Wednesday, May 15, 2013

IAEA on Instituting Regulation of Licensee Safety Culture

The International Atomic Energy Agency (IAEA) has published a how-to report* for regulators who want to regulate their licensees' safety culture (SC).  This publication follows a series of meetings and workshops, some of which we have discussed (here and here).  The report is related to IAEA projects conducted “under the scope of the Regional Excellence Programme on Safe Nuclear Energy–Norwegian Cooperation Programme with Bulgaria and Romania. These projects have been implemented at the Bulgarian and Romanian regulatory bodies” (p. 1)

The report covers SC fundamentals, regulatory oversight features, SC assessment approaches, data collection and analysis.  We'll review the contents, highlighting IAEA's important points, then provide our perspective.

SC fundamentals

The report begins with the fundamentals of SC, starting with Schein's definition of SC and his tri-level model of artifacts, espoused values and basic assumptions.  Detail is added with a SC framework based on IAEA's five SC characteristics:

  • Safety is a clearly recognized value
  • Leadership for safety is clear
  • Accountability for safety is clear
  • Safety is integrated into all activities
  • Safety is learning driven.
The SC characteristics can be described using specific attributes.

Features of regulatory oversight of SC 


This covers what the regulator should be trying to achieve.  It's the most important part of the report so we excerpt the IAEA's words.

“The objective of the regulatory oversight of safety culture, focused on a dynamic process, is to consider and address latent conditions that could lead to potential safety performance degradation at the licensees’ nuclear installations. . . . Regulatory oversight of safety culture complements compliance-based control [which is limited to looking at artifacts] with proactive control activities. . . . ” (p. 6, emphasis added)

“[R]egulatory oversight of safety culture is based on three pillars:

Common understanding of safety culture. The nature of safety culture is distinct from, and needs to be dealt with in a different manner than a compliance-based control. . . .

Dialogue. . . . dialogue is necessary to share information, ideas and knowledge that is often qualitative. . . .

Continuousness. Safety culture improvement needs continuous engagement of the licensee. Regulatory oversight of safety culture therefore ideally relies on a process during which the regulator continuously influences the engagement of the licensee.” (p. 7)

“With regards to safety culture, the regulatory body should develop general requirements and enforce them in order to ensure the authorized parties have properly considered these requirements. On the other hand, the regulatory body should avoid prescribing detailed level requirements.” (p. 8)  The licensee always has the primary responsibility for safety.

Approaches for assessing SC

Various assessment approaches are currently being used or reviewed by regulatory bodies around the world. These approaches include: self-assessments, independent assessments, interaction with the licensee at a senior level, focused safety culture on-site reviews, oversight of management systems and integration into regulatory activities.  Most of these activities are familiar to our readers but a couple merit further definition.  The “management system” is the practices, procedures and people.**  “Integration into regulatory activities” means SC-related information is also collected during other regulatory actions, e.g., routine or special inspections.

The report includes a table (recreated below) summarizing, for each assessment approach, the accuracy of results and resources required.  Accuracy is judged as realistic, medium or limited and resource requirements as high, medium and low.  The table thus shows the relative strengths and weaknesses of each approach.





Criteria

Approaches Accuracy of SC picture Effort Management involvement Human and Organizational Factors & SC skills





Self-assessment Medium Low (depending on Low Medium
Review
who initiates the
(to understand
(high experience and
self-assessment,
deliverables)
skills of the
regulator or

reviewers are
licensee)

assumed)








Independent Medium Low Low Medium
assessment Review


(to understand
(high experience and


deliverables)
skills of the



reviewers are



assumed)








Interaction with the Limited (however Medium High Medium
Licensee at Senior can support a


Level shared



understanding)







Focused Safety Realistic (gives High Medium High
Culture On-Site depth in a moment


Review of time)







Oversight of Medium (Reduced Low Low Medium
Management System if only formal


Implementation aspects are



considered)







Integration into Medium (when Medium (after an Medium (with an Medium (specific
Regulatory properly trended intensive initial intensive initial training
Activities and analyzed) introduction) support) requirement and




experience sharing)




Data collection, analysis and presenting findings to the licensee

The report encourages regulators to use multiple assessment approaches and multiple data collection methods and data sources.  Data collection methods include observations; interviews; reviews of events, licensee documents and regulator documents; discussions with management; and other sources such as questionnaires, surveys, third-party documents and focus groups.  The goal is to approach the target from multiple angles.  “The aim of data analysis is to build a safety culture picture based on the inputs collected. . . . It is a set of interpreted data regarding the organizational practices and the priority of safety within these practices. (p. 17)

Robust data analysis “requires iterations [and] multi-disciplinary teams. A variety of expertise (technical, human and organizational factors, regulations) are necessary to build a reliable safety culture picture. . . . [and] protect against bias inherent to the multiple sources of data.” (p. 17)

The regulator's picture of SC is discussed with the licensee during periodic or ad hoc meetings.  The objective is to reach agreement on next steps, including the implementation of possible meeting actions and licensee commitments.

Our perspective

The SC content is pretty basic stuff, with zero new insight.  From our viewpoint, the far more interesting issue is the extension of regulatory authority into an admittedly soft, qualitative area.  This issue highlights the fact that the scope of regulatory authority is established by decisions that have socio-political, as well as technical, components.  SC is important, and certainly regulatable.  If a country wants to regulate nuclear SC, then have at it, but there is no hard science that says it is a necessary or even desirable thing to do.

Our big gripe is with the hypocrisy displayed by the NRC which has a SC policy, not a regulation, but in some cases implements all the steps associated with regulatory oversight discussed in this IAEA report (except evaluation of management personnel).  For evidence, look at how they have been pulling Fort Calhoun and Palisades through the wringer.


*  G. Rolina (IAEA), “Regulatory oversight of safety culture in nuclear installations” (Vienna: International Atomic Energy Agency, 2013).

**  A management system is a “set of interrelated or interacting elements (system) for establishing policies and objectives and enabling the objectives to be achieved in an efficient and effective way. . . . These elements include the structure, resources and processes. Personnel, equipment and organizational culture as well as the documented policies and processes are parts of the management system.” (p. 30)

1 comment:

  1. As noted in the second footnote an assertion is made: "organizational culture as well as the documented policies and processes are parts of the management system."

    As is customary in discussions of "nuclear safety culture" an enterprise (the legal and corporate entity that actually holds the license and title to the plant's capital) is postulated to exist apart from its "(safety) management system;" the latter is at once presumed to contain as a "part" the "organizational culture."

    There is something inherently circular in this construct - a convenient circularity as it enables the regulatory authorities to render all aspects of enterprise sense and decision-making subject to its own prime imperative: Do Safety First.

    Once that fundamental non-sequitur is poured as a foundation, the are few illogical conclusions about the mechanization of the "socio" aspects of enterprise operation that are indefensible. What goes unnoticed is the manner in which such studied irrationality leads inexorably to the infinite regress found in NRC's Strategic, and unbounded, Duty of Prevention. So much for the licensee holding the primary responsibility for safety!

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