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Overview of the Development of the Safety Culture Characteristics 

The proposed U.S. Nuclear Regulatory Commission (NRC) agency-wide safety culture 

characteristics retain the concepts of the Reactor Oversight Process (ROP) safety culture 

components but were revised to be generically applicable; include explicit reference to security 

concerns; streamlined; and clarify the wording used to describe some of the concepts. Further 

discussion of the changes follows. 

 

Applicability. Because the 13 safety culture components were tailored for use in the ROP, some 

of the terminology used in the ROP component descriptions is not applicable to the other, 

non-reactor organizations and processes the NRC also regulates. For example, one ROP 

component refers to the licensee’s “corrective action program” because power reactor licensees 

in the U.S. have established sophisticated, formal processes and programs for identifying, 

evaluating and resolving nuclear safety issues. By contrast, a small industrial radiography firm 

typically would not have the resources to establish a formal program. However, the overarching 

principle, which is that an organization with a healthy safety culture identifies, evaluates and 

resolves safety and security problems, applies to large power reactors and small firms as well. 

Therefore, the agency-wide safety culture characteristics refer to identifying, evaluating and 

resolving problems affecting safety and security but do not use the term “corrective action 

program.” Instead, the agency-wide safety culture characteristics include a Problem 

Identification and Evaluation characteristic and a Problem Resolution characteristic. 

Security. For consistency with the NRC’s mission and increased focus on the safety/security 

interface, each of the safety culture characteristics refers to “safety and security” where only 

“safety” was previously mentioned. For example, the ROP Continuous Learning Environment 

component is described as “the licensee ensures that a learning environment exists.” The 

related agency-wide safety culture characteristic is described as “management maintains a 

continuous learning environment in which opportunities to improve safety and security are 

sought out and implemented.” The unique aspects of security would be addressed, as 

appropriate within the examples or aspects for each characteristic. 

Streamlined. In accordance with Inspection Manual Chapter 0305, the ROP inspection staff 

uses nine of the 13 safety culture components when implementing the baseline inspection 

program. Four of the components are “reserved” for use only during supplemental inspections 

when a licensee’s performance has declined. When the staff had the opportunity to consider 

the four reserved components in inspection activities, it appeared that some of them were 

redundant with the safety culture concepts captured in the nine baseline components and their 

associated aspects. For example, the staff noted that the extent to which a licensee implements 

improvements that are identified through Operating Experience (OpE) reviews or Self- and 

Independent Assessments (OpE and assessments are two of the nine baseline ROP 

components) is an indication of the extent to which the licensee is maintaining a Continuous 

Learning Environment (one of the reserved components). Alternatively, if a licensee identifies 

problems or weaknesses from OpE reviews or assessments and resolves them, then the use of 

OpE and assessments can be viewed as indicating that the licensee’s processes for identifying 

and resolving problems are effective (the ROP Corrective Action Program component). 

Power reactor licensees and other NRC-regulated entities use a variety of means to identify 

problems as well as opportunities for improvement. The overarching safety culture concepts 

are that the licensee identifies problems and resolves them and seeks out and implements 

opportunities for improvement no matter what means are used to achieve these ends. 

Therefore, the agency-wide set of safety culture characteristics does not include OpE and 
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Self- and Independent Assessments as separate characteristics, although they continue to be 

meaningful examples (aspects) of a strong safety culture in nuclear power plants. Similar 

considerations led to the elimination of Safety Policies and Organizational Change Management 

as safety culture characteristics in the revised set. 

Clarified. The staff noted that the wording of some of the ROP components could be improved 

to more fully or accurately communicate the overarching concept. For example, the work 

practices component is described as “personnel work practices support human performance,” 

which does not fully capture the intended scope of this component. Although using human 

performance enhancing tools, such as self- and peer-checking, following procedures and 

holding pre-job briefs, provide evidence of a healthy safety culture, there are additional attitudes 

and behaviors at the individual contributor level that provide equally diagnostic information 

about the strength of the organization’s safety culture. These may include not only following 

procedures but also taking responsibility to ensure that an error found in a procedure is 

corrected; not only re-checking one’s calculations when performing an engineering analysis but 

also questioning one’s underlying assumptions and the data on which the analysis is based; or 

not only wearing one’s personal protective equipment but also insisting that co-workers also 

protect themselves. Therefore, to more accurately capture the intended broader scope of these 

safety culture-related attitudes and behaviors, the description of the ROP work practices 

component was rewritten as the following safety culture characteristic: “As individual 

contributors, personnel demonstrate ownership for safety and security in their day-to-day work 

activities.” 
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Changes from the 13 ROP Safety Culture Components to the 9 draft Policy Statement Safety Culture 

ROP Safety Culture 

Components 

Proposed Safety Culture 

Characteristics 

Comments

Decision-Making - Licensee decisions demonstrate that nuclear safety is an overriding priority. 

Licensee Decision-Making – Licensee decisions ensure that safety and security are maintained. 

Re-named to clarify that the decisions to which the refers are decisions at the organizational level, ratdecisions made by individuals, for example, on the making in day-to-day work activities would be an aPractices characteristic. Deleted “nuclear safety is because that is the basic definition of a healthy safphrase is too broad. In addition, the ROP componaddress security. Replaced with “ensure that safemaintained” to describe the desired outcomes of li

Resources – The licensee ensures that personnel, equipment, procedures, and other resources are available and adequate to assure nuclear safety. 

Resources – The licensee ensures that the personnel, equipment, procedures, and other resources needed to assure safety and security are available. 

Minor revision to eliminate “adequate” and replace needed to assure...” for clarity. Added reference maintain security. 

Work Control - The licensee plans and coordinates work activities, consistent with nuclear safety. 

Work Planning and Control – 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. 

Expanded to clarify that the focus of the characteriinteractions between individuals and work groups tensure that work is planned, coordinated and comAdded reference to security. 

Work Practices - Personnel work practices support human performance. 

Work Practices – As individual contributors, personnel demonstrate ownership for safety and security in their day-to-day work activities. 

Revised to clarify that this characteristic refers to tsecurity are everyone’s responsibility”) and behavibut are not limited to, the use of human performanin their day-to-day work activities. Added referenc

Corrective Action Program - The licensee ensures that issues potentially impacting nuclear 

Problem Identification and Evaluation – Management ensures that issues potentially 

Eliminated reference to the CAP because not all Nhave formal corrective action programs. Divided thto clarify that problem identification/evaluation and 
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ROP Safety Culture 

Components 

Proposed Safety Culture 

Characteristics 

Comments

safety are promptly identified, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their significance. 

impacting safety or security are promptly identified and fully evaluated, commensurate with their significance. Problem Resolution – The licensee ensures that safety and security issues are promptly addressed and corrected, commensurate with their significance. 

organizational behaviors. Combined problem idenevaluation because evaluation is typically required extent/nature of a problem or issue is identified. Adsecurity to both characteristics. 

Operating experience - The licensee uses operating experience (OE) information, including vendor recommendations and internally generated lessons learned, to support plant safety. 

 Not retained as a separate characteristic. The rev

operating experience and internally generated lessin the identification of problems and issues as well organizational improvement. Depending on how it OE can be viewed as an aspect (specific exampleidentification/evaluation characteristic or the continenvironment characteristic. Further, the availabilitresources necessary to collect, review and apply it regulated entities, so this component would not be particularly as written (i.e., “plant safety”). Thereforetained as an aspect of other safety culture charaapplicable. 

Self- and Independent Assessments - The licensee conducts self- and independent assessments of their activities and practices, as appropriate, to assess performance and identify areas for improvement. 

 Not retained as a separate characteristic. As discu

the OE component, self- and independent assessmidentify problems and opportunities for improvemewith respect to OE, not all NRC-regulated entities resources to conduct or sponsor self- and indepenTherefore, this concept also would no longer be a but could be used by a program office as an aspeccharacteristic, where applicable. 
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ROP Safety Culture 

Components 

Proposed Safety Culture 

Characteristics 

Comments

Environment for Raising Concerns - An environment exists in which employees feel free to raise concerns both to their management and/or the NRC without fear of retaliation and employees are encouraged to raise such concerns. Preventing, Detecting, and Mitigating Perceptions of Retaliation - A policy for prohibiting harassment and retaliation for raising nuclear safety concerns exists and is consistently enforced. 

SCWE – Management maintains a work environment in which personnel feel free to raise concerns without fear of retaliation. 

Combined the two ROP components into a single renamed it “Safety Conscious Work Environment” and simplicity. Included reference to managementcreating and maintaining an open environment for with the Commission’s policy statement [insert cite portions of the two ROP components would be retcharacteristic and tailored to the specific processeenvironments of non-reactor regulated entities. 

Accountability - Management defines the line of authority and responsibility for nuclear safety. 

Accountability – Roles, responsibilities and authorities for safety and security are clearly defined and reinforced. 

Removed the concept of a “line of authority and remay not apply to some NRC-regulated entities. Adsecurity. 

Continuous Learning Environment - The licensee ensures that a learning environment exists. 

Continuous Learning Environment – Management maintains a continuous learning environment in which opportunities to improve safety and security are sought out and implemented. 

Expanded the description for greater clarity. Adde

Organizational Change Management - Management uses a systematic process for planning, coordinating, and evaluating the safety impacts of decisions related to major changes in organizational structures and functions, 

 Not retained as a separate characteristic because 

applicable to all NRC-regulated entities, particularlWhere applicable, it would be retained as an aspeDecision-Making characteristic. 
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ROP Safety Culture 

Components 

Proposed Safety Culture 

Characteristics 

Comments

leadership, policies, programs, procedures, and resources. Management effectively communicates such changes to affected personnel. Safety Policies - Safety policies and related training establish and reinforce that nuclear safety is an overriding priority. 

 Not retained as a separate characteristic because 

concepts already included in the other characteristgenerically applicable.