The intent of the NRC's Safety Culture Common Language Path Forward initiative is to describe safety culture (SC) attributes at a more detailed level than the NRC’s SC policy statement. On January 29-30, 2013 the NRC held a public workshop to finalize the draft SC common language.* The document they issued after the workshop** contains attribute definitions and examples of behavior and artifacts that support or embody each attribute. This document will be used by the NRC to develop a NUREG containing the final common language.
Last March we posted on a draft produced by previous workshops, focusing on areas we consider critical for a strong SC: decision making, corrective action, management incentives and work backlogs. In that post, our opinion was that decision making and corrective action were addressed in a satisfactory manner, the treatment of incentives was minimally acceptable and backlogs were all but ignored.
So, how does the “final” language treat the same subject areas? Is it better than the draft comments we reviewed last March? The arrows indicate whether the final version is better ↑, the same → or worse ↓.
Decision making – Good↑. Decision making incorporates “. . . a consistent, systematic approach to make decisions” (p. 51) and a conservative bias, i.e., “. . . decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop.” (p. 52) In addition, communicating, explaining and justifying individual decisions is mentioned throughout the document.
Goal conflict is addressed under leader behavior “. . . when resolving apparent conflicts between nuclear safety and production” (p. 12) and leaders “avoid unintended or conflicting messages that may be conveyed by operational decisions” (p. 37); work process “activities are coordinated to address conflicting or changing priorities.” (p. 23)
Corrective action – Satisfactory→. The section on problem identification and resolution (pp. 13-17) is suffused with desirable characteristics of corrective actions and the CAP. A good CAP has a low threshold for identifying issues and problems are thoroughly evaluated. Corrective actions are timely, effective and prevent recurrence of problems. Periodic analysis of CAP and other data is used to identify any programmatic or common cause issues.
Management incentives – Unsatisfactory↓. The section on incentives appears to focus on workers, not managers: “Leaders ensure incentives, sanctions, and rewards are aligned with nuclear safety policies and reinforce behaviors and outcomes which reflect safety as the overriding priority.” (p. 7) This is even less complete than the single sentence that appeared in last year's draft: “Senior management incentive program [sic] reflect a bias toward long-term plant performance and safety.”*** The failure to mention the senior management incentive program is a serious shortcoming.
Backlogs – Minimally Acceptable↑. Backlogs are specifically mentioned in maintenance and engineering (p. 24) and document changes (p. 25). In addition, problem evaluation, corrective actions, CAP trending analyses, operating experience lessons and many administrative activities are supposed to be addressed in a “timely” manner. I hope that implies that backlogs in these areas should not be too large.
But attention to backlogs is still important. Repeating what we said last year, “Excessive backlogs are demoralizing; they tell the workforce that accomplishing work to keep the plant, its procedures and its support processes in good repair or up-to-date is not important. Every “problem plant” we worked on in the late 1990s had backlog issues.”
Overall, this latest document is an improvement over the March 2012 version but still short of what we'd like to see.
* M.J. Keefe (NRC) to U.S. Shoop (NRC), “Summary of the January 29-30, Workshop to Develop Common Language for Safety Culture” (Feb. 7, 2013) ADAMS ML13038A059.
** Nuclear Safety Culture Common Language 4th Public Workshop January 29-31, 2013 ADAMS ML13031A343.
*** U.S. Shoop (NRC) to J. Giitter (NRC), “Safety Culture Common Language Path Forward” (Mar. 19, 2012) p. 12. ADAMS ML12072A415.