Most operators maintain structured occurrence reporting systems. Databases are active, trends are monitored, and internal reporting channels are established.

However, reporting activity must not be confused with comprehensive hazard identification.

Occurrence reporting is inherently reactive. It captures events that have already materialized. Proactive hazard identification, by contrast, aims to detect latent conditions and emerging risks before they result in occurrences.

A common systemic weakness is excessive reliance on voluntary reports as the primary source of hazard data. This creates a “reporting illusion,” where the organization assumes risk visibility is sufficient because reporting volume is high.

Effective hazard identification requires deliberate mechanisms such as:

  • Structured operational risk assessments,
  • Line Operations Safety Audits (LOSA),
  • Focused safety studies,
  • Active engagement of operational management.

Without systematic risk exploration, the SMS remains reactive by design.

Conclusion: A reporting system collects data on what has happened. Hazard identification requires structured efforts to understand what could happen.