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.
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.
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.
|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|
|assessment Review||(to understand|
|(high experience and||deliverables)|
|skills of the|
|Interaction with the||Limited (however||Medium||High||Medium|
|Licensee at Senior||can support a|
|Focused Safety||Realistic (gives||High||Medium||High|
|Culture On-Site||depth in a moment|
|Oversight of||Medium (Reduced||Low||Low||Medium|
|Management System||if only formal|
|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|
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.
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” IAEA TECDOC 1707 (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)