Monday, May 3, 2010

Testing Positive - the NRC on Safety Culture

We have been spending some time with the NRC’s draft statement of policy on safety culture published in the Federal Register on November 6, 2009.*

The initial Commission policy statement on safety culture in 1989 simply referred to “safety culture”. The current statement initially refers to the need for a “strong” safety culture (“It is the Commission’s policy that a strong safety culture is an essential element for individuals . . . .”) but then settles on “positive” safety culture as the fundamental expectation of the policy (“licensees . . . should foster a positive safety culture in their organizations and among individuals . . . .”) (p. 57526) The NRC provides its definition of “safety culture” in the draft policy but does not specifically define “strong” or “positive” safety culture. The NRC states that “certain organizational characteristics and personnel attitudes and behaviors are present in a positive safety culture.” (p. 57528) It also notes that “The INSAG definition emphasizes that in a positive safety culture, the goal of maintaining nuclear safety receives the highest priority in the organization’s and individuals’ decision-making and actions when faced with a conflict with other organizational or individual goals.” (p. 57527)

We found the use of the term “positive” potentially ambiguous and decided to explore its possible meaning(s) as applicable to safety culture and what might be the NRC’s intent in using it to describe safety culture.

First of all we note the use of “positive” in this context is as an adjective. Complicating matters a bit from the start is that there are eight definitions of the adjective, positive. A few are readily dismissed such as where positive refers to the charge of electricity associated with a proton or having higher electric potential. But many remain. The definitions of positive that could be applicable to nuclear safety culture include:

  • prescribed, or formally laid down and imposed;
  • unconditioned or independent of changing circumstances;
  • real, not fictitious and being effective in a social circumstance;
  • contributing toward or characterized by increase or progression;
  • favorable, having a good effect.

Consulting with Black’s Law Dictionary, the term positive is defined as:

“Laid down, enacted, or prescribed. Direct, absolute, explicit.” Sounds close to the first definition above.So what did the NRC intend by the usage of positive to modify “safety culture”? The short answer is we don’t know. The various definitions imply several possible interpretations. Perhaps the more straightforward is the “prescribed” definition. It would require licensees have an explicit and prescribed policy for safety culture at its facilities, and the policy would need to address elements of safety culture as laid out in the policy statement. This interpretation might also imply that the safety culture is unconditioned and independent of changing circumstances; i.e., enduring. The other possibility is that the NRC intends the “favorable” and “increasing and progressing” safety culture. This meaning has more of a dynamic implication and is similar to continuous improvement. The NRC’s alternate use of the term “strong” in the introduction to the policy doesn’t help much either. Strong can mean the “power to resist or endure” so it could be consistent with the first definition that safety culture should be enduring. But it also implies “resistant to change” which could be good or bad, depending on the current state of safety culture and any need to change (improve) it.

Where does this leave us? As a minimum it would appear necessary that the NRC amplify its use of these modifiers of safety culture and the specific meanings that are intended. Better yet, the NRC could not use these terms and simply rely on an old regulatory standby such as “adequate” safety culture.

* Draft Safety Culture Policy Statement: Request for Public Comments NRC-2009-0485-0001

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