The M&E Just Policy for Maintenance Errors and Violations

An explanation of the process

The M&E Just Policy for Maintenance Errors and Violations is designed to direct the Local Manager/Supervisor in the necessary steps to take when they become aware of a maintenance-related error or violation. The specific steps called out in the Just Policy ensure that all subsequent fact-gathering is conducted in a way that is conducive to learning as much as possible about the error or violation in order to put the best fixes in place to prevent reoccurrence. The Just Policy reinforces the M&E commitment to enhancing the safety culture within our organization by ensuring the organization focus on the opportunities to learn from our mistakes, constantly improve our system design and to manage our employees in a fair, consistent and just manner.
The Just Policy requires a strong sense of “shared accountability” at all levels of the M&E organization. This means that M&E is responsible for designing the most reliable system (e.g. processes, procedures, resources, facilities, incentives) necessary to produce the desired outcomes (e.g. quality, safety, compliance) and for managing the choices made by their employees in a fair and just manner. The employee is responsible for making good quality choices and encouraged to self-report safety concerns, near-misses or errors/violations once they are identified. This delicate balance of shared accountability will only reach its fullest potential if the entire organization is operating under the principles of a just culture.
The key principles of a just culture are the foundation of the Just Policy for Maintenance Errors and Violations. A just culture balances the shared accountability and puts the same focus on the organizations responsibilities for system design and managing employee behaviors as it does on the choices made by the employees. A just culture recognizes that human errors, or human fallibility, is inevitable and it is the organizations responsibility to support the employee and to focus on the system design to reduce the likelihood of human error in the process. It also recognizes that it is human nature to drift away from full compliance; this is referred to as “at-risk” behavior. At-risk behavior is defined as a behavioral choice that increases risk, where either the risk is not recognized or is mistakenly believed to be justified. At-risk behaviors typically encompass a group of people who have become confident with a short-cut or develop a “standard practice” in order to get the job done. We all behave at-risk at some time or another. A simple example of at-risk behavior is driving 70mph in a 65mph zone, with the flow of traffic. The drivers are often well aware of the speed limit and the rules of the road, but have become confident in the past successes of deviating from the rule with no bad outcomes – typically with positive reinforcements such as arriving at their destination on time. The at-risk behavior is best managed by coaching employees in a positive, supportive manner to recognize the risks associated with the behavioral choices and also improving the system to remove incentives that drive the at-risk behavior. Finally, a just culture recognizes that occasionally an employee will act recklessly. Reckless behavior is defined as a conscious disregard of a substantial and unjustifiable risk. A just culture believes that disciplinary action is only appropriate in the rare case of a reckless choice in order to discourage the individual reckless choice. M&E, through the Just Policy, will begin to identify and clearly communicate where the “line is drawn” between at-risk behavior and the reckless act. These just culture principles have been used in the M&E ASAP program for two years now with great success.
In order to fairly and consistently assess the quality of the choices made by the employees and identify system deficiencies, M&E has assigned this responsibility to the Director of Maintenance Compliance team who are now trained and qualified to apply the MEAA and just culture tools (the Just Culture AlgorithmTM) per the Just Policy.
How does the Just Policy relate to other policies such as M&E ASAP, the Maintenance Event Assessment Aid (MEAA), Peak Performance through Commitment (PPC) or time and attendance?
Beginning on June 15, the Just Policy for Maintenance Errors and Violations will become effective. It applies to any maintenance-related error or violation by any member of the M&E organization. The Just Policy applies only to “maintenance-related errors or violations”. It does not apply to violations of AA Rules of Conduct, attendance policy, etc.
The Just Policy not only provides a clear direction on how the organization will manage maintenance-related risks and accountability, but it also better aligns managements’ fact-gathering investigation (the Preliminary Investigation) with the MEAA and ASAP processes. The Just Policy will define when one investigation ends and the other begins – as well as ensures all involved are working with the same tools, definitions and principles.
The actions taken with an employee under the guidance of the Just Policy do not conflict with the Peak Performance through Commitment (PPC) policy; instead the Just Policy provides standardization and consistent application of PPC by limiting PPC action to only the reckless act.

What does the Just Policy mean for M&E personnel, such as the AMT?
For the AMT, or any M&E personnel involved in the maintenance-related error or violation, the Just Policy will ensure that you are treated in a fair and “just” manner. The Just Policy will require a thorough, non-punitive root cause investigation (MEAA) and the Just Culture AlgorithmTM to standardize the action taken with the employee involved and the system. Both tools are designed to provide consistency, fairness, balanced focus of accountability and apply equally regardless of how severe the outcome of the error or violation was. The Just Policy will require that both of these tools are applied by the neutral, un-biased team of just culture qualified Compliance Managers within the Director of Maintenance organization or by the M&E ASAP Event Review Committee for reports filed through ASAP. Ultimately, the employee will be able to trust that they can speak honestly and openly about the factors that led up to an error or event knowing that the organization is more interested in learning as much as possible and preventing reoccurrences than they are with punishing an employee or building a case for discipline. The employee will be able to see that managing within the Just Policy will bring fairness, balanced accountability and improvements to the systems we work within – making it a better environment to work within and easier to produce the desired results.
Where can I find out more about the Just Policy?
M&E has developed a website on me.aa.com where employees can review the Just Policy and supporting documents. The website address is https://twu514.org/files/2024/01/4-AA-Just-Policy.pdf.