Wednesday, February 10, 2016

NEA’s Safety Culture Guidance for Nuclear Regulators

A recent Nuclear Energy Agency (NEA) publication* describes desirable safety culture (SC) characteristics for a nuclear regulator.  Its purpose is to provide a benchmark for both established and nascent regulatory bodies.

The document’s goal is to describe a “healthy” SC.  It starts with the SC definition in INSAG-4** then posits five principles for an effective nuclear regulator: Safety leadership is demonstrated at all levels; regulatory staff set the standard for safety; and the regulatory body facilitates co-operation and open communication, implements a holistic approach to safety, and encourages continuous improvement, learning and self-assessment.

The principle that caught our attention is the holistic (or systemic) approach to safety.  This approach is discussed multiple times in the document.  In the Introduction, the authors say the regulator
should actively scrutinise how its own safety culture impacts the licensees’ safety culture.  It should also reflect on its role within the wider system and on how its own culture is the result of its interactions with the licensees and all other stakeholders.” (p. 12)

A subsequent chapter contains a more expansive discussion of each principle and identifies relevant attributes.  The following excerpts illustrate the value of a holistic approach.  “A healthy safety culture is dependent on the regulatory body using a robust, holistic, multi-disciplinary approach to safety.  Regulators oversee and regulate complex socio-technical systems that, together with the regulatory body itself, form part of a larger system made up of many stakeholders, with competing as well as common interests.  All the participants in this system influence and react to each other, and there is a need for awareness and understanding of this mutual influence.” (p. 19)

“[T]he larger socio-technical system [is] influenced by technical, human and organisational, environmental, economic, political and societal factors [including national culture].  Regulators should strive to do more than simply establish standards; they should consider the performance of the entire system that ensures safety.” (p. 20)

And “Safety issues are complex and involve a number or inter-related factors, activities and groups, whose importance and effect on each other and on safety might not be immediately recognisable.” (ibid.)

The Conclusions include the following: “Regulatory decisions need to consider the performance and response of the entire system delivering safety, how the different parts of the system are coupled and the direction the system is taking.” (p. 28)

Our Perspective

Much of this material in this publication will be familiar to Safetymatters readers*** but the discussion of a holistic approach to regulation is more extensive than we’ve seen elsewhere.  For that reason alone, we think this document is worth your quick review.  We have been promoting a systems view of the nuclear industry, from individual power plants to the overall socio-technical-legal-political construct, for years. 

The committee that developed the guidance consisted of almost thirty members from over a dozen countries, the International Atomic Energy Agency and NEA itself.  It’s interesting that China was not represented on the committee although it has world's largest nuclear power plant construction program**** and, one would hope, substantial interest in effective safety regulation and safety culture.  (Ooops!  China is not a member of the NEA.  Does that say something about China's perception of the NEA's value proposition?)

*  Nuclear Energy Agency, “The Safety Culture of an Effective Nuclear Regulatory Body” (2016).  Thanks to Madalina Tronea for publicizing this document.  Dr. Tronea is the founder/moderator of the LinkedIn Nuclear Safety Culture discussion group.  The NEA is an arm of the Organisation for Economic Co-operation and Development (OECD).

**  International Nuclear Safety Advisory Group, “Safety Culture,” Safety Series No. 75-INSAG-4, (Vienna: IAEA, 1991), p. 4.

***  For example, the list of challenges a regulator faces includes the usual suspects: maintain the focus on safety, avoid complacency, resist external pressures, avoid regulatory capture and maintain technical competence. (pp. 23-25)

****  “China has world's largest nuclear power capacity under construction,” China Daily (Dec. 30, 2015).


  1. "Lack of Safety Culture" is often used as a red herring to avoid having to admit that the event could have been averted by complying with existing regulations.


  2. One of the top attributes of a good safety culture is the widespread knowledge of and the transparently fastidious adherence to the rules of safety.

  3. Without the flowdown of safety requirements and the commitment to compliance with them safety culture is a cruel joke.


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