tag:blogger.com,1999:blog-4170623839736191950.post6821862020592277207..comments2022-12-03T19:22:46.911-08:00Comments on Safetymatters: Safety culture information, analysis and management: The NRC Does Not Regulate Safety Culture, Right?Bob Cudlinhttp://www.blogger.com/profile/08502712287881656493noreply@blogger.comBlogger3125tag:blogger.com,1999:blog-4170623839736191950.post-41212272102200990832012-04-26T11:52:26.088-07:002012-04-26T11:52:26.088-07:00Re: Dave Collins' comment that BP management d...Re: Dave Collins' comment that BP management did not know the difference between OSHA safety and process safety. He may be going easy on BP. We think it's possible that BP leadership was not focused on ANY type of safety as a high priority. Clearly they made decisions that favored business objectives in trying to get the rig finished and into production. The lengthy period of no lost-time worker accidents could have been simple good fortune, and not the result of BP management activityLewis Connerhttps://www.blogger.com/profile/08283295941018353006noreply@blogger.comtag:blogger.com,1999:blog-4170623839736191950.post-37333516894393937892012-04-24T16:59:49.137-07:002012-04-24T16:59:49.137-07:00Define, measure, manage [and regulate]. In order t...Define, measure, manage [and regulate]. In order to manage [or regulate] anything effectively, you need to be able to measure [assess] it accurately. To measure anything accurately, to need to be able to define it clearly [you need what is referred to as an "operational definition".<br /><br />There are many different types of safety culture. How safely you drive is your own personal "driver safety culture". There are many safety cultures at a plant [I made a slide of this that INPO uses] electrical,medical, OSHA, chemical etc. <br /><br />What is called "nuclear safety culture" is actually "process safety culture" which is the same as the process safety culture of any HRO.<br /><br />Vis a vis "safety culture" I was on the NRC "expert panel" in 2011 that developed the new NRC definition. I was [by a considerable margin] the most expert on the subject, but I was also a "member of the public" and most of my input was overruled by INPO, NEI, NRC and industry executives. <br /><br />I did get a few words in such as "leadership" and "protect people and environment" but overall NRC developed an improper, inaccurate definition becuase they [as is usual] tend to be quite arrogent and often DO NOT LISTEN WELL AT ALL.<br /><br />As the Baker commission investigating the 2005 BP Texas refinery acident pointed out, BP leadership did not know the difference between OSHA safety culture and process safety culture. Just hours prior to the 2011 BP Gulf oil disaster, BP executives landed on the platform to deliver an OSHA safety award for low worker accident rate, then BOOM because BP managers had [to save a little time and money] overruled process safety measures [addition of drilling mud] planned by Haliburton. With the mud, Berkeley blowout expert Dr. Bob Bea says it is likely there would have been no blowout.<br /><br />Point is, exactly like BP, NRC does not understand that "nuclear safety culture" is "process safety culture". I did a 15 minute presentation at the workshop, people stared with blank expressions, no one understood what I was saying, but there were no questions. Not one. No one wanted to understand, becuase [like BP] the industry [mainly NEI and INPO] wanted to do what that they wanted to do, period.<br /><br />Here is a proper definition of nuclear safety culture that would [or at least could] have led to proper effective assessment management [and regulation] of NSC, if NRC had been able to listen to me [truly listen to me with an open mind for just a few minutes] at the 2011 meeting:<br /><br />Nuclear [or HRO, or Process] Safety Culture<br /><br />"In a high hazard industry or venture, professional leadership attitudes that ensure risk of harm to the public or the environment is maintained as low as reasonably achievable, thereby assuring stakeholder trust."<br /><br />However, it needs to be understood as the process safety culture operating operates within a HHI/HHV/HRO, which also need to be understood.<br /><br />High Hazard Industry or Venture<br /><br />"An industry or venture that operates and manages specialized processes with significant inherent risk of harm to public health or the environment. Examples: nuclear power, aviation, medical, chemical, military."<br /><br />High Reliability Organization<br /><br />"An organization that manages specialized processes with significant inherent risk of harm to public health or the environment."<br /><br />I have several dozen more fully developed definitions [i.e. a "language"] necessary for fully understanding HRO / nuclear / process safety culture, but what is the point of trying to discuss them if NRC / NEI / INPO do not to wish to listen, to understand?<br /><br />I am beyond caring and am at peace now. You can lead a horse to water, but you can't make him drink. You can show a man the solution, but you can't make him think.<br /><br />Dave Collinsdavednukerhttps://www.blogger.com/profile/15004166764727867004noreply@blogger.comtag:blogger.com,1999:blog-4170623839736191950.post-25210006710097373742012-04-05T12:05:29.955-07:002012-04-05T12:05:29.955-07:00With respect for your view, I would say you are be...With respect for your view, I would say you are bending over backwards to interpret the evidence as consistent with a conclusion they are "not 'officially' regulating safety culture."<br /><br />The very usage regarding "officially regulating" is indicative of the sorts of hypothetical hair-splitting that the entire NSC exercise promotes. Of course they are regulating - when "expectations" lead to enforceable consequences in the inspection program results - its regulation. <br /><br />The NRC doesn't have the authority to do anything but regulated. The issue here is not about regulation but about the manner of enforcement and the degree of persuasion and compliant response that Staff will accept as they go about their regulatory duties. In any quasi-logical world how could it be different?<br /><br />If the issue with NSC is not whether it is regulation or not, then we can step back and ask are these effective and prudent ways to meet the NRC's Strategic Safety Objectives? <br /><br />Given that those SSO embody a Duty of Prevention - zero acceptance that not all significant close calls can be avoided - I suggest that it will not be effective and will devolve into the imprudent. The Entergy Confirmatory Order in the Fitzpatrick case seems to me a good example of how NSC regulation leads to NRC over-functioning.Bill Mullinsnoreply@blogger.com