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”.