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10 jUST CULTURE BEyOND LEGISLATION
Just Culture Beyond Legislation
By Paul Reuter, ECA Board Director
ith the introduction of the Occurrence
WReporting Regulation in November
2015, the European aviation industry finally
received a legally binding definition of ‘Just
Culture’. While a binding regulation is crucial,
it is not enough. Most airlines still struggle
with the concept of Just Culture and how to
introduce it in their structure and, more
importantly, how to make it work.
The reasons for this are manifold. But at
the core, for it to work, Just Culture requires
more than just a regulatory compliance and
copy-pasting the definition in the airlines’
manuals. Just Culture is a far-reaching
paradigm shift that requires the organisation
to turn inwards, contemplate on itself and, remember Sullenberger’s landing on the values need to be lived daily - from the top
possibly, be ready to change its approaches. But Hudson. These reports on “what went right” down.
it also requires the organisation to be clear and can be just as important for the organisation to And herein lays the biggest challenge for
concise about the values it communicates and learn as the “what went wrong” ones. the organisation and its management; every
shares with its people. Shiny posters and catchy Nevertheless, it also needs to be clear that single day, in the way it communicates
slogans will not do, at least, not in the long certain behaviours, like criminal intent or internally (and also externally to a certain
run. For Just Culture to blossom, an organisa- recklessness, cannot be tolerated either for the extent), in the way the hierarchy approaches
tion will require to actively cultivate trust, simple reason that this would also undermine issues, problems, and interacts with the staff,
mutual respect, and credibility within. This, any effort to have a credible Just Culture the awareness that Just Culture principles need
however, will prove to be quite a challenge for perception. to be followed and strengthened, as well as
most organisations. So why bother? Today, the EU Regulation on Occurrence credibly fostered, must be present. Even on the
Air Transport is a complex and dynamic Reporting (376/2014) requires staff to report bad days. Or, especially on the bad days!
environment, where no matter how these events. By adhering to Just Culture Taking the time to build this culture of
well-trained or motivated an individual is, due principles, what we are trying to do is to trust and respect, taking the time to reflect on
to the physiological, cognitive, and sensory change that deeply engrained behaviour of how the organisation approaches things,
limits on the human condition, this individual hiding mistakes and rather encourage people accepting that the human element within the
will sometimes end up making mistakes, errors to honestly report these events without organisation is an important factor for success,
in judgement or the wrong analysis of a needing to fear undue retribution. on par with legislation. The European
situation. All this might lead to situations Unfortunately, we will not be able to simply legislation is a prodigious step towards an even
where safety is impaired or perceived to be decree that “We now have Just Culture and safer aviation. But pilots are at the front line of
impaired. We need to accept this and we need could everybody please behave accordingly”. the system: if we do not report events,
to be aware that, in order to continuously We will need to create, grow, and nurture this decisions or mistakes, the whole system will
improve our imperfect system (our setup, atmosphere that will slowly generate trust from remain a nice theory.
procedures, rules…), we need to get the data the staff in the organisation and foster mutual
from these “unsafe” events and deviations from respect.
the norm to analyse them and improve on For most organisations, and very often also An extended version of this article was
what we are doing and how we are doing it. It for the individuals at the helm, this will mean a published on www.eurocockpit.be as part
should also be kept in mind that often it is the (sometimes large) shift in mentality. The of ECA’s #ReportingMatters campaign.
human interference that saves the day. When organisation will need to reflect on the values The campaign aims at raising awareness
the unforeseen complexity of the operation it wants to share and uphold. It needs not only on the new Occurrence Reporting
Regulation in Europe, encouraging safety
leads to a disaster, the human, relying on to continuously promote these values within reporting and promoting Just Culture.
experience and possibly on instinct, acts. Just the organisation but, just as importantly, these
Issue 3 | 2016 InterPilot | The safety and Technical Journal of IFALPA