Safety Culture

Work Processes

Trait Tal

Trait Talk was developed to provide 

you with a better understanding of the 

nine safety culture traits found in the 

U.S. Nuclear Regulatory Commission’s 

(NRC) Safety Culture Policy Statement 

(SCPS) and how they apply to you—

whether you are an NRC employee 

interacting with an external stakeholder, 

an NRC licensee, a vendor or contractor 

employee, an organization interested 

in the safe and secure use of nuclear 

materials, or others involved in nuclear 

safety regulation. Please see page 4 

of Safety Culture Trait Talk for more 

information on the SCPS.

Experience has shown that certain 

personal and organizational traits are 

present in a positive safety culture. 

A trait, in this case, is a pattern of 

thinking, feeling, and behaving that 

emphasizes safety, particularly in goal 

conflict situations, for example, in 

situations where production, schedule, 

or just the cost of effort may conflict 

with doing the job safely. The NRC 

identified nine traits of a positive safety 

culture in the SCPS, although the agency 

recognizes that additional traits may also 

be important. In addition, please note 

that the traits were not developed to 

be used for inspection purposes.

Each Trait Talk includes a fictional 

scenario based on a different 

licensee or community. The scenario 

used in this Trait Talk is based on the 

materials community. 

As you read through Trait Talk, consider 

the following questions: 

1. How does this trait apply to my 

organization? 

2. Are there other attributes and 

examples that better fit my 

organization? 

3. What impact does this trait have on 

the safety culture in my organization? 

4. How does this increase my 

understanding of the safety culture 

in my organization? 

5. How could I improve the performance 

of this trait in my organization?

What Is The Definition Of Work Processes? 

The NRC’s SCPS defines Work Processes as when the process of planning and controlling 

work activities is implemented so that safety is maintained.

Why Is This Trait Important?

The process of designing and controlling work to ensure safety is an important 

part of an organization, and how effectively an organization manages and 

implements their work processes is a reflection of their safety culture. For 

example, effective work processes in a positive safety culture will have a 

well-designed workflow that includes the assignment of responsibilities to 

leaders, work groups, and individuals. Work activities will be prioritized, 

coordinated across workgroups, and communicated effectively. Policies and 

procedures will incorporate the appropriate risk insights and be effectively 

planned, executed, verified, and documented. The rigorous development, 

management and adherence to work processes helps ensure the safe use of 

nuclear materials and reflects a positive safety culture. 

Many organizations operating high-risk technologies (such as in industries 

using nuclear materials) employ collaborative decisionmaking, develop detailed 

procedures, and require verification of steps during procedure implementation 

under normal operations. The development and implementation of 

emergency operating procedures is equally as rigorous. Other high reliability 

organizations, however, may base activities around individual expertise and 

professionalism, autonomy, and rapid team-based response, particularly during 

off-normal conditions. Both perspectives can be important for the design and 

implementation of work processes. For example, organizations may require strict 

adherence to normal and emergency operating procedures. However, flexibility 

may be necessary when responding to off-normal conditions.

The need for procedural compliance during normal or emergency operations 

and the allowance for flexibility and individual autonomy during periods of offnormal conditions pose a dilemma for many organizations. One of the biggest 

management challenges may be how to realize the benefits of both approaches 

given that these two perspectives on controlling work processes can create 

internal inconsistencies. 

Issue 2 July, 2014

One of the traits of a positive safety culture as described in the U.S. Nuclear 

Regulatory Commission’s Safety Culture Policy Statement.
Safety Culture Trai  Tal

WHAT DOES THIS TRAIT LOOK LIKE?

Work Management: The organization implements a 

process of planning, controlling, and executing work activities 

such that nuclear safety is the overriding priority. The work 

process includes the identification and management of risk 

commensurate to the work.

Work is effectively planned and executed by incorporating risk 

insights, job-site conditions, and the need for coordination 

with different groups or job activities. The work process 

appropriately prioritizes work and incorporates contingency 

plans, compensatory actions, and abort criteria as needed. 

Leaders consider the impact of changes to the work scope and 

the need to keep personnel apprised of the work status. The 

work process ensures individuals are aware of the nuclear 

safety risks associated with work in the field, and other parallel 

station activities. Insights from probabilistic risk assessments are 

considered in daily work activities and change processes. Work 

activities are coordinated to address conflicting or changing 

priorities across the whole spectrum of activities contributing to 

nuclear safety. The work process limits temporary modifications. 

Design Margins: The organization operates and 

maintains equipment within design margins. Margins are 

carefully guarded and changed only through a systematic and 

rigorous process. Special attention is placed on maintaining 

fission product barriers, defense-in-depth, and safety-related 

equipment.

The work process supports nuclear safety and the maintenance 

of design margins by minimizing long-standing equipment 

issues, preventive maintenance deferrals, and maintenance 

and engineering backlogs. The work process ensures focus on 

maintaining fission product barriers, defense-in-depth, and 

safety-related equipment. Design and operating margins are 

carefully guarded and changed only with great thought and 

care. Safety-related equipment is operated and maintained well 

within design requirements. 

Documentation: The organization creates and maintains 

complete, accurate, and up-to-date documentation.

Activities are governed by comprehensive, high-quality 

programs, processes, and procedures. Design documentation, 

procedures, and work packages are complete, thorough, accurate, 

and current. Components are labeled clearly, consistently, and 

accurately. The backlog of document changes is understood, 

prioritized, and actively managed to ensure quality. 

Procedure Adherence: Individuals follow processes, 

procedures, and work instructions. 

Individuals follow procedures. Individuals understand and use 

human error reduction techniques. Individuals review procedures 

and instructions prior to work to validate that they are appropriate 

for the scope of work and that required changes are completed prior 

to implementation. Individuals manipulate equipment only when 

appropriately authorized and directed by approved procedures 

or work instructions. Individuals ensure that the status of work 

activities is properly documented. 

2 United States Nuclear Regulatory Commission
Safety Culture Trai  Tal

WHAT IS A SCENARIO IN WHICH THIS 

TRAIT COULD PLAY A ROLE?

Two radiographers were performing nondestructive testing 

operations of pipe welds at a temporary job site using a 2.4 

TBq (65 Ci) iridium -192 radioactive source in a radiography 

camera. In between shots, the first radiographer briefly entered 

the restricted area without conducting a radiation survey. Upon 

exiting the restricted area, he noticed that a piece of equipment 

had fallen onto the guide tube, putting a crimp in the tube. 

After the next shot, without conducting a radiation survey, 

both radiographers entered the restricted area to set up for 

the next operation thinking that the source had been properly 

retracted into the shielded position. However, the crimp in the 

guide tube from the fallen equipment prevented the source 

from retracting back to the shielded position. The second 

radiographer’s ratemeter sounded an alarm indicating that 

radiation exposures greater than the preset amount were being 

exceeded, while the first radiographer’s ratemeter did not alarm. 

Because the first radiographer’s ratemeter did not alarm, they 

both assumed that the second radiographer’s ratemeter was not 

functioning properly. They continued operations and did not 

notify the radiation safety officer of the incident. The radiation 

safety officer became aware of the incident when he identified 

an overexposure of both workers from the personnel dosimetry 

reports that he received a few weeks later. 

There is a high potential dose hazard associated with 

industrial radiographic operations. The process of planning 

and controlling work activities so that safety is maintained 

(work processes) was lacking in this scenario. Although the 

regulations require it, the radiographers did not conduct 

a radiation survey to ensure that the source was properly 

retracted into the shielded position in the camera. The 

radiographers failed to investigate the discrepancy between the 

two ratemeters. Also, the radiographers did not properly follow 

procedures for notification of the radiation safety officer of the 

incident or the potential overexposure because they believed 

that the ratemeter that sounded was faulty.

Thinking about the scenario discussed above, consider the 

following questions:

1. How does this scenario apply to the safety culture 

trait of Work Processes?

2. What kinds of actions and behaviors would have 

reinforced safety as the overriding priority?

3. How could management have handled this 

situation differently?

WHO CAN I CONTACT WITH A 

QUESTION OR SUGGESTION?

The NRC looks forward to continuing to provide you with 

information about the traits of a positive safety culture. If you 

have a question or would like to make a suggestion, please 

contact the U.S. Nuclear Regulatory Commission, Office of 

Enforcement, Safety Culture Team, at external_safety_culture.

resource@nrc.gov.

Issue 2, July 2014 3

Sources of Information:

1 “Why is this trait important?” was derived, in part, 

from a literature review (Agencywide Documents 

Access and Management System (ADAMS) Accession 

No. ML13023A054) prepared by Pacific Northwest 

National Laboratories for the NRC Office of Nuclear 

Regulatory Research. 

2 “What does this trait look like?” was derived from 

the Safety Culture Common Language effort (ADAMS 

Accession No. ML13031A343), under the direction of 

the Office of Nuclear Reactor Regulation. Panelists 

from the NRC, nuclear power industry, and the public 

created attributes of a positive nuclear safety culture, 

and examples of each attribute that a nuclear power 

organization should demonstrate in maintaining a 

positive safety culture. Although these attributes and 

examples were created specifically for the reactor 

community, they may also be applicable to various 

other communities and organizations. For purposes 

of Trait Talk, the examples were partially rewritten to 

increase applicability to nuclear as well as non nuclear 

communities. 

3 “What is a scenario in which this trait played a role?” 

was developed specifically for Safety Culture Trait Talk 

for educational purposes only. The scenario is fictional 

and any resemblance to actual events, people, or 

organizations is purely coincidental.
Safety Culture Trai  Tal

4 United States Nuclear Regulatory Commission

The NRC’s SCPS provides the NRC’s expectation that 

individuals and organizations performing regulated 

activities establish and maintain a positive safety culture 

commensurate with the safety and security significance 

of their activities and the nature and complexity of 

their organizations and functions. Because safety and 

security are the primary pillars of the NRC’s regulatory 

mission, consideration of both safety and security issues, 

commensurate with their significance, is an underlying 

principle of the SCPS.

The NRC’s SCPS applies to all licensees, certificate holders, 

permit holders, authorization holders, holders of quality 

assurance program approvals, vendors and suppliers of 

safety-related components, and applicants for a license, 

certificate permit, authorization, or quality assurance 

program approval subject to NRC authority. In addition, 

the Commission encourages the Agreement States (States 

that assume regulatory authority over their own use 

of certain nuclear materials), their licensees, and other 

organizations interested in nuclear safety to support the 

development and maintenance of a positive safety culture 

within their regulated communities. The SCPS is not a 

regulation; therefore, it is the organization’s responsibility, 

as part of its safety culture program, to consider how to 

apply the SCPS to its regulated activities.

The NRC’s SCPS, which includes the definition of nuclear 

safety culture and the nine traits of a positive safety culture, 

can be found on the NRC’s Safety Culture Web site. The 

Web site includes additional safety culture information, as 

well as the NRC safety culture case studies, which describe 

how the presence or absence of safety culture traits affects 

the outcome of the events.

WHAT IS THE NRC’S SAFETY CULTURE POLICY STATEMENT?

There are many definitions of safety culture. Most of these definitions focus on the idea that in a positive safety culture 

individuals and organizations emphasize safety over competing goals, such as production or costs, ensuring a safety-first focus. 

The NRC’s SCPS defines nuclear safety culture as the core values and behaviors resulting from a collective commitment 

by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment.

Experience has shown that certain personal and organizational traits are present in a positive safety culture. The following traits 

were included in the NRC’s SCPS, although additional traits may also be important in a positive safety culture:

Leadership Safety Values

and Actions

Problem Identification 

and Resolution Personal Accountability

Leaders demonstrate a 

commitment to safety in 

their decisions and behaviors.

Issues potentially impacting 

safety are promptly identified, 

fully evaluated, and promptly 

addressed and corrected 

commensurate with 

their significance.

All individuals take personal

responsibility for safety.

Work Processes Continuous Learning Environment for 

Raising Concerns

The process of planning and 

controlling work activities is 

implemented so that safety 

is maintained. 

Opportunities to learn about ways 

to ensure safety are sought out 

and implemented.

A safety conscious work 

environment is maintained 

where personnel feel free to 

raise safety concerns without 

fear of retaliation, intimidation, 

harassment or discrimination.

Effective Safety 

Communications Respectful Work Environment Questioning Attitude

Communications maintain 

a focus on safety.

Trust and respect permeate the 

organization.

Individuals avoid complacency 

and continually challenge existing 

conditions and activities in 

order to identify discrepancies 

that might result in error or 

inappropriate action.