In compliance with the standards and recommended practices (SARPS) set by the International Civil Aviation Organization (ICAO), Non-punitive policy is an important element of the SMS’ implementation, that must be distributed, adopted and respected in order to have an effective SMS. However, many organizations confuse non-punitive policies with voluntary reporting processes.
Here’s a crucial point to be clarified:
The promotion of continuous safety improvements within a Safety Management System requires the implementation of a non-punitive policy which means that all the personnel have an opportunity to raise safety concerns and report hazards as their contribution to safety improvement without being punished for that or questioned about their job-performance. This type of reports may generate a hazardous and unhealthy work environment if the personnel (front employees and managers) are not aware of the context of such a policy and are not trained on it as well as the just culture. Moreover, when a non-punitive policy is applied as a “get-out-of-jail” free card only it could be applied to report excuses for inferior job performance rather than improving the safety.
That’s why , it is clear that understanding a non-punitive policy is a whole learning process that not all of the organizations give importance to , hence the absence of a meaningful result.
The key to success of a non-punitive policy is to build a bridge between an organizational culture where learning is promoted and mistakes are accepted as a learning tool but not accepted as an excuse. That’s called “Accountability”.
Furthermore, this kind of policy can only be understood in an environment where the top management is prepared to hear about the mistakes and the errors of all the lines of personnel. The personnel also have to understand through the training and awareness sessions, that whenever they state a hazard , it doesn’t always mean that they have to eliminate it immediately or they are the ones who will have to assume it and find a solution by themselves. A safety concern does not automatically make this hazard. That’s why clarity, transparency and honesty are so important to make the personnel work together in a safe environment.
Non-punitive policy is crucial for an effective SMS but requires a continuous awareness on its importance, understanding and implementation.