Understanding the Non-Punitive Policy
Insightful Prospective from frequent contributor CatalinaNJB.
A
non-punitive policy is not a “get-out-of jail free card”, but a policy for
continuous, or continual safety improvements within an SMS system. When a
non-punitive policy is understood within an organization all personnel have an
opportunity to raise safety concerns and report hazards as their contribution
to safety improvement. When hazards are not identified, they are latent and
unknown risk factors with a potential to cause an incident or accident. In
organizations where there is no training provided for understanding the
non-punitive policy, the doors are left wide open to apply the policy to any non-job
performance activities. When a non-punitive policy is applied as a
“get-out-of-jail” free card it could be applied to report excuses for inferior
job performance rather
than reporting specific to the
hazard, or incident itself.
Applying a non-punitive policy as a
safety-excuse tool is when contributors reports on themselves to avoid being
questioned about their job-performance. This type of report may take form in of
projecting a less desired outcome to a mistake with the assumption that others
in the organization have had similar thoughts and experiences as oneself and
therefore accept the report without further investigation. Where mistakes are
widely accepted in an organization to be non-punitive policy applicable, the
door to learning is forever closed.
In organizations where the door to
learning is closed, another door opens wide to report on others of their
job-performance mistakes. These types of reports may take form of projecting a
less desired job quality onto safety. Since learning already is inhibited by
organizational acceptance of mistakes the safety-card becomes the
“straight-flush” to generate a hazardous working environment.
When these types of reports are accepted as a
replacement for learning the organization is undermining the concept of
learning and the promotion of continuous, or continual safety improvements.
Contributors
of hazard reports may expect that hazards reported are eliminated immediately even
if the hazard reported is a low impact hazard. This expectation comes from the
fact that a hazard stated is assumed to have a safety impact and that someone else
has an obligation eliminate the hazard immediately. That someone has an opinion
of a hazard being a safety concern does not automatically make this hazard a
safety risk. It takes an analytic process to identify the risk factor of a
hazard including collection of more data. An identified hazard accompanied by
an opinion of being a safety risk, is only an opinion of a hazard. An
identified hazard does not automatically become a risk, even if accompanied by
that opinion.
When the non-punitive policy is
understood in an organization and applied within a Just Culture, opportunities
of options becomes available to improve safety. 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. This bridge is called the bridge of accountability.
These options to improve safety are
available since learning is acceptable, reporting has become fact-finding mission
and the organization is prepared to learn from the expert. The experts being
someone who just learned the hard way by making an error in job performance. Understanding
the non-punitive policy is to feel the contribution of productivity when
performing job-tasked responsibilities of high quality. A non-punitive policy
can only be understood in an environment where “the boss” accepts to hear “bad
news”.
CatalinaNJB
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