GM2 ORGH.MGM.200(b)(2)(iv) General requirements for the management system

BUILDING AND MAINTAINING A SAFETY CULTURE

It is recommended that the GH organisation consider the aspects and examples below to foster a safety culture within its organisation:

(a) SMS training

(1) Safety and safety culture training for all levels of management to ensure that personnel are aware of the following:

(i) All safety management practices and procedures applicable to their role.

(ii) Their individual responsibility in maintaining safety in their daily tasks. This can be achieved by highlighting aspects of safety when delivering training to develop personnel’s technical competence. The training should include explanations of why particular safety‑related actions are taken and why safety procedures are introduced or changed. The competence of personnel is proven when they are able to draw conclusions from safety information systems and willing to implement safety‑related changes.

(iii) How various human, technical and organisational factors affect the safety of the whole system.

(2) Training on the analysis of safety data and investigation of occurrences for the personnel participating in such activities.

(3) Training and communication to encourage personnel to identify hazards and suggest solutions. Use open‑ended questions to encourage discussion instead of questions that require only a ‘yes’ or ‘no’ answer.

(b) Communication on safety — open, consistent and transparent communication and information‑sharing among GH personnel regarding safety aspects, horizontally (among personnel) and vertically (from management to front‑line personnel and vice versa).

(1) Organise communication sessions to help the GH personnel understand the main concepts of safety culture and become aware of the following aspects:

(i) the importance of reporting,

(ii) the outcome of reporting (meaningful, visible result),

(iii) the potential safety consequences of not reporting,

(iv) the concept of a just culture and reporter’s protection,

(v) the difference between an inadvertent error/mistake/lapse and an intentional act/reckless conduct,

(vi) the importance of reporting errors on a voluntary basis and of sharing experiences.

(2) Organise formal and informal discussions about safety culture concepts, such as ‘error’, ‘mistake’, ‘intentional’, ‘non‑intentional’, ‘negligence’, ‘wilful misconduct’ and ‘gross negligence’, and examples of ‘crossing the line between error and negligence’.

(3) Ensure the timely and effective dissemination of safety notices and safety information to all personnel.

(4) Include any feedback from past briefings and report on follow‑up action taken.

(5) Apply positive reinforcement (praise/thanks for appropriate behaviour).

(6) Share feedback on disseminated results of reported events on a regular basis, in both formal and informal discussions/meetings.

(7) Schedule short debriefings regularly with whole teams about how activities went — aspects that were noticeable, different, not in line with operational procedures, positive or negative — and whether something should be changed. It is important to understand why people do things the way they do.

(8) Listen to the concerns of personnel, without being defensive. The purpose of a briefing is to encourage personnel to start thinking about safety problems. Practical examples can be used in the discussion.

(9) Review the lessons learned from the organisation’s own occurrence reports and safety surveys on a regular basis.

(10) Arrange a ‘display wall’ in the briefing room, to pose questions to personnel — for example, asking them for their opinion about changing an operational procedure — or to inform them about changes stemming from the industry standards that they apply, the regulator or ICAO.

(11) Arrange competitions and games that aim to increase awareness of safety or improve the safety of day‑to‑day activities.

(12) Personalise safety outcomes (including health and safety).

(13) Participate in safety‑related communication campaigns organised by the aerodrome operator or aircraft operator at the aerodrome where the organisation provides GH services.

(c) Safety reporting

(1) Personnel are encouraged to report essential safety‑related information. However, a clear line is drawn between acceptable and unacceptable behaviour. This helps in building accountability.

(2) Safety reporting is facilitated using forms that are easy to find, easy to fill in and easy to submit, and that ensure full anonymity. Consider the difficulty of reporting after/during a night shift or a difficult shift (involving congested traffic, severe weather conditions, etc.). In unusual or emergency situations, personnel can report directly to decision‑makers to allow a timely response. This aids the flexibility and effectiveness of reporting.

(3) The outcome of internal safety investigations should ensure that the GH organisation disseminates the lessons learned and applies non‑punitive measures to improve the safety culture within the organisation and avoid the occurrence of similar incidents.

(d) Human resource management

(1) Ensure management’s full involvement in and support for these activities;

(2) Allocate sufficient resources to analysing safety events, to identifying the root causes and providing feedback to reporters and to creating a hazard register based on which safety performance indicators can be established to measure the achievement of safety objectives.

(3) Ask front‑line personnel to provide input or feedback when developing or improving procedures.

(4) Involve, as necessary, front‑line GH personnel to clarify technical or procedural aspects in the investigation of occurrences and further dissemination of the outcomes and lessons learned from an event.