NRC Safety Culture Worksh

NRC Safety Culture Worksh

Lynne Fairobent

Manager of Legislative and Regulatory Aff

American Association of Physicists in Medi

September 28, 2010
AAPM

• Is the premier premier organization in medical organization in medical

physics; a broadly-based scientific andprofessional discipline encompassing p

discipline encompassing p

principles and applications in biology anmedi i c ne wh i i i t d t

hose mission is to advance t

science, education and professional pra

of medical physics.

• Represents over 7,300 medical physicist
Apparent Agreement on the Ba

Def ff l inition o

f Sa

fety Culture

• ‘‘Nuclear Safety Culture is the core valu

Nuclear Safety Culture is the core valu

and behaviors resulting from a collectivcommitment b l d d i di id l by lea

ders an

d indi

viduals 

emphasize safety over competing goals 

ensure protection of people and theenvironment.’’
Background

• The basic definition and traits develope• The basic definition and traits develope

during the February workshop and contin thS b h d l i he September 17th Federal Register 

appropriate for the NRC, its licensees a

certificate holders, and all of the other stakeholders.
One Size Does Not Fit All

One Size Does Not Fit All

• Although it is laudable to try and have a • Although it is laudable to try and have

a

single definition that can apply to allcategories of licensees, i i ll t 

is equall

y

important to note that implementatio

the traits and behaviors as they apply tthe specific licensee categories may dif

specific licensee categories may dif
Differences to

Specifl f ic Application of Use

• In medical uses nuclear safety does not • In medical uses, nuclear safety does not

preempt or override patient safety espe

in emergency in emergency situations For example situations. For example, lsaving measures should always pre-emneed to d i i ih decontaminate a patient in the

emergency room.
Path Forward Path Forward

• NRC must define: NRC must define:

– the characteristics that, in the agencyview, define a positive safety culture an

define a positive safety culture, an

– the metrics for assessing a licensee’sprogram agai t th h t i ti inst those characteristics.

• Without specific definition, the interpre

of a positive safety culture remainssubjective.
Next Steps Next Steps

• AAPM believes the next critical step is to

develop specific actionable characteristics behaviors specific to each license categor

• This next level or “third tier,” once develop

will provide more meaning in the individulicensee category and relate the generalcharacteristics to specific behaviors andi di i n cat ons of f l ih f a strong safety culture in tha

particular field.
AAPM Recommendations AAPM Recommendations

• NRC must work closely with the Agreem

NRC must work closely with the Agreem

States to prioritize this effort relative to regulatory issues.

• In the absence of adequate Agreement 

suppor

t f thi i iti ti th f t l

for this initi

ative, the sa

f

e

ty cul

concept would potentially only be appl

approximately twenty percent of thebyproduct materials users nationwide.
AAPM Recommendations AAPM Recommendations

• NRC should conduct workshops, in NRC should conduct workshops, in

coordination with the Agreement Statespecific to each category of licensee to 

to each category of licensee to 

NRC’s approach to safety culture and enth t a

t it t ti l l d t 

its expec

t

ations are clearly un

ders

t

• These should be specific roundtable

discussions and not simply presentationprofessional society conferences.
AAPM Recommendations AAPM Recommendations

• Guidelines explaining NRC expectations Guidelines explaining NRC expectations

regarding adoption of Safety Culture vamust be promulgated be promulgated.

• If stakeholders do not understand how t

il t mp emen

t S f t C lt d h 

S

a

f

e

ty 

C

ulture, an

d

have me

to use internally to determine the

effectiveness of their efforts, attention minimal.
AAPM Recommendations AAPM Recommendations

• NRC should refrain from including safety NRC should refrain from including safety

culture issues in inspection reports andassessments until such time that the fin

until such time that the fin

policy has been issued, relevant coordinwith th l t d it d A 

the regula

t

e

d community an

d

Agre

States has occurred, and implementingguidance is issued to ensure that NRC’sexpectations are clear.
AAPM Recommendations AAPM Recommendations

• That the NRC’s safet

y culture scheme be

clarified that if medical licensees candemonstrate the extent to which currentrequirements and practice meet the “intethe NRC safety culture policy”, they should have to use methods and terminologydeveloped by NRC staff who might haveli i d m te

d und di f h d d derstanding o

f met

h

o

ds an

d

requirements currently used by healthcareorganizations.
Questions?