Part 17 – Safety Culture, Discipline and Corrective Action

This Part establishes SAHPA’s approach to safety culture, discipline, and corrective action within the recreational hang gliding and paragliding community.

The objective of this Part is to promote aviation safety through learning, accountability, and proportionate response to unsafe conduct, while ensuring that decisions affecting members’ rights, privileges, or standing are lawful, reasonable, and procedurally fair.

This Part applies to all SAHPA members and, where relevant to public safety or regulatory compliance, to non-members interacting with SAHPA-regulated activities.

This Part operates subject to the governance and duty of care framework set out in Part 1 of this Operations Manual.

Guidance

Safety Culture and Just Culture Principles

SAHPA recognises that aviation safety is best achieved through a strong safety culture that encourages reporting, learning, and continuous improvement.

SAHPA adopts a Just Culture approach, which recognises that:

  • human error is an inevitable part of aviation activity;
  • learning from incidents and hazards is essential to improving safety outcomes; and
  • not all unsafe acts warrant disciplinary action.

A Just Culture does not excuse reckless, intentional, or unlawful conduct. Rather, it distinguishes between:

  • honest mistakes or system-induced errors;
  • at-risk behaviour arising from lack of awareness or poor judgement; and
  • reckless or deliberate disregard for safety or legal requirements.

Relationship Between Safety, Discipline and Learning

SAHPA’s safety management, disciplinary, and corrective action functions are complementary and interdependent.

Safety reporting and investigation are primarily learning-oriented. Disciplinary action is reserved for circumstances where conduct demonstrates recklessness, repeated non-compliance, wilful disregard of rules, or behaviour incompatible with aviation safety or public trust.

Corrective action may include education, restrictions, supervision, or other non-punitive measures designed to restore safe conduct and reduce future risk.

Administrative Justice and Fairness

Where SAHPA takes decisions that materially and adversely affect a member’s rights, privileges, or legitimate expectations, such decisions constitute administrative action for the purposes of the Promotion of Administrative Justice Act.

Accordingly, SAHPA recognises that such decisions must be:

  • reasonable, proportionate to the conduct and risk involved; and
  • procedurally fair.

This includes, where applicable, providing affected persons with notice of the allegations, an opportunity to respond, and clear communication of decisions and reasons.

Complaints, Allegations, and Evidence

SAHPA may receive complaints, allegations, or reports relating to safety, conduct, or compliance from members, officials, landowners, members of the public, or statutory bodies, and shall assess such matters within its governance scope in accordance with the principles of Just Culture, lawfulness, reasonableness, and procedural fairness. In considering complaints, SAHPA may rely on any relevant information, including written statements, electronic communications, recordings, site reports, or expert input, and shall determine the relevance and weight of such information having regard to credibility, corroboration, context, and proportionality. SAHPA is not obliged to disclose all information or sources relied upon where disclosure would reasonably prejudice safety, confidentiality, privacy, or the lawful conduct of governance processes, and may, following assessment, take no action, implement corrective or preventative measures, initiate disciplinary processes, impose interim safety restrictions, or refer matters to statutory authorities as appropriate.

Corrective Action

Corrective action is intended to address unsafe behaviour, competency gaps, or systemic issues before they escalate into incidents, accidents, or enforcement action.

Corrective action may be appropriate where:

  • conduct falls below expected safety standards but does not amount to recklessness;
  • a pattern of minor non-compliance emerges;
  • remedial intervention is likely to reduce future risk.

Corrective action is distinct from punishment and is intended to support continued safe participation in the sport.

Escalation Beyond Internal Discipline

Where safety-related conduct raises public interest concerns or may involve unlawful aviation activities, escalation, reporting, and public risk mitigation shall be addressed in accordance with Part 18 (Discipline, Reporting, and Public Interest Protection).

Peer Support

SAHPA recognises that incidents, accidents, near-misses, or other distressing events may have psychological or emotional impacts on pilots, instructors, officials, volunteers, and affected family members. Peer Support is a voluntary, confidential, and non-judgemental form of informal support provided by trained peers to promote wellbeing and resilience within the aviation community. Peer Support is not a medical, therapeutic, investigative, operational, search and rescue, or enforcement function, does not replace professional care or formal processes, and does not imply fault or wrongdoing. Engagement with Peer Support is entirely voluntary and operates independently of accident investigation, disciplinary processes, and regulatory oversight, subject only to limitations required by law or where necessary to prevent serious harm.

Safety Officers

SAHPA recognises that effective safety culture requires visible, experienced individuals empowered to identify hazards, intervene where necessary, and support pilots in maintaining safe operations. Safety Officers supplement, but do not replace, the safety responsibilities of instructors, site custodians, or committee members. Safety Officers provide support and intervention at an operational level and do not constitute a disciplinary or investigative function.


Rules relating to Safety Culture, Discipline and Corrective Action

17.1 Promotion of Safety Culture

17.1.1 SAHPA shall promote a safety culture that encourages the reporting of hazards, incidents, and unsafe conditions without fear of inappropriate punitive action.

17.2 Protection of Good-Faith Reporting

17.2.1 No member shall be subjected to disciplinary action solely for the good-faith reporting of hazards, incidents, or safety concerns, unless the report discloses reckless, intentional, or unlawful conduct.

17.3 Threshold for Disciplinary Action

17.3.1 SAHPA may institute disciplinary action where conduct demonstrates recklessness, wilful non-compliance, repeated unsafe behaviour, or conduct incompatible with aviation safety or the reputation of SAHPA.

17.4 Corrective Action as a Primary Response

17.4.1 Where appropriate, SAHPA shall prefer corrective and remedial measures over punitive action in order to restore safe conduct and reduce future risk.

17.5 Lawfulness and Authority

17.5.1 All disciplinary and corrective actions shall be exercised within the authority delegated to SAHPA and its structures, and in accordance with applicable law.

17.6 Procedural Fairness

17.6.1 Any disciplinary or corrective action that materially and adversely affects a member’s rights or privileges shall be conducted in a procedurally fair manner, consistent with the Promotion of Administrative Justice Act.

17.7 Proportionality and Reasonableness

17.7.1 Sanctions and corrective measures shall be proportionate to the nature of the conduct, the level of risk posed, and any mitigating or aggravating factors.

17.8 Reasons for Decisions

17.8.1 Where disciplinary or corrective action is imposed, SAHPA shall provide the affected member with clear reasons for the decision, consistent with principles of administrative justice.

17.9 Separation from Enforcement

17.9.1 Disciplinary and corrective actions under this Part shall not preclude reporting to, or action by, statutory enforcement authorities where required by law or public safety considerations.

17.10 Safety Officers

17.10.1 SAHPA may designate qualified individuals as Safety Officers for the purposes of supporting safety oversight, hazard identification, and safety culture.

17.10.2 A Safety Officer may be an instructor or a suitably experienced senior pilot who has been formally appointed in accordance with the SAHPA Manual of Procedures.

17.10.3 A Safety Officer shall have the authority to:

  • identify and raise safety concerns;
  • advise pilots, instructors, and officials on safety-related matters;
  • recommend the suspension or cessation of unsafe activities, subject to applicable rules.

17.10.4 The authority conferred by this section does not limit the right or responsibility of any member to raise safety concerns, decline to participate in unsafe activities, or draw attention to hazards in accordance with this Operations Manual.

17.10.5 A Safety Officer shall not exercise disciplinary authority unless separately authorised under this Operations Manual.

17.10.6 A Safety Officer shall act impartially, proportionately, and in accordance with SAHPA’s just culture principles.

17.10.6 Interference with, obstruction of, or retaliation against a Safety Officer acting in good faith constitutes a safety governance matter.

17.11 Complaints and Evidence

17.1.1 SAHPA may receive complaints, allegations, or reports relating to safety, conduct, or compliance from any person or entity.

17.11.2 SAHPA shall conduct an initial assessment of complaints to determine whether the matter falls within its governance scope, whether further consideration or internal action is warranted, and whether the matter should be referred or escalated to the South African Civil Aviation Authority, its Enforcement division, or another competent authority.

17.11.3 SAHPA shall assess complaints and supporting information in a manner consistent with the principles of administrative fairness, proportionality, and Just Culture.

17.11.4 SAHPA may consider any relevant information when making governance, safety, or disciplinary determinations, including but not limited to written statements, electronic communications, photographs, recordings, site reports, and expert or official input.

17.11.5 SAHPA shall determine the relevance and weight to be given to information received, having regard to credibility, corroboration, context, and reliability.

17.11.6 SAHPA is not obliged to disclose all information, evidence, or sources relied upon where disclosure would reasonably prejudice safety, privacy, confidentiality, the protection of informants, or the lawful conduct of governance or disciplinary processes.

17.11.7 Following assessment of a complaint, SAHPA may take no action, implement corrective or preventative measures, initiate disciplinary processes under Part 2, impose interim safety measures, or refer the matter to statutory authorities in accordance with Part 18.