Appendix 1 to GM 13 Just Culture - ANSP level - possible justifications

Sep 4, 2026

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Appendix 1 to GM 13 sets out a structured set of assessment questions for verifying a Just Culture framework at ANSP level, with corresponding possible justifications. It covers policy publication and content defining unacceptable behaviour, protection of reporters from disciplinary action for self-reported occurrences, and support mechanisms such as legal assistance. The appendix also specifies arrangements for Critical Incident Stress Management, safety actions after occurrences, and governance measures for independent safety investigation, access to data, confidentiality, and required training and qualifications.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages5

Reading Time13 min

AccessFree to download

Policy and its implementation

ANSP.P.1 Policy elements related questions

ANSP.P.2 Policy elements related questions

ANSP.P.3 Policy elements related questions

ANSP.P.4 Policy elements related questions

ANSP.P.5 Policy elements related questions

Policy elements related to staff safety actions and investigation governance

ANSP.P.6 Policy elements related questions

ANSP.P.7 Roles and Responsibilities clearly defined and implemented

ANSP.P.8 Roles and Responsibilities clearly defined and implemented

ANSP.P.9 Roles and Responsibilities clearly defined and implemented

ANSP.P.10 Roles and Responsibilities clearly defined and implemented

ANSP.P.11 Training

ANSP.P.12 Training

ANSP.P.13 Training

Legal/Judiciary

Appendix 1 to GM 13 Just Culture-ANSP level-possible justification Appendix 1 to GM 13 – Just Culture – ANSP level-possible justifications | ID | Area | Question | Possible justifications | | --- | --- | --- | --- | | Policy and its implementation | | | | | ANSP.P.1 | Policy elements related questions | Is there an explicit Just Culture policy, which is formally endorsed by management and staff representatives and made public? | Written and published policy signed by management and staff representatives. | | ANSP.P.2 | Policy elements related questions | Does the Just Culture policy contain a description of what is considered to be unacceptable behaviour? | In accordance with the definition in Article 2,(k) of Commission Regulation (EU) No 691/2010 “unacceptable behaviour” should be considered as gross negligence, wilful violations and destructive acts. Besides this definition, it is realised that it is difficult to implement a hard line between acceptable and unacceptable behaviour. Therefore, there is a link between this question and question ANSP.O.8 .
Possible evidences: written statement in policy. | | ANSP.P.3 | Policy elements related questions | Does the Just Culture policy guarantee that no disciplinary action will be taken regarding the reporter by the service provider for self-reported occurrences (except for the cases defined above in question ANSP. P.2)? | Written statement in policy. | | ANSP.P.4 | Policy elements related questions | Does the ANSP provide legal support for its own staff in case of prosecution / legal action related to a safety occurrence? | Communications to staff advising that legal support is available and indicating the procedure how to access such support. | | ANSP.P.5 | Policy elements related questions | Is there an established and well known Critical Incident Stress Management programme? | Critical Incident Stress Management (CISM) is the structured assistance for a normal reaction to an abnormal event. A CISM programme can help the controllers see that incidents are“normal”, that they can help the organisation improve and that they can happen to everybody. Use of CISM is considered asan indication that the organisation is not intending to “punish”staff but to provide support to those involved in occurrencesand thus is aiming to implement a “just culture”. More information can for example be found in the “Critical incident Stress Management: User Implementation Guide” published by EUROCONTROL in 2008 ([Ref. nr. 08/11/03-27](Ref. nr. 08/11/03-27)).
Possible justifications: details of a CISM programme, communications to staff advising that CISM is available and indicating procedure how to access such support, procedures indicating when CISM is provided. | Appendix 1 to GM 13 Just Culture-ANSP level-possible justification | ID | Area | Question | Possible justifications | | --- | --- | --- | --- | | ANSP.P.6 | Policy elements related questions | Are safety actions taken in respect to staff after an occurrence without impact on pay of the staff member concerned until the end of the investigation? | No financial penalties on pay until the occurrence investigation has been completed.
In some cases the persons involved in an incident could need some additional training which could have an impact on hours and wages. Such a “training” would be the result of the investigation and would not be required or mandated before the investigation is completed. Typically, the investigation should be considered completed once the report has been finalized. It may, as a side effect, encourage those carrying out the investigation to complete the report in a timely fashion. Possible justifications: an overview of safety actions taken after an occurrence and their implications to the pay of the persons involved in the occurrence. | | ANSP.P.7 | Roles and Responsibilities clearly defined and implemented | Are the service provider’s safety investigators completely independent and separate from a

FAQs

What must be verified about the Just Culture policy at ANSP level?

The policy should be explicitly endorsed by management and staff representatives and formally published. It must also describe what constitutes unacceptable behaviour and align with the defined scope in the referenced regulation.

How does the appendix address protection for reporters who self-report occurrences?

It requires a written policy statement ensuring no disciplinary action is taken regarding the reporter for self-reported occurrences, except for cases defined elsewhere in the policy framework.

What governance and support measures are required for safety investigations and safety data access?

Safety investigators must be independent from line and operations management, have unimpeded access to all relevant data, and operate under rules that define access and ensure confidentiality. The appendix also requires that CISM staff are nominated and adequately trained.

Sep 4, 2026

Uploaded by Pentious