Saturday, February 12, 2011

“what people do, not why they do it…”

Our perseverance through over three hours of the web video of the Commission meeting on the proposed safety culture policy statement was finally rewarded in the very last minute of discussion.  Commissioner Apostolakis reiterated some of his concerns with the direction of the policy statement, observing that the NRC is a performance-based agency and:

“...we really care about what people do and maybe not why they do it….”

Commissioner Apostolakis was amplifying his discomfort with the inclusion of values along with behaviors in the policy as values are inherently fuzzy, not measurable, and may or may not be a prerequisite to the right behaviors.  Perhaps most of all, he believed omitting the reference to core values would not detract from the definition of safety culture. 

Earlier in the meeting Commissioner Apostolakis had tried to draw out the staff on whether the definition of safety culture needed values in addition to behaviors [at time 2:34:58], and would it be a fatal flaw to omit “core values”.  The staff response was illuminating.  The justification offered for retaining values was “stakeholder consensus”, and extensive outreach efforts that supported inclusion.  (But why was it so important to stakeholders?)  The staff went on to clarify: “culture does not lend itself to be inspectable”, but “having values with behaviors is what culture is all about”.   Frankly we’re not sure what that means, but we do know that safety culture behaviors are inspectable because they are observable and measurable.

That much of the staff’s justification for including values in the policy statement seemed to reside in the fact that all the stakeholders had agreed received positive endorsement by Chairman Jaczko when he observed:  “...Commissioner Magwood I think made a profound point that there was value in this process here that may be tremendously more important than the actual policy statement was the fact that people got together and started talking about this and realized that across this wide variety of stakeholders, there was pretty good agreement about the kinds of things that we were talking about.”

Chairman Jaczko also weighed in on the values-behaviors contrast, coming down firmly on the inclusion of values and offering the following justification:

“...not all entities with a good safety culture will have necessarily the right values…”

Respectfully, we believe at a minimum this will further confuse the NRC’s policy on safety culture, and in all likelihood places emphasis in exactly the wrong place.  Is the Chairman agreeing all that matters is what people do?  Or is he suggesting that the NRC would find fault with a licensee that was acting consistent with safety but did not manifest the “right” values.  And how would the NRC reach such a finding?  More fundamentally, isn’t Commissioner Apostolakis correct in his blunt statement - that we [NRC] don’t care why they [licensees] do it?

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