Purpose of Non-Punitive Reporting Policies in Aviation SMS Programs
Dedicated, hard-working safety managers drive the setup of airline and airports' aviation safety management systems (SMS).
These safety managers are often left to decipher ambiguous requirements that are open to multiple interpretations. This comes into play especially when upper management wants to "pencil-whip" an aviation SMS program and merely check the boxes.
Most safety managers are not content to merely "check the box." They have integrity and want to do the right thing. After all, each of us wants to do the best we can.
In Phase 2 of an ICAO compliant safety management system implementation is to setup the reactive risk management processes. One part of these reactive risk management processes is the "hazard reporting system," which can be as simple as paper-based reports, or as complex as electronic forms on the Internet that notify safety managers whenever new hazards are reported.
An essential element of this hazard reporting system is the "non-punitive reporting policy." Non-punitive reporting policies:
- Reduce friction (resistance) to the aviation SMS program;
- Builds confidence in the SMS processes;
- Help engender trust between front-line employees and managers;
- Are the basis of the "just culture;" and
- Offer clear understanding of what to expect when employees submit hazard reports.
In this article, we'll describe:
- What one expects in a non-punitive reporting policy;
- Discuss the importance of reviewing your non-punitive reporting policy; and
- Provide a template for you to use or modify at your discretion.
Non-Punitive Reporting Policies are VERY Important
Not all cultures have adapted "just culture" concepts. In several Asian countries, there will always be somebody to take the blame. Heads must roll. When employees realize that consequences follow reports of bad news, how often will you expect employees to report.
In short, without an effective non-punitive reporting policy, your airline or airport's reporting culture will not exist!
Whenever there is some degree of protection, employees are more inclined to participate in SMS programs and take ownership of the processes.
Note how I stressed "some degree of protection." Employees should never expect a blind eye whenever there is:
- Willful misconduct;
- Unwillingness or inability to learn from past similar events;
- Deliberate neglect of the involved parties; or
- Unlawful conduct.
Management must always conduct a thorough and careful analysis of the event whenever determining whether not to honor the non-punitive reporting policy.
Getting the Non-Punitive Reporting Policy Rightly Worded
Non-punitive reporting policies are not new. Some regions call these policies their "safety reporting policy." This label may be confused with another policy whose purpose is to outline what types of reports your airline or airport desires to enter their aviation risk management process and the guidelines for submitting these safety reports.
There are several non-punitive reporting policy templates that have been made available over the past ten years. It is probable that if your airline or airport has a non-punitive reporting policy, it originated from a template that came from an SMS training provider or one of the civil aviation authorities known for publishing good aviation SMS content. From experience, I have found that these CAAs produce the best content, in order of excellence:
- Civil Aviation Safety Authority (CASA-Australia);
- Federal Aviation Administration (U.S.); and
- Transport Canada.
If you started your non-punitive reporting policy from a template, did you change the name of the company in the template. I don't know how many times I've heard the story of auditors going into an airline or airport to find very nice SMS documentation. The only problem was that in many cases, the safety manager neglected to change the company name.
Copying manuals was very common five years ago. One could purchase an SMS manual for as little as $1200 USD. The problem with this approach is that SMS manuals are unique to the operator, as each operation is unique.
Templates are great places to start your non-punitive reporting policy. They serve as a great starting point or inspiration to quickly crafting a non-punitive reporting policy that is suitable to your management's style.
Get Management Support for Reporting Policies
Non-punitive reporting policies may be seen as idealistic and too liberal for many managers. Before posting your non-punitive reporting policy, make sure that top management supports the concepts outlined in your policy and that this policy is communicated to all members of your airline or airport.
Also, be careful that management is practicing what your SMS program's policies are preaching. That is, be consistent in applying the policy.
Make Sure to Review Reporting Policies Annually
There must be a mechanism in place to ensure your aviation SMS policies are reviewed regularly. Some advanced aviation SMS software programs will send managers an alert whenever policies require review. However, you don't need anything fancy. Simply put a date into your calendar to serve as a reminder.
There is risk when putting an alert into your calendar to review policies. What happens when you leave the company or move to a different department? Not your problem, some will say. But most safety managers are sincere, dedicated professionals and will find a way to minimize this risk.
Policies should be reviewed and accepted by upper management. Safety managers typically act as the facilitators in this regard.
Final Thoughts on Non-Punitive Reporting Policies
Non-punitive reporting policies are essential to developing a just culture and to enhance your airline or airport's hazard reporting culture.
It is never too late to implement such a policy. And don't forget to review it regularly. Many aviation SMS software programs have management tools to remind managers that policies and procedures require review.
You may be interested in comparing your non-punitive reporting policy with one of three industry-accepted templates.