Non-Punitive Reporting of Hazards, Incidents Or Accidents

Non-Punitive Reporting of Hazards, Incidents Or Accidents

Post by CatalinaNJB

A non-punitive policy under an SMS program is a policy for the internal reporting of hazards, incidents or accidents, including the conditions under which immunity from disciplinary action will be granted. The intent of the policy is for organizations to receive data from personnel and then analyse how organizational processes are functioning, or why they are not being as safe as first assumed.

A simple non-punitive reporting policy

Within an SMS organization, the outcome of processes is not totally dependant on inputs, but also on human factors variables. The concept in process management that outcome is dependant on what is put into the process is based on standard inputs without variation. Within an SMS environment the variables are human factors, where the same input to a process may yield a different outcome with different personnel involved. If the outputs of SMS processes did not vary the variables of human factors, a non-punitive policy would be redundant and ineffective. 

Since the beginning of aviation, airports and airlines, have been audited, inspected and assessed for compliance. One year the audit result was found to be in compliance, while the next year the same systems were found not to be in compliance. Often, there were changes to audit and inspection results when an organization hired new personnel to do audits and inspections. This does not imply that one was more correct than the other, but that the variables of human factors made a change in outcome with the same process. In a real world, human factors variations spread out like a dropped bag of marbles.           

Human factors variations could be controlled by enforcement. When applying this concept, variations are not managed, or considered, they are only enforced. Some industries are heavily into enforcing technical standards. When enforcing an outcome, the enforcement is of the outcome, or process result itself, and not of the processes which lead up to the result. This is an effective tool for selective non-compliance discovery, but an extreme ineffective and resource demanding tool for an unbiased process compliance discovery. In addition, for fully compliance with this enforcement process, the technical enforcement process itself must also self be enforced, which is a concept causing an indefinite level of layers of enforcement. However, when applying a non-punitive policy of process compliance, the resource demand is drastically reduced, compliance increased and higher profit generated.

Variables are the fork in the road

  

Safety Management System in aviation has recognized that human factors exist and that identifying these variables will increase safety margins of processes with the result of a more effective and streamlined organization. With a non-punitive policy in place, the odds of receiving data of critical importance to safety are increasingly in favor of the airports, or airlines. A non-punitive policy does not imply that in times prior to SMS, personnel received punitive punishment for internal reporting of a hazard, an incident or an accident. The non-punitive policy is a defined link within an SMS system for the system be compliance with organizational polices, that it is documented, approved, accountable and applied to operational processes.

CatalinaNJB