tag:blogger.com,1999:blog-4170623839736191950.post5402357949426946790..comments2022-12-03T19:22:46.911-08:00Comments on Safetymatters: Safety culture information, analysis and management: IAEA on Instituting Regulation of Licensee Safety CultureBob Cudlinhttp://www.blogger.com/profile/08502712287881656493noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-4170623839736191950.post-75816819137855363982013-05-16T13:48:11.118-07:002013-05-16T13:48:11.118-07:00As noted in the second footnote an assertion is ma...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." <br /><br />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."<br /><br />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.<br /><br />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!Bill Mullinsnoreply@blogger.com