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 Proposed Safety Culture Components 

U.S. Nuclear Regulatory Commission 

Public Workshop on Development of a Policy Statement 

On Safety Culture and Security Culture 

February 3, 2009 

Guidance for Submitting Comments 

Your input is requested on the attached questions! 

 When providing written comments, please list the relevant topic and question numbers 

when appropriate. 

 When commenting, please exercise caution with regard to site-specific security-related 

information. Comments may be made available to the public in their entirety. 

 Optional – please consider including your contact information with your submission: 

name, affiliation, email, and phone number. Note that personal information will not be 

removed from your submission if it is made public. 

You are encouraged to provide your comments to the following contact by February 11, 2009, 

to ensure the consideration of your comments. Comments received after this date will be 

considered if it is practical to do so. 

June Cai 

U.S. Nuclear Regulatory Commission 

Mail Stop O4 A15A 

Washington, DC 20555 

june.cai@nrc.gov 

(301) 415-5192 

Website Resource

Visit the NRC Safety Culture public website at: http://www.nrc.gov/aboutnrc/regulatory/enforcement/safety-culture.html to review background/historical information and 

to keep up-to-date on NRC activities in this area. 
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PROPOSED SAFETY CULTURE COMPONENTS 

 Background Information 

The U.S. Nuclear Regulatory Commission (NRC) safety culture working group developed a set 

of 13 safety culture components to be used in the Reactor Oversight Process (ROP) based on a 

variety of sources including the nuclear and other domestic industries, international 

organizations and regulatory bodies, organizational literature and the knowledge and 

experience of the working group members. The information on safety culture gathered by the 

working group was screened to ensure that the information in the components was 

unambiguous, within the NRC’s regulatory purview, provides insights on the components 

through existing inspection techniques, and was generally applicable to reactor licensees. The 

NRC’s components were compared to both industry and international safety culture attributes to 

ensure that the staff fully captured concepts appropriate for NRC oversight. In an effort to use 

language, titles, and nomenclature that are common with the industry, the working group 

compared the NRC’s safety culture components to the safety culture attributes and principles 

developed by the Institute of Nuclear Power Operations (INPO). To address internal and 

external stakeholder feedback following a series of public meetings in the late 2005 through 

early 2006 time frame, the working group further revised the safety culture components to 

enhance their concepts and use language that would better facilitate use of the components 

under the ROP. 

The enhanced ROP incorporating the safety culture components was implemented in June 

2006. The safety culture components were more recently evaluated for their applicability to 

other licensee environments such as for oversight of fuel facilities and new reactor construction. 

These reviews indicated that all of the components were applicable to these environments, 

albeit with tweaking of some of the language to take into consideration the unique aspects of 

those environments. 

In reviewing the components for their potential inclusion in the development of the draft policy 

statement(s), staff made further changes based on lessons learned from the initial 18 month 

implementation of the ROP and also in consideration of the following: 

• Improved the overall organization of concepts, such as integrated some components into 

others to combine related concepts 

• Better address “security” 

• Reword to be more generic to all licensee and certificate holders 

• Separated some components related to individual worker performance from the higher 

level programmatic and organizational performance types of functions 

This review resulted in the proposed nine safety culture components as provided in the 

attached. Under each of the safety culture components are example aspects to help with the 

understanding of each of the components.
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QUESTIONS ON SAFETY CULTURE COMPONENTS 

1. Is there an area(s) important to safety or security culture that does not appear to be 

captured by the set of nine components? Is the missing area(s) relevant to a particular set 

of licensees or certificate holders? Or is it generically applicable? If so, please specify. 

2. Of the identified components, is there a safety culture component(s) that you consider to 

not be important, or to not contribute, to safety culture and should therefore be dropped? If 

so, please specify. 

3. How should the Commission communicate a common understanding of the components 

of safety/security culture? 

4. How should the Commission, through the policy statement, influence licensee and 

certificate holders to use their understanding of safety/security culture to improve 

performance? 

5. Should there be new regulatory requirements specifically addressing safety culture? If 

so, please explain. Or, how should safety culture insights to be used, e.g., to inform 

regulatory response to findings or violations within existing requirements?

6. Given the range of NRC licensees and certificate holders, how can the Commission best 

communicate its expectations regarding the scope of programs and processes to address 

safety/security culture in a manner that appropriately considers the different licensee and 

certificate holders environment?

7. How should the Commission define the components of safety and security culture (i.e., 

one set of components addressing both safety and security culture in an integrated manner 

or two sets of components, one to address safety culture and another to address security 

culture)? What are the risks and benefits of combining or separating them?
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PROPOSED SAFETY CULTURE COMPONENTS AND GENERIC EXAMPLES 

Work Practices (WP) – As individual contributors, personnel demonstrate ownership for 

safety and security in their day-to-day work activities. 

WP1– (work quality) Personnel ensure that their day-to-day work activities and products meet 

high standards, commensurate with the potential impacts of their work on safety and security, 

by, for example, remaining fit for duty; relying on the guidance contained in procedures, work 

instructions, drawings, databases, and other job aids and reference materials; and using human 

error prevention techniques, such as holding pre-job briefings, performing self- checks, and 

requesting peer checks or reviews. 

WP2 – (individual decision-making) In their day-to-day work, personnel proceed with caution 

when making safety- or security-related decisions, especially when faced with uncertain or 

unexpected conditions, to ensure that safety and security are maintained. For example, when 

making decisions related to a safety- or security-related work product or activity, individuals 

question the validity of their underlying assumptions, identify possible unintended consequences 

that could affect safety and/or security, and obtain appropriate management and/or 

interdisciplinary input and approvals. They do not proceed in the face of uncertainty, 

unexpected conditions, or unsafe circumstances until the conditions or concerns are resolved. 

Work Planning and Control (WPC) – Processes for planning and controlling work ensure 

that individual contributors, supervisors and work groups communicate, coordinate, and 

execute their work activities in a manner that supports safety and security.

WPC1 – (communication and cooperation) Individual contributors and work groups 

communicate and cooperate during work projects and activities to ensure that safety and 

security are maintained. For example, during the execution of work, personnel are kept 

informed of current operational safety or security status; the operational impact of planned and 

on-going work activities; and the potential for interactive effects between activities (including 

nuclear safety/security interface considerations and off-site activities) that are or will be 

performed concurrently. 

WPC2 – (supervisory oversight) Supervisors and managers are accessible and oversee work 

activities and products, including the work of contractors and vendors, to ensure that safety and 

security are maintained. They reinforce safety and security standards in their interactions with 

others. For example, managers and supervisors challenge work activities and work products 

that do not meet their standards. 

Safety Conscious Work Environment (SCWE) – Management maintains a SCWE in which 

personnel feel free to raise concerns without fear of retaliation. 

SCWE1 – (raising concerns) Personnel freely, openly and without fear of retaliation, 

communicate conditions or behaviors that may impact safety or security, and provide complete, 

accurate and forthright information to management, oversight, audit, and regulatory 

organizations without fear of retaliation. 
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SCWE2 – (retaliation) Management investigates claims of harassment, intimidation, retaliation, 

and discrimination consistent with the regulations regarding employee protection. If an instance 

of harassment, intimidation, retaliation or discrimination for raising a safety or security concern 

is identified, management takes corrective actions in a timely manner. 

Problem Identification and Evaluation (PIE) – Management ensures that issues 

potentially impacting safety or security are promptly identified and fully evaluated, 

commensurate with their significance. 

PIE1 – (low threshold/wide scope) Problem identification processes (e.g., raising issues to 

management, the corrective action program – CAP, self- and independent assessments, 

oversight groups, any alternative processes for raising concerns) have a low threshold and wide 

scope for identifying issues. Personnel identify issues promptly, completely and accurately, 

including fitness-for-duty, radiological, industrial, or chemical safety concerns, and nuclear 

safety and security issues. 

PIE2 – (problem evaluation) The licensee thoroughly, accurately, and in a timely manner 

evaluates problems identified from any source (e.g., the CAP, reviews of internal lessons 

learned and lessons learned by others, self- and independent assessments, and alternative 

processes for raising concerns or resolving differing professional opinions), commensurate with 

their safety/security significance. Problems, issues and conditions adverse to quality are 

properly classified and prioritized. Causes and contributors to safety- and security-significant 

problems are accurately identified as well as their extent; and the extent of conditions 

associated with the problems is accurately identified. 

Problem Resolution (PR) – The licensee ensures that safety and security issues are 

promptly addressed and corrected, commensurate with their significance. 

PR1 – (timeliness) The licensee implements actions, in a timely manner, to address 

safety/security issues and adverse trends (both of which may be identified from any source, 

such as the CAP, reviews of internal lessons learned and lessons learned by others, self- and 

independent assessments, input from oversight groups, or alternative processes for raising 

safety and security concerns and resolving differing professional opinions), commensurate with 

their significance and complexity. 

PR2 – (effectiveness) Problem resolutions are effective in addressing cause(s) and preventing 

recurrence of problems and issues affecting safety and security. The licensee evaluates and 

monitors the effectiveness of problem resolutions, commensurate with their significance. 

Resources (R) – The licensee ensures that the personnel, equipment, procedures, and 

other resources needed to assure safety and security are available. 

R1 – (training and qualifications) The licensee ensures that personnel are qualified to perform 

their assigned tasks. For example, training is developed and implemented to ensure 

competence. 
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R2 – (documentation) Procedures, work instructions, design documentation, drawings, 

databases and other job aids and reference materials are complete, accurate and up-to-date. 

Procedures and work instructions are usable, commensurate with the knowledge, skills and 

abilities of personnel. 

Licensee Decision-Making (LDM) – Licensee decisions ensure that safety and security 

are maintained. 

LDM1 – (safety/security first) Management adopts and reinforces the approach that a proposed 

action must be demonstrated to be safe and maintains the facility in a secure status in order to 

proceed, rather than an approach that a proposed action must be demonstrated to be unsafe or 

to compromise facility security in order to disapprove the action 

LDM2 – (potential goal conflicts) Management develops, communicates and implements 

production, cost and schedule goals in a manner which demonstrates that safety and security 

are overriding priorities. 

Accountability (A) – Roles, responsibilities and authorities for safety and security are 

clearly defined and reinforced. 

A1 – (roles and responsibilities) Management ensures that personnel understand their roles and 

responsibilities in maintaining safety and security. Programs, processes, procedures, and 

organizational interfaces are clearly defined and implemented as designed. 

A2 – (leadership for safety/security) Leaders at all levels of the organization consistently 

demonstrate that safety and security are overriding priorities. 

Continuous Learning Environment (CLE) – Management maintains a continuous learning 

environment in which opportunities to improve safety and security are sought out and 

implemented. 

CLE1 – (encouragement to improve) Management encourages individuals to develop and 

maintain current their professional and technical knowledge, skills, and abilities, and ensures 

knowledge transfer. Management also ensures that personnel remain knowledgeable of 

industry standards and innovative practices and encourages personnel to identify opportunities 

to improve safety and security performance. 

CLE2 – (improvement implementation) Personnel at all levels of the organization seek out 

areas for improvements. Changes to standards, programs, processes, and procedures are 

implemented in order to improve safety and security performance. Management and 

supervision challenge behaviors reflecting an attitude that current performance is “good 

enough.”