Aviation Safety Letter 2/2005
More Thoughts on a "Non-Punitive" Reporting Policy
Blackfly Air managers are back; this time briefly exposing their limited understanding of a "non-punitive" reporting policy on page 6. Here are some expanded thoughts on this important safety management system (SMS) component. All companies should strive to develop a non-punitive, disciplinary policy as part of their SMS. Employees are more likely to report events, and cooperate in an investigation, when some level of immunity from disciplinary action is offered. When considering the application of a non-punitive disciplinary policy, companies might want to consider whether the event involved wilful intent on the part of the individual involved, and the attendant circumstances. For example, has the individual been involved in an event like this before, and did the individual participate fully in the investigation.
A typical non-punitive reporting policy might include the following statements:
Safe flight operations are ABC Airlines' most important commitment. To ensure this commitment, it is imperative that we have uninhibited reporting of all incidents and occurrences that compromise the safety of our operations.
We ask that each employee accept the responsibility to communicate any information that may affect the integrity of flight safety. Employees must be assured that this communication will never result in reprisal, thus allowing a timely, uninhibited flow of information to occur.
All employees are advised that ABC Airlines will not initiate disciplinary action against an employee who discloses an incident or occurrence involving flight safety. This policy cannot apply to criminal, international or regulatory infractions.
ABC Airlines has developed safety reports to be used by all employees for reporting information concerning flight safety. They are designed to protect the identity of the employee who provides information. These forms are readily available in your work area.
- We urge all employees to use this program to help ABC Airlines continue its leadership in providing our customers and employees with the highest level of flight safety.
Such a policy should be clearly laid out and communicated to all staff. Some operators communicate this policy to their staff by having it printed on the hazard reporting forms. In order to encourage a healthy reporting culture in a company, there should really be only three reasons to discipline an employee. They are:
- wilful negligence;
- criminal intent; and
- use of illicit substances.
For further information, consult Transport Canada's Safety Management Systems for Small Aviation Operations - A Practical Guide to Implementation (TP 14135), and Safety Management Systems for Flight Operations And Aircraft Maintenance Organizations - A Guide to Implementation (TP 13881).
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