Monday, December 5, 2011

Regulatory Assessment of Safety Culture—Not Made in U.S.A.

Last February, the International Atomic Energy (IAEA) hosted a four-day meeting of regulators and licensees on safety culture.*  “The general objective of the meeting [was] to establish a common opinion on how regulatory oversight of safety culture can be developed to foster safety culture.”  In fewer words, how can the regulator oversee and assess safety culture?

While no groundbreaking new methods for evaluating a nuclear organization’s safety culture were presented, the mere fact there is a perception that oversight methods need to be developed is encouraging.  In addition, outside the U.S., it appears more likely that regulators are expected to engage in safety culture oversight if not formal regulation.

Representatives from several countries made presentations.  The NRC presentation discussed the then-current status of the effort that led to the NRC safety culture policy statement announced in June.  The presentations covering Belgium, Bulgaria, Indonesia, Romania, Switzerland and Ukraine described different efforts to include safety culture assessment into licensee evaluations.

Perhaps the most interesting material was a report on an attendee survey** administered at the start of the meeting.  The survey covered “national regulatory approaches used in the oversight of safety culture.” (p.3) 18 member states completed the survey.  Following are a few key findings:

The states were split about 50-50 between having and not having regulatory requirements related to safety culture. (p. 7)  The IAEA is encouraging regulators to get more involved in evaluating safety culture and some countries are responding to that push.

To minimize subjectivity in safety culture oversight, regulators try to use oversight practices that are transparent,  understandable, objective, predictable, and both risk-informed and performance-based. (p. 13)  This is not news but it is a good thing; it means regulators are trying to use the same standards for evaluating safety culture as they use for other licensee activities.

Licensee decision-making processes are assessed using observations of work groups, probabilistic risk analysis, and during the technical inspection. (p. 15)  This seems incomplete or even weak to us.  In-depth analysis of critical decisions is necessary to reveal the underlying assumptions (the hidden, true culture) that shape decision-making.

Challenges include the difficulty in giving an appropriate priority to safety in certain real-time decision making situations and the work pressure in achieving production targets/ keeping to the schedule of outages. (p. 16)  We have been pounding the drum about goal conflict for a long time and this survey finding simply confirms that the issue still exists.

Bottom Line

The meeting was generally consistent with our views.  Regulators and licensees need to focus on cultural artifacts, especially decisions and decision making, in the short run while trying to influence the underlying assumptions in the long run to reduce or eliminate the potential for unexpected negative outcomes.

**  A. Kerhoas, "Synthesis of Questionnaire Survey."

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