accurate picture of the challenges facing aviation workers and the safety system as a whole.
The publication of this report is therefore welcomed by ETF, however, the real test will be whether its findings translate into meaningful action. The evidence now clearly states that socio-economic factors deserve greater attention and we call on EASA to implement their recommendations through concrete follow-up actions – ensuring that the findings lead to more robust oversight, a just reporting culture and tangible improvements for aviation workers and safety across Europe.