3/2003 rev 1 iv.3.1 – slide 1 of 65 session iv.3.1 iaea post graduate educational course radiation...

3/2003 Rev 13/2003 Rev 1 IV.3.1 – slide IV.3.1 – slide 11 of 65 of 65

Session IV.3.1Session IV.3.1

IAEA Post Graduate Educational CourseIAEA Post Graduate Educational CourseRadiation Protection and Safe Use of Radiation SourcesRadiation Protection and Safe Use of Radiation Sources

Part IV Principles of Radiation Protection and theInternational Framework

Module 3 The Development ofSafety Culture

Session 1 Policies, Procedures and Responsibilities


We will discuss the basic concepts of a We will discuss the basic concepts of a Safety CultureSafety Culture

OverviewOverview


Safety culture is that assembly Safety culture is that assembly of characteristics and attitudes of characteristics and attitudes in organizations and in organizations and individuals which establishes individuals which establishes that, as an that, as an overriding priorityoverriding priority, , safety issues receive the safety issues receive the attention warranted by their attention warranted by their significance.significance.

Priority to Safety CulturePriority to Safety Culture


This statement emphasizes that Safety This statement emphasizes that Safety Culture is:Culture is:

attitudinal as well as structural,attitudinal as well as structural, relates both to organizations and relates both to organizations and

individuals, andindividuals, and concerns the requirement to match all concerns the requirement to match all

safety issues with appropriate perceptions safety issues with appropriate perceptions and actionand action

Safety CultureSafety Culture


The definition relates Safety Culture to The definition relates Safety Culture to personal attitudes and habits of thought and personal attitudes and habits of thought and to the style of organizationsto the style of organizations

Although such matters are generally Although such matters are generally intangible, they lead to tangible intangible, they lead to tangible manifestationsmanifestations

A principal requirement is the development of A principal requirement is the development of means to use the tangible manifestations to means to use the tangible manifestations to test what is underlyingtest what is underlying



Safety Culture requires all duties important Safety Culture requires all duties important to safety to be carried out:to safety to be carried out:

correctlycorrectly with alertnesswith alertness with due thoughtwith due thought with full knowledgewith full knowledge with sound judgement andwith sound judgement and with a proper sense of accountabilitywith a proper sense of accountability



An organization pursuing activities with a bearing on An organization pursuing activities with a bearing on safety makes its responsibilities well known and safety makes its responsibilities well known and understood in a understood in a safety policy statementsafety policy statement

This statement is provided as guidance to staff and This statement is provided as guidance to staff and to declare the to declare the organization’s objectivesorganization’s objectives and the and the public public commitment of corporate management to commitment of corporate management to safetysafety

Safety policy statements by different bodies with Safety policy statements by different bodies with differing functions vary in both form and contentdiffering functions vary in both form and content

Statements of Safety PolicyStatements of Safety Policy


ProceduresProcedures

sound procedures and good practices are not fully sound procedures and good practices are not fully adequate if merely practiced mechanicallyadequate if merely practiced mechanically

Individual ResponsibilitiesIndividual Responsibilities

rather than merely adhering to defined rather than merely adhering to defined procedures, individuals must act in accordance procedures, individuals must act in accordance with a ‘Safety Culture’ with a ‘Safety Culture’ understanding the work understanding the work proceduresprocedures as well as complying with the as well as complying with the proceduresprocedures

procedures should be followed even when procedures should be followed even when quicker methods are availablequicker methods are available


ProceduresProcedures

Management ResponsibilitiesManagement Responsibilities

to provide a hierarchy of up to date documents to provide a hierarchy of up to date documents including including detailed working proceduresdetailed working procedures

procedures should beprocedures should be clear and unambiguous clear and unambiguous and they should form an integral seriesand they should form an integral series

procedures should receive formal procedures should receive formal scrutinyscrutiny, , checking and testing under the organizations’ checking and testing under the organizations’ quality assurancequality assurance arrangements, and formal arrangements, and formal means should be adopted for their means should be adopted for their controlcontrol


An An operating organizationoperating organization has full and formal has full and formal responsibility for the safety of its plantsresponsibility for the safety of its plants

Its safety policy statement is clear and is provided to Its safety policy statement is clear and is provided to all staffall staff

This statement declares a commitment to excellent This statement declares a commitment to excellent performance in all activities important for safety, performance in all activities important for safety, making it plain that safety has the utmost priority, making it plain that safety has the utmost priority, overriding if necessary the demands of production or overriding if necessary the demands of production or project schedulesproject schedules

ResponsibilitiesResponsibilities


A A regulatory bodyregulatory body has a weighty influence on the has a weighty influence on the safety of activitirs within its purview and an effective safety of activitirs within its purview and an effective Safety Culture pervades its own organization and its Safety Culture pervades its own organization and its staffstaff

The basis is again set down in a safety policy The basis is again set down in a safety policy statementstatement

This makes a commitment to implement legislation This makes a commitment to implement legislation and to act to promote plant safety and the protection and to act to promote plant safety and the protection of individuals and the public, and to protect the of individuals and the public, and to protect the environmentenvironment



Supporting organizationsSupporting organizations, which include those , which include those responsible for design, manufacture, construction responsible for design, manufacture, construction and research, influence greatly the safety of plantsand research, influence greatly the safety of plants

Their primary responsibility is for quality of the Their primary responsibility is for quality of the product, whether this is a design or a manufactured product, whether this is a design or a manufactured component, installed equipment, a safety report or component, installed equipment, a safety report or software development, or any other output important software development, or any other output important to safetyto safety

The basis for Safety Culture in such an organization The basis for Safety Culture in such an organization is the directive establishing policy and practices to is the directive establishing policy and practices to achieve quality, and thereby to meet the safety achieve quality, and thereby to meet the safety objectives of the future operatorobjectives of the future operator



The responsibility assigned toThe responsibility assigned to individuals individuals is defined is defined and documented in sufficient detail to prevent and documented in sufficient detail to prevent ambiguityambiguity

The collective definitions of the authority and The collective definitions of the authority and responsibility of individuals are reviewed to ensure responsibility of individuals are reviewed to ensure that there are no omissions or overlaps and no that there are no omissions or overlaps and no problems of shared responsibilitiesproblems of shared responsibilities

Definitions of responsibility are approved at a higher Definitions of responsibility are approved at a higher level of authoritylevel of authority



Managers ensure that individuals understand not only Managers ensure that individuals understand not only their own responsibilities but also those of their their own responsibilities but also those of their immediate colleagues and of their management unit, immediate colleagues and of their management unit, and how these responsibilities complement those of and how these responsibilities complement those of other groupsother groups

This requirement for careful definition of This requirement for careful definition of responsibilities applies with special force to operating responsibilities applies with special force to operating organizations since they carry the formal organizations since they carry the formal responsibility for plant safetyresponsibility for plant safety

The delegated responsibility of the plant manager for The delegated responsibility of the plant manager for the safety of the plant is given particular emphasisthe safety of the plant is given particular emphasis



Lines of AuthorityLines of Authority

one key requirement common to all organizations is one key requirement common to all organizations is strong lines of authority established for those strong lines of authority established for those matters bearing on safety – this is accomplished by matters bearing on safety – this is accomplished by means of clear reporting lines with few and simple means of clear reporting lines with few and simple interfaces, supported by the definition and interfaces, supported by the definition and documentation of dutiesdocumentation of duties

the formal responsibility for plant safety lies with the the formal responsibility for plant safety lies with the operating organizations and the delegated authority operating organizations and the delegated authority with the plant managerwith the plant manager

discharge of individual responsibilities is facilitated discharge of individual responsibilities is facilitated by unique and clear lines of authorityby unique and clear lines of authority


A Questioning AttitudeA Questioning Attitude

A Rigorous and Prudent ApproachA Rigorous and Prudent Approach

CommunicationCommunication

SafetySafety

++

++

Individual CharacteristicsIndividual CharacteristicsContributing to Safety CultureContributing to Safety Culture


Managers’Managers’CommitmentCommitment

Definition ofDefinition ofResponsibilitiesResponsibilities

Definition andDefinition andControl ofControl of

Safety PracticesSafety Practices

QualificationsQualificationsand Trainingand Training

Rewards andRewards andSanctionsSanctions

Audit, Review andAudit, Review andComparisonComparison

Statement ofStatement ofSafety PolicySafety Policy

ManagementManagementStructuresStructures

ResourcesResources

Self RegulationSelf Regulation

Policy LevelPolicy LevelCommitmentCommitment

QuestioningQuestioningAttitudeAttitude

Rigorous andRigorous andPrudent ApproachPrudent Approach

CommunicationCommunication

Individuals’Individuals’CommitmentCommitment


Major ComponentsMajor Componentsof Safety Structureof Safety Structure


Organizational ArrangementsOrganizational Arrangements

GovernmentGovernment

Regulatory AgencyRegulatory Agency

CorporateCorporate

PlantPlant

Supporting OrganizationsSupporting Organizations


Organizational ArrangementsOrganizational Arrangements

GovernmentGovernment

Legislature – makes the lawsLegislature – makes the laws Regulatory Agency – implements the laws Regulatory Agency – implements the laws

(may also include initial enforcement)(may also include initial enforcement) Audit Agency – evaluates the Audit Agency – evaluates the

effectiveness of the Regulatory Agencyeffectiveness of the Regulatory Agency Judiciary – final enforcement toolJudiciary – final enforcement tool


This Act is the fundamental United States law on This Act is the fundamental United States law on both the civilian and the military uses of nuclear both the civilian and the military uses of nuclear materialsmaterials

On the civilian side, it provides for both the On the civilian side, it provides for both the development and the regulation of the uses of development and the regulation of the uses of nuclear materials and facilities in the United States, nuclear materials and facilities in the United States, declaring the policy that declaring the policy that "the development, use, and "the development, use, and control of atomic energy shall be directed so as to control of atomic energy shall be directed so as to promote world peace, improve the general welfare, promote world peace, improve the general welfare, increase the standard of living, and strengthen free increase the standard of living, and strengthen free competition in private enterprise“competition in private enterprise“

Atomic Energy Act of 1954Atomic Energy Act of 1954as Amended in 1974as Amended in 1974


The Act requires that civilian uses of nuclear The Act requires that civilian uses of nuclear materials and facilities be licensed, and it empowers materials and facilities be licensed, and it empowers the NRC to establish by rule or order, and to enforce, the NRC to establish by rule or order, and to enforce, such standards to govern these uses such standards to govern these uses as "the as "the Commission may deem necessary or desirable in Commission may deem necessary or desirable in order to protect health and safety and minimize order to protect health and safety and minimize danger to life or property“danger to life or property“

Commission action under the Act must conform to Commission action under the Act must conform to the Act’s procedural requirements, which provide an the Act’s procedural requirements, which provide an opportunity for hearings and Federal judicial review opportunity for hearings and Federal judicial review in many instancesin many instances



Under section 274 of the Act, the NRC may enter into Under section 274 of the Act, the NRC may enter into an agreement with a State for discontinuance of the an agreement with a State for discontinuance of the NRC’s regulatory authority over some materials NRC’s regulatory authority over some materials licensees within the Statelicensees within the State

The State must first show that its regulatory The State must first show that its regulatory program is compatible with the NRC’s and adequate program is compatible with the NRC’s and adequate to protect public health and safetyto protect public health and safety

The NRC retains authority over, among other things, The NRC retains authority over, among other things, nuclear power plants within the State and exports nuclear power plants within the State and exports from the Statefrom the State



StateStateJurisdictionJurisdiction

FederalFederalJurisdictionJurisdiction

CurrentlyCurrentlyFederalFederalbut Activelybut ActivelySeeking State JurisdictionSeeking State Jurisdiction

Federal vs State JurisdictionFederal vs State Jurisdictionover Radioactive Materialsover Radioactive Materials


Number of LicensesNumber of LicensesStateState Federal Federal StatesStatesAlabama Alabama 20 20 430430Alaska Alaska 7 7 00Arizona Arizona 17 17 292292Arkansas Arkansas 7 7 257257California California 55 55 2,1372,137Colorado Colorado 22 22 337337Connecticut Connecticut 194194 00Delaware Delaware 62 62 00District ofDistrict of Columbia Columbia 46 46 00Florida Florida 20 20 1,3211,321Georgia Georgia 17 17 502502Hawaii Hawaii 57 57 00

Number of LicensesNumber of LicensesStateState Federal Federal StatesStatesIdaho Idaho 84 84 00Illinois Illinois 46 46 742742Indiana Indiana 282 282 00Iowa Iowa 4 4 183183Kansas Kansas 4 4 318318Kentucky Kentucky 11 11 401401Louisiana Louisiana 11 11 479479Maine Maine 2 2 130130Maryland Maryland 61 61 561561Massachusetts Massachusetts 34 34 533533Michigan Michigan 514 514 00Minnesota Minnesota 161 161 00Mississippi Mississippi 8 8 315315Missouri Missouri 294 294 00



Number of LicensesNumber of LicensesState State Federal Federal StatesStatesMontana Montana 77 77 00Nebraska Nebraska 6 6 140140Nevada Nevada 5 5 240240New Hampshire New Hampshire 9 9 8282New Jersey New Jersey 520 520 00New Mexico New Mexico 15 15 218218New York New York 53 53 1,3661,366North Carolina North Carolina 20 20 696696North Dakota North Dakota 10 10 6161Ohio Ohio 45 45 710710Oklahoma Oklahoma 39 39 244244Oregon Oregon 10 10 464464Pennsylvania Pennsylvania 741 741 00

Number of LicensesNumber of LicensesState State Federal Federal StatesStatesRhode Island Rhode Island 2 2 6060South Carolina South Carolina 17 17 362362South Dakota South Dakota 44 44 00Tennessee Tennessee 25 25 555555Texas Texas 52 52 1,5101,510Utah Utah 10 10 200200Vermont Vermont 35 35 00Virginia Virginia 383 383 00Washington Washington 17 17 407407West Virginia West Virginia 183 183 00Wisconsin Wisconsin 262 262 00Wyoming Wyoming 88 88 00Others Others 164 164 00Total Total 4,922 4,922 16,25316,253



RegulationsRegulations

The Federal Agency issues Regulations which The Federal Agency issues Regulations which are legally bindingare legally binding

In order to obtain, possess, use, transfer or In order to obtain, possess, use, transfer or dispose of radioactive material, organizations dispose of radioactive material, organizations must apply for and be issued a license and must apply for and be issued a license and must obey the regulationsmust obey the regulations


RegulationsRegulations

The Regulations which in the United States are termed The Regulations which in the United States are termed “Title 10 of the Code of Federal Regulations” include “Title 10 of the Code of Federal Regulations” include many sections which establish Safety Requirements for many sections which establish Safety Requirements for specific activities such as:specific activities such as:

Part 20Part 20 Standards for Protection Against RadiationStandards for Protection Against RadiationPart 34Part 34 Licenses for Licenses for Industrial RadiographyIndustrial Radiography and and

Radiation Safety Requirements for Industrial Radiation Safety Requirements for Industrial Radiographic OperationsRadiographic Operations

Part 35Part 35 MedicalMedical Use of Byproduct Material Use of Byproduct MaterialPart 36Part 36 Licenses and Radiation Safety Requirements Licenses and Radiation Safety Requirements

for for IrradiatorsIrradiatorsPart 39Part 39 Licenses and Radiation Safety Requirements Licenses and Radiation Safety Requirements

for for Well LoggingWell Logging


Guidance DocumentsGuidance Documents

To assist licensees in understanding the expectations To assist licensees in understanding the expectations of the Federal Agency, Guidance Documents are of the Federal Agency, Guidance Documents are provided such as provided such as NUREG 1556NUREG 1556::

Vol 2Vol 2 Program-Specific Guidance About Program-Specific Guidance About Industrial Industrial RadiographyRadiography Licenses Licenses

Vol 5Vol 5 Program-Specific Guidance About Program-Specific Guidance About Self-Shielded Self-Shielded IrradiatorIrradiator Licenses Licenses

Vol 9Vol 9 Program-Specific Guidance About Program-Specific Guidance About MedicalMedical Use Use LicensesLicenses

Vol 14Vol 14 Program-Specific Guidance About Program-Specific Guidance About Well Logging, Well Logging, Tracer, and Field Flood StudyTracer, and Field Flood Study Licenses Licenses


EnforcementEnforcement

Although only used as a last resort, credible Although only used as a last resort, credible enforcement is essential for those who do not exhibit a enforcement is essential for those who do not exhibit a strong commitment to Safety Culture. The US NRC strong commitment to Safety Culture. The US NRC Enforcement Policy States:Enforcement Policy States:

While adequate protection is presumptively assured by While adequate protection is presumptively assured by compliance with NRC requirements, circumstances may compliance with NRC requirements, circumstances may arise where new information reveals that an unforeseen arise where new information reveals that an unforeseen hazard exists or that there is a substantially greater hazard exists or that there is a substantially greater potential for a known hazard to occur. In such potential for a known hazard to occur. In such situations, the NRC has the statutory authority to situations, the NRC has the statutory authority to require licensee action above and beyond existing require licensee action above and beyond existing regulations to maintain the level of protection regulations to maintain the level of protection necessary to avoid undue risk to public health and necessary to avoid undue risk to public health and safety. safety.


EnforcementEnforcement

The NRC also has the authority to exercise discretion to The NRC also has the authority to exercise discretion to permit continued operations -- despite the existence of permit continued operations -- despite the existence of a noncompliance -- where the noncompliance is not a noncompliance -- where the noncompliance is not significant from a risk perspective and does not, in the significant from a risk perspective and does not, in the particular circumstances, pose an undue risk to public particular circumstances, pose an undue risk to public health and safety. When noncompliance occurs, the health and safety. When noncompliance occurs, the NRC must evaluate the degree of risk posed by thatNRC must evaluate the degree of risk posed by thatnoncompliance to determine if specific immediate noncompliance to determine if specific immediate action is required.action is required. Where needed to ensureWhere needed to ensureadequate protection of public health and safety, the adequate protection of public health and safety, the NRC may demand immediate licensee action,NRC may demand immediate licensee action,up to and including a shutdown or cessation of up to and including a shutdown or cessation of licensed activities.licensed activities.


Lines of CommunicationLines of Communication

CommunicationCommunication is the key to success. It is also a is the key to success. It is also a “two-way-street”:“two-way-street”:

management must keep everyone informed of the management must keep everyone informed of the policies related to Safety as well as clearly policies related to Safety as well as clearly communicate their commitment to Safetycommunicate their commitment to Safety

individuals must be encouraged to communicate individuals must be encouraged to communicate Safety concerns to management – where deemed Safety concerns to management – where deemed necessary, a “chain-of-command” structure is necessary, a “chain-of-command” structure is acceptable provided Safety concerns are elevated acceptable provided Safety concerns are elevated to the appropriate level - a separate, direct channel to the appropriate level - a separate, direct channel to senior management or an independent group to senior management or an independent group should be available should lower level should be available should lower level management fail to adequately address the issuemanagement fail to adequately address the issue



Lack of communication or inability to Lack of communication or inability to communicate will significantly impact Safety communicate will significantly impact Safety CultureCulture

Some examples are provided on the following Some examples are provided on the following slidesslides



Lack of Communication or Inability to Communicate Lack of Communication or Inability to Communicate may result from situations such as:may result from situations such as:

Senior Management not wanting to be told bad Senior Management not wanting to be told bad news (e.g., “if you have a problem fix it, don’t news (e.g., “if you have a problem fix it, don’t bother me with the details”)bother me with the details”)

Junior Management not wanting to acknowledge Junior Management not wanting to acknowledge the existence of problems to Senior Management the existence of problems to Senior Management for fear of impacting their careers (e.g., “if we tell for fear of impacting their careers (e.g., “if we tell the boss there’s a problem he’ll blame me”) or the boss there’s a problem he’ll blame me”) or fear of interference from a higher level (e.g., “if fear of interference from a higher level (e.g., “if we tell the boss there’s a problem he’ll start we tell the boss there’s a problem he’ll start telling us how to do our job”)telling us how to do our job”)



Individuals being warned (directly or implicitly) Individuals being warned (directly or implicitly) not to raise safety concerns by their supervisorsnot to raise safety concerns by their supervisors

Inaccessibility of those who can take action (e.g., Inaccessibility of those who can take action (e.g., absentee management who never visit the absentee management who never visit the workplace so that individuals don’t know who to workplace so that individuals don’t know who to turn to for assistance)turn to for assistance)

Although fear is often the prime factor contributing Although fear is often the prime factor contributing to lack of communication, in some cases it is to lack of communication, in some cases it is lethargy (e.g., “if I raise a safety concern, then I’ll be lethargy (e.g., “if I raise a safety concern, then I’ll be asked to do something about it or I’ll have to fill out asked to do something about it or I’ll have to fill out a lot of useless paperwork, let someone else do it”)a lot of useless paperwork, let someone else do it”)


Attention to safety involves many elements:Attention to safety involves many elements:

Individual Individual awarenessawareness of the importance of safety. of the importance of safety.

Knowledge and competenceKnowledge and competence, conferred by training , conferred by training and instruction of personnel and by their self-and instruction of personnel and by their self-education.education.

CommitmentCommitment, requiring demonstration at senior , requiring demonstration at senior management level of the high priority of safety and management level of the high priority of safety and adoption by individuals of the common goal of adoption by individuals of the common goal of safety.safety.



Attention to safety involves many elements:Attention to safety involves many elements:

MotivationMotivation, through leadership, the setting of , through leadership, the setting of objectives and systems of rewards and sanctions, objectives and systems of rewards and sanctions, and through individuals* self-generated attitudes.and through individuals* self-generated attitudes.

SupervisionSupervision, including audit and review practices, , including audit and review practices, with readiness to respond to individuals’ with readiness to respond to individuals’ questioning attitudes.questioning attitudes.

ResponsibilityResponsibility, through formal assignment and , through formal assignment and description of duties and their understanding by description of duties and their understanding by individuals.individuals.



Techniques Organizations Techniques Organizations Use To Change Their CultureUse To Change Their Culture

Most ImportantMost Important

Senior managementSenior management visibly and vigorously visibly and vigorously demonstrates its demonstrates its commitmentcommitment and support for and support for safety culture valuessafety culture values

Staff is trainedStaff is trained to convey and develop skills to convey and develop skills related to safety culture valuesrelated to safety culture values



Very ImportantVery Important

Safety culture value statements are developedSafety culture value statements are developed

Safety culture values are communicated to Safety culture values are communicated to staffstaff

Management practices are consistent with Management practices are consistent with desired safety culture valuesdesired safety culture values



Very Important (cont)Very Important (cont)

Rewards, incentives and promotions are Rewards, incentives and promotions are offered to encourage individual practices offered to encourage individual practices compatible with safety culture valuescompatible with safety culture values

Meetings are used to convey and support Meetings are used to convey and support safety culture valuessafety culture values



Very Important (cont)Very Important (cont)

The organizational structure is made The organizational structure is made compatible with safety culture valuescompatible with safety culture values

Systems, procedures and processes which Systems, procedures and processes which are compatible with the safety culture values are compatible with the safety culture values are establishedare established



Moderate ImportanceModerate Importance

The responsibilities of employees who do not The responsibilities of employees who do not support the desired safety culture values are support the desired safety culture values are replaced or changedreplaced or changed

Anecdotes and stories are used to convey Anecdotes and stories are used to convey safety culture valuessafety culture values

Employees who demonstrate exemplary safety Employees who demonstrate exemplary safety culture are made company heroesculture are made company heroes



Some ImportanceSome Importance

Employees who possess or are willing to Employees who possess or are willing to accept safety culture values are recruitedaccept safety culture values are recruited

Slogans and signs are used to symbolize Slogans and signs are used to symbolize safety culture valuessafety culture values

A manager or group primarily responsible for A manager or group primarily responsible for safety culture change efforts is establishedsafety culture change efforts is established


Safety Cultures (good and bad)Safety Cultures (good and bad)Observed by the IAEAObserved by the IAEA

Most organizations had a fairly good safety Most organizations had a fairly good safety culture, but all had areas for improvement.culture, but all had areas for improvement.

Some organizations had already employed Some organizations had already employed considerable resources for self-assessment considerable resources for self-assessment and further enhancement of safety culture.and further enhancement of safety culture.

The root cause of many problems could be The root cause of many problems could be related to intangible factors. Therefore, it was related to intangible factors. Therefore, it was necessary to continue efforts to better necessary to continue efforts to better understand, promote and enhance safety understand, promote and enhance safety culture.culture.


In some organizations safety policy In some organizations safety policy statements at corporate and plant level were statements at corporate and plant level were inadequate and had not been communicated inadequate and had not been communicated to all staff.to all staff.

Nuclear safety and the overriding importance Nuclear safety and the overriding importance of safety was not incorporated in company of safety was not incorporated in company policy statements.policy statements.



Corporate nuclear safety review committees Corporate nuclear safety review committees were not established and in some plants no were not established and in some plants no formal safety review committee existed.formal safety review committee existed.

Training programmes did not include safety Training programmes did not include safety culture topics.culture topics.

Appraisal forms for promotion did not include Appraisal forms for promotion did not include specific sections on candidates’ attitudes to specific sections on candidates’ attitudes to safety.safety.



No means for recognition of good safety No means for recognition of good safety performance existed.performance existed.

Managers and supervisors needed to hold Managers and supervisors needed to hold periodic meetings to convey and reinforce the periodic meetings to convey and reinforce the safety policy to all staff.safety policy to all staff.

Supervisors needed to check the conduct of Supervisors needed to check the conduct of work more often, especially on safety related work more often, especially on safety related equipment.equipment.



Operational feedback, lessons learned and Operational feedback, lessons learned and examples of shortcomings were not used to examples of shortcomings were not used to educate staff or to highlight safety awareness.educate staff or to highlight safety awareness.

There was a lack of any effective There was a lack of any effective communication systems for management/ communication systems for management/ workers to inform each other on safety issues.workers to inform each other on safety issues.



The U.S. Nuclear Regulatory Commission regulates the Nation’s civilian use of byproduct, source, and special nuclear materials to ensure adequate protection of the public health and safety, to promote the common defense and security, and to protect the environment.

US Regulatory AgencyUS Regulatory AgencyMission StatementMission Statement


Prevent radiation-related deaths and illnesses, promote the common defense and security, and protect the environment in the use of civilian nuclear reactors.

Prevent radiation-related deaths and illnesses, promote the common defense and security, and protect the environment in the use of source, byproduct, and special nuclear material.

US Regulatory AgencyUS Regulatory AgencyStrategic GoalsStrategic Goals


Prevent significant adverse impacts from radioactive waste to the current and future public health and safety and the environment, and promote the common defense and security.

Support U.S. interests in the safe and secure use of nuclear materials and in nuclear non-proliferation.

US Regulatory AgencyUS Regulatory AgencyStrategic GoalsStrategic Goals


Independence:

Nothing but the highest possible standards of ethical performance and professionalism should influence regulation. However, independence does not imply isolation. All available facts and opinions must be sought openly from licensees and other interested members of the public. The many and possibly conflicting public interests involved must be considered. Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated.

US Regulatory AgencyUS Regulatory AgencyPrinciples of Good RegulationPrinciples of Good Regulation


Openness:

Nuclear regulation is the public's business, and it must be transacted publicly and candidly. The public must be informed about and have the opportunity to participate in the regulatory processes as required by law. Open channels of communication must be maintained with Congress, other government agencies, licensees, and the public, as well as with the international nuclear community.



Efficiency:

The American taxpayer, the rate-paying consumer, and licensees are all entitled to the best possible management and administration of regulatory activities. The highest technical and managerial competence is required, and must be a constant agency goal. NRC must establish means to evaluate and continually upgrade its regulatory capabilities. Regulatory activities should be consistent with the degree of risk reduction they achieve. Where several effective alternatives are available, the option which minimizes the use of resources should be adopted. Regulatory decisions should be made without undue delay.



Clarity:

Regulations should be coherent, logical, and practical. There should be a clear nexus between regulations and agency goals and objectives whether explicitly or implicitly stated. Agency positions should be readily understood and easily applied.



Reliability:

Regulations should be based on the best available knowledge from research and operational experience. Systems interactions, technological uncertainties, and the diversity of licensees and regulatory activities must all be taken into account so that risks are maintained at an acceptably low level. Once established, regulation should be perceived to be reliable and not unjustifiably in a state of transition. Regulatory actions should always be fully consistent with written regulations and should be promptly, fairly, and decisively administered so as to lend stability to the nuclear operational and planning processes.



Integrity - in our working relationships, practices and decisions.

Excellence - both in our individual and collective actions.

Service - to the public, and others who are affected by our work.

Respect - for individuals' roles, diversity, and viewpoints.

Cooperation - in the planning, management, and work of the agency.

Commitment - to protecting the public health and safety.

Openness - in communications and decision making.

US Regulatory AgencyUS Regulatory AgencyOrganizational ValuesOrganizational Values


US Regulatory AgencyUS Regulatory AgencyManagement ChallengesManagement Challenges


PerceptionsPerceptions

In 2002, the Office of the Inspector general of the US In 2002, the Office of the Inspector general of the US Nuclear Regulatory Commission conducted a survey of Nuclear Regulatory Commission conducted a survey of the Safety Culture and Climate within the Agency. This the Safety Culture and Climate within the Agency. This was a follow-up to a similar survey conducted in 1998.was a follow-up to a similar survey conducted in 1998.

The results can be viewed at the following website:The results can be viewed at the following website:http://www.nrc.gov/reading-rm/doc-collections/insp-http://www.nrc.gov/reading-rm/doc-collections/insp-gen/2003/03a-03.pdfgen/2003/03a-03.pdf

The results are correlated many different ways in the The results are correlated many different ways in the report. The following slide shows the correlation with report. The following slide shows the correlation with Grade Level (i.e., employees vs management)Grade Level (i.e., employees vs management)


PerceptionsPerceptions

SeniorSeniorManagementManagement

Most EmployeesMost Employees

JuniorJuniorManagementManagement


Having just completed a rather lengthy discussion of Safety Culture it is now time to consider the following quote:

“Beware of OrganizationsWhose Top Priority is Safety”

This would appear to contradict all that we have stated. Isn’t this what we want? Don’t we want an organization to have Safety as its “Top Priority”?

Final Thoughts Final Thoughts


The quote on the preceding slide is taken from a contractor in the United States who teaches a training course entitled “Root Cause/Incident Investigation Team Training” to the Federal Agency responsible for Radiation Safety. The contractor also consults with licensee organizations who have had accidents, helping them to determine the “Root Causes” and correct them

Obviously the business of this contractor is Safety, so why would they say such a thing?

The answer is simple. For its very existence, a non-regulatory organization’s “Top Priority” is to conduct business and make money



Safety may be a “High Priority” but it can’t be the“Top Priority”. If Safety were the Top Priority, then, to insure perfect safety, the organization would likely have to terminate operations. Airlines would stop flying, automakers would stop producing cars, etc

However, if the organization continues to operate, it must compromise and accept some degree of reduced safety (i.e., acknowledge that accidents may happen but take reasonable steps to minimize the probability and severity). Thus Safety is not their “Top Priority”



Even for Regulatory Agencies, safety cannot be their “Top Priority” otherwise they would refuse to license any activity that had the potential for exposing individuals to radiation or releasing radioactive material into the environment

As we have seen, all that a Regulatory Agency can do is to strive for “adequate” protection of public health and safety

Licenses are issued to organizations that expose people to radiation, however, restrictions are imposed to minimize the probability and severity



The goal is to “control” risk rather than “eliminate” risk. If we could eliminate the risk without sacrificing the benefits, we would certainly do so. But in most cases this cannot be done. So we accept some level of risk in exchange for the benefits accrued

So, if an organizations management states that “Safety is our Top Priority”, be skeptical. Do they really mean it or are they merely saying it because that is what they think Regulatory Agencies want to hear. Be inquisitive, dissect their philosophy, scrutinize their actions and do whatever is needed to find out where they really stand on Safety



Where to Get More InformationWhere to Get More Information

IAEA Safety Series Report No 75-INSAG-4, Safety IAEA Safety Series Report No 75-INSAG-4, Safety Culture, 1991Culture, 1991

http://www.nrc.gov/reading-rm/doc-collections/cfr/http://www.nrc.gov/reading-rm/doc-collections/cfr/

(US NRC Regulations)(US NRC Regulations)

http://www.nrc.gov/reading-rm/doc-collections/http://www.nrc.gov/reading-rm/doc-collections/nuregs/nuregs/

(US NRC Guidance Documents)(US NRC Guidance Documents)

http://www.nrc.gov/what-we-do/regulatory/http://www.nrc.gov/what-we-do/regulatory/enforcement.htmlenforcement.html(US NRC Enforcement Policy)(US NRC Enforcement Policy)