Thursday, May 17, 2012

NEI Safety Culture Initiative: A Good Start but Incomplete

The March 2012 NRC Regulatory Information Conference included a session on the NRC’s Safety Culture Policy Statement.  NRC personnel made most of the session presentations but there was one industry report on the NEI’s safety culture initiative.  The NEI presentation* included the figure shown below which we’ll assume represents industry’s current schematic for how a site’s safety culture should be assessed and maintained. 



The good news here is the central role of the site’s corrective action program (CAP).  The CAP is where identified issues get evaluated, prioritized and assigned; it is a major source for changes to the physical plant and plant procedures.  A strong safety culture is reflected in an efficient, effective CAP and vice versa.

Another positive aspect is the highlighted role of site management in responding to safety culture issues by implementing appropriate changes in site policies, programs, training, etc.

We also approve of presentation text that outlined industry’s objective to have “A repeatable, holistic approach for assessing safety culture on a continuing basis” and to use “Frequent evaluations [to] promote sensitivity to faint signals.”  

Opportunities for Improvement

There are some other factors, not shown in the figure or the text, that are also essential for establishing and maintaining a strong safety culture.  One of these is the site’s decision making process, or processes.  Is decision making consistently conservative, transparent, robust and fair?  How is goal conflict handled?  How about differences of opinion?  Are sensors in place to detect risk perception creep or normalization of deviance? 

Management commitment to safety is another factor.  Does management exercise leadership to reinforce safety culture and is management trusted by the organization?

A third set of factors establishes the context for decision making and culture.  What are corporate’s priorities?  What resources are available to the site?  Absent sufficient resources, the CAP and other mechanisms will assign work that can’t be accomplished, backlogs will grow and the organization will begin to wonder just how important safety is.  Finally, what are management’s performance objectives and incentive plan?

One may argue that the above “opportunities” are beyond the scope of the industry safety culture objective.  Well, yes and no.  While they may be beyond the scope of the specific presentation, we believe that nuclear safety culture can only be understood and  possibly influenced by accepting a complete, dynamic model of ALL the factors that affect, and are affected by, safety culture.  Lack of a system view is like trying to drive a car with some of the controls missing—it will eventually run off the road. 


*  J.E. Slider, Nuclear Energy Institute, “Status of the Industry’s Nuclear Safety Culture Initiative,” presented at the NRC Regulatory Information Conference (March 15, 2012).

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