Safety Policy Greatly Affects Safety Culture and Safety Performance
"Safety Policy" is a major asset for building an effective safety culture in aviation safety management systems (SMS). An aviation SMS is a complex system of interrelated components and elements, and "Safety Policy" is one of the four SMS components (or pillars). For a quick review, the four SMS components are:
- Safety Policy;
- Safety Risk Management (SRM);
- Safety Assurance (SA); and
- Safety Promotion.
Each of these four SMS components is essential to the success of EVERY aviation SMS, regardless of whether your company is an:
- Aviation maintenance organization;
- Flight School, etc.
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Safety Policy Critical to Aviation SMS Success
The Safety Policy component is critical to every aviation SMS that hopes to maximize safety benefits. The safety policy should not be tucked away somewhere out of site, or just used to "check the box."
The effective treatment of your safety policy component will positively influence the other three components to build a robust and resilient safety culture. As some quick examples, Safety Policy affects the other three components, such as:
- Safety Policy elements should be included as an SMS training requirement (Safety Promotion component);
- Safety Policy outlines employee protections from management for self-reporting errors and mistakes, therefore, safety policy becomes instrumental in stimulating hazard reporting behaviors (Safety Assurance component); and
- Safety Policy defines the scope of the aviation SMS, which becomes essential in Safety Risk Management activities (i.e., System Description and hazard identification).
The Safety Policy pillar is about building a skeleton framework for your SMS implementation in terms of:
- Setting expectations;
- Delivering most critical safety information; and
- Guiding safety behavior.
Here are 4 pieces of a safety policy that you should have in your aviation safety management system.
1 - Mandatory and Voluntary Safety Issue Reporting Policy
Employee participation is critical to the success of every aviation SMS. There is a realistic expectation that all employees are required to support the SMS implementation through active participation and reporting safety concerns.
Safety reports from employees provide essential data for management to address these reported safety concerns and improve the "system." Management must become aware of a deficiency to mitigate risk promptly. Therefore, employees are obligated to immediately report safety concerns not only for their safety but also for the safety of other affected stakeholders.
Since the days of the "traditional safety program," there has been the concept of events that MUST be reported and those "nice to report" events. We can categorize these types of events as either:
- Mandatory (required to report); and
- Voluntary (not required, but management is interested in the report to review and mitigate risk).
Examples of mandatory reports may include:
- Events related to aircraft operation (fuel related, collisions, crew incapacitation, etc.);
- Technical-related events (structural-related, system malfunctions, maintenance);
- Events related to air navigation services (collisions, close calls, etc.); and
- Events related to airports and ground handlers' treatment of passengers, mail, and cargo.
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Importance of Voluntary Reporting in Aviation SMS
Mandatory and voluntarily reported safety issues are very important for optimizing the safety reporting culture for your organization. While the reasoning behind mandatory reports remains self-evident, justifying voluntary reports requires a bit more consideration.
To quickly get to the point, consider the image at the right. In short, the image depicts that for every major event, there will be 600 close calls or minor events. This image is based on Heinrich's accident triangle.
What the image NOT telling us is that there will be 600 minor events, and then a major event will occur. The major event could be the first event, the 300th event, or fall anywhere else in the continuum between one and six hundred events. What we want to stress is that those 600 events will often be considered among the "voluntarily reported safety events."
Why Urge Employees to Report All Close Calls and Minor Events?
Minor events and close calls are important to the risk management process. They provide ample opportunities for management to address these minor events before the underlying hazards manifest into the major event. To put this another way, your SMS has up to 600 opportunities to mitigate the risk that is related to the major event.
While I'm talking about close calls and minor safety events, let's not forget that we got here by discussing the importance of employees submitting any type of issue that may potentially affect safe aircraft operations. Most of these safety reports will fall under the voluntary reporting category.
So how do you relay this important safety concept to all your employees so that they remain alert and submit ALL minor safety issues and close calls? We can tell you that it starts with the safety policy. You may have another name for the policy that urges employees to submit certain types of safety issues, such as the "safety reporting policy." The safety reporting policy can be a subset (or part) of the main safety policy.
This safety reporting policy simply lists:
- What kinds of safety issues employees must report; and
- What kinds of safety issues employees can report if the situation warrants it?
Having this kind of safety policy offers the kind of guidance that could otherwise deter employees from not reporting seemingly unimportant issues. Some safety managers don't care for language like "mandatory," but the fact is that every job has requirements that one must complete.
It's healthy to set boundaries like this, and it gives clear guidance that employees can follow to meet expectations. Having this type of policy is conducive to developing and maintaining an effective safety culture that does not have to be continuously prodded to submit safety reports.
This safety reporting policy can be as simple or detailed as you would like. It will be very helpful for employees to provide the types of issues that are mandatory/voluntary as well as a brief description. As a power tip, your safety team should include this policy as a part of recurring SMS training.
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2- Safety Org Chart
"A picture is worth a thousand words." This is no less true of organizational charts. Organizational charts visually illustrate the hierarchical relationship between employees' positions or jobs. Not all org charts are created equal, and an org chart is an aviation SMS implementation that is meant to show the hierarchy in relation to the aviation SMS, and not necessarily the formal reporting structure of the company.
Org charts will differ from quality to safety operations. Org charts measure two things:
- Hierarchy of responsibility; and
- Information flow.
The second point is extremely important and still remains an overlooked aspect of org charts as used in aviation SMS. When employees want to know what happens with safety information, they look at the org chart. When employees want to know whom to talk to, they look at the org chart.
Having a safety org chart also proves that management has outlined the structure of the SMS initiative, including duties and responsibilities of all personnel to the SMS implementation.
3 - Non-Punitive Reporting Policy
Most companies now include a non-punitive reporting policy as a part of their safety policy repertoire. This policy is absolutely essential for any company wishing to optimize its safety reporting activities. The non-punitive reporting policy:
- Assures employees that management will not retaliate for self-reporting errors and mistakes;
- Emphasizes employee responsibilities to the aviation SMS;
- Highlights the importance of safety reporting behavior for successful SMS implementations;
- Smooths the way for hazard identification activities that preclude safety reporting; and
- Continually reminds employees of non-punitive reporting during recurrent training and safety promotion activities.
Why is a non-punitive reporting policy so important? Unfortunately, employees at many companies are afraid to report safety issues. We can say that these fears are based on past management behavior, especially in companies that believe the best way to handle an event is to fire the actors responsible for the event. Unjustified punitive responses damage safety cultures.
Employees will not report safety events when they know they may lose their jobs or that their friends may be punished as a result of the safety report. This is not a good situation, so we need to reduce this fear of managerial retribution.
Part of overcoming this fear is:
- Continually reminding employees of the non-punitive policy;
- Reinforcing this policy through visible action (walk the talk and not conflict with the published safety policy); and
- Explicitly listing behaviors that are not protected by the non-punitive reporting policy, such as drug abuse, willful sabotage, or unlawful activities.
Related Aviation Safety Reporting Articles
- 5 Simple Tips to Improve Aviation Safety Reporting Cultures
- Understanding Mandatory and Voluntary Safety Reporting in Aviation SMS
- How Confidential Aviation Safety Reporting Systems Offer Assurance to Employees
4 - Safety Manager Contact Information
A common audit finding is that employees don't know who their safety manager is. This problem increased as organizations get larger. The primary way to combat this easily avoidable audit finding is:
- Create a policy that includes the safety manager's name and contact info;
- Include this policy as an initial training requirement; and
- Include this policy as a recurring training requirement.
The fact is that in larger organizations the safety manager doesn't have time to interface with each employee. Having this kind of policy will help ameliorate this problem. A power tip is to publish the safety manager's contact information in your safety promotion communications.
Final Thoughts on Safety Policy in Aviation SMS
The Safety Policy component of an aviation SMS implementation receives considerable attention early in the implementation process. After all, the safety policy is laying out the ground rules and the framework for the SMS.
In order to implement an aviation SMS, the SMS must have structure. The safety policy defines the roles, responsibilities, and relationships in the SMS. Without this SMS component, an SMS would have no common structure and no accountability from management. This is perhaps key to differentiating the traditional safety program from a formal aviation safety management system.
If you are starting your SMS implementation, or feel it is time to review your SMS implementation, please review these useful resources.
Last updated April 2023.