Saturday, January 28, 2017

How Does One Know If An Organization Is Applying The Non-Punitive Policy

That an organization has a non-punitive policy is an organizational and senior management statement
of accountability and a commitment of support for improved job-performance. In many
With the stroke of a pen the reactions to future events are set.
organizations, personnel job-performance has reached its limits with little, or no room for improvements, until there are unexpected and major quality flaws or improper customer services discovered. Sometime these events are named “mistakes” which initiate the process of learning-stagnation and there is no further action to learn from this “mistake”. Applying the non-punitive reporting policy is a policy to learn from mistakes and train for improvements.

A safety management system should include any requirements for an effective and continuous improvement of the SMS system. A non-punitive policy is a system-design regiment to be included as any additional requirements for the safety management system. This requirement is not a specific non-punitive policy design requirement, but it becomes an operational performance criteria for the SMS to function effectively.  When assessing the performance of an SMS, there is a requirement to apply a policy for the internal reporting of hazards, incidents and accidents, including the conditions under which immunity from disciplinary action will be granted. Immunity is for a person to be protected, or exempted from something, especially an obligation or penalty.

Data is formatted to comprehensive information.
This requirement to include a policy where there is immunity from disciplinary actions is applicable to the organization itself, or to the senior management team and is not applicable to employees of the organization. However, the non-punitive policy the organization develops becomes applicable to their employees in just-culture environment as an occurrence reporting tool, and applicable to the management to ensure this policy is applied as intended.   

There  are several tools available to analyze operational data either to confirm that the policy is applied as intended or to discredit opinions of an effective policy. One of these tools is to analyze identified training and training records for the person who submitted a report. After the airport, or airline received the report they applied their non-punitive policy to the contributor's behavior. An organization may have a check-box marked on the paper-format report form, or in electronic format that the non-punitive policy was applied, but these check-box tasks does not qualify as data to confirm, or discredit that the policy is applied. Check boxes are not direct-data, but indirect-data as triggers for further actions. The confirmation of applying the non-punitive policy is found in the training records.        


Saturday, January 14, 2017

Understanding the Non-Punitive Policy

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
Writing a non-punitive policy is a skill of quality assurance.
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.

Understanding the message of a non-punitive policy is a learning process.
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”.