Havoc –
You are correct, there is a certain element of reporting error in internal self-reports. But the safety manager should be looking for clues both internally and externally and not relying solely on internal metrics.
SAS –
The more I think about your question the more I feel your “safety manager” is playing the victim.
As you well know, the HEMS industry is in crisis – HEMS pilot is currently the most hazardous profession in the US and ER doctors are advocating against the use of HEMS except in cases of suspected brain injury. Every time another twisted Lifeguard flight is shown on the news the perception of HEMS, and in fact the entire helicopter industry is degraded. To perform effectively, a manager needs to understand the threats/risks/costs involved in all aspects of an operation; if my safety manager came to me with this statement I would wonder where they have been for the last year, what they have been doing and why they are keeping secrets from me.
I think a better strategy for your manager would have been for him/her to the Managing Director 12 months prior, made a case that fatal accidents are the largest unpredictable and unnecessary cost to the company, and explain that the steady recurrence of accidents is a threat to future business (including examples of direct costs (replacement costs, insurance premiums, litigation) and an estimate of indirect costs (turnover, loss of future revenue). This would be followed by a plan to determine the threats to safety at the operation (analysis of internal/external incidents/accidents using some standardized system such as SHEL-L or HFACS; if you are a HEMS operator, Burt Boquet has already done this work for you) and then a method to review the findings and develop strategies to eliminate/mitigate the biggest threats/risks. These plans would include both costs and quantitative measures to compare against, so during quarterly (monthly?) reviews of these efforts Safety can demonstrate to Management the effectiveness of their efforts. One fatal every thirteen months is pretty harsh; in this example it should be pretty easy to make a business case for safety. If your manager doesn’t do it, it’s only a matter of time before plaintiff’s attorneys does the work for him.