SAFETY CULTURE

Environment for 

Raising Concerns

TRAIT TALK

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 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 

nuclear research facilities. 

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 Environment 

For Raising Concerns? 

The NRC’s SCPS defines Environment for Raising Concerns as maintaining a safety-conscious 

work environment where personnel feel free to raise safety concerns without fear of retaliation, 

intimidation, harassment, or discrimination.

Why Is This Trait Important?

Fostering an environment for raising concerns is an important attribute of a positive 

nuclear safety culture. Organizations should have a work environment where employees are 

encouraged to raise safety concerns and where those concerns are reviewed promptly, given the 

proper priority based on their potential safety significance, and appropriately resolved, with 

timely feedback to the originator of the concerns and to other employees as appropriate. 

Employees should feel free to raise safety concerns to their management without fear of 

harassment, intimidation, retaliation, or discrimination. The organization is prohibited by law 

from taking adverse retaliatory actions against employees because they raised concerns. When 

allegations of discrimination or retaliation arise, the appropriate level of management must be 

involved to review the facts, evaluate or reconsider the action, and, where warranted, remedy 

the matter. In addition to the hardship caused to the individual employee, the perception by 

fellow workers that raising concerns has resulted in retaliation can generate a chilling effect 

that may discourage other workers from raising concerns. Any reluctance on the part of 

employees to raise concerns can be detrimental to nuclear safety.

The organization should clearly identify the processes that employees may use to raise 

concerns, such as discussing issues with their supervisor or filing deficiency reports for 

problem identification and resolution. However, it is important to recognize that some 

employees may not always be comfortable raising concerns through the normal channels, 

such as with their immediate supervisor. From a safety perspective, no method of raising 

potential safety concerns should be discouraged. Therefore, the organization should focus on 

achieving and maintaining an environment where employees feel free to raise their concerns 

directly to their supervisors, as well as ensuring that alternate means of raising and addressing 

concerns are accessible, credible, and effective. These alternative approaches may include an 

“open-door” policy that allows the employee to bring a concern to a higher-level manager, an 

ombudsman program, or an employee concerns program.

An organization that reinforces an environment for raising concerns typically has welldeveloped systems for prioritizing problems and directing resources, effective communications 

for openly sharing information and analyzing the root causes of identified problems, and 

management that promotes employee confidence in raising and resolving concerns.

Issue 5 December, 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 TRAIT TALK

WHAT DOES THIS TRAIT LOOK LIKE?

Safety Conscious Work Environment (SCWE) 

Policy: The organization effectively implements a policy 

that supports individuals’ rights and responsibilities to 

raise safety concerns and does not tolerate harassment, 

intimidation, retaliation, or discrimination for doing so. 

Individuals feel free to raise nuclear safety concerns without 

fear of retribution, with confidence that their concerns 

will be addressed. Executives and senior managers set and 

reinforce expectations for establishing and maintaining a 

safety-conscious work environment. Policies and procedures 

reinforce that individuals have the right and responsibility 

to raise nuclear safety concerns and define the responsibilities 

of leaders to create an environment in which individuals 

feel free to raise safety concerns. Leaders are trained to take 

ownership when receiving and responding to concerns, 

recognizing confidentiality if appropriate, and ensuring they 

are adequately addressed in a timely manner. Individuals are 

trained that behaviors or actions that could prevent concerns 

from being raised, including harassment, intimidation, 

retaliation, or discrimination, will not be tolerated and are 

violations of law and policy. All claims of retaliation are 

investigated and any necessary corrective actions are taken in 

a timely manner, including actions to mitigate any potential 

chilling effect. 

Alternate Process for Raising Concerns: The 

organization effectively implements a process for raising and 

resolving concerns that is independent of line management 

influence. Safety issues may be raised in confidence and are 

resolved in a timely and effective manner. 

Executives establish, support, and promote the use of 

alternative processes for raising concerns and ensure 

corrective actions are taken. Leaders understand their 

role in supporting alternate processes for raising concerns. 

Processes for raising concerns or resolving differing 

professional opinions that are alternatives to the corrective 

action program and operate outside the influence of the 

management chain are communicated and accessible to 

individuals. Alternative processes are independent, include 

an option to raise concerns confidentially, and ensure these 

concerns are appropriately resolved in a timely manner. 

Individuals receive feedback in a timely manner. Individuals 

have confidence that issues raised will be appropriately 

resolved. Individuals assigned to respond to concerns have the 

appropriate competencies. 

2 United States Nuclear Regulatory Commission

Experimental gamma irradiation source similar to the source referenced in the Trait Talk example.
SAFETY CULTURE TRAIT TALK

WHAT IS A SCENARIO IN WHICH 

THIS TRAIT COULD PLAY A ROLE?

A research scientist in the nuclear physics program at a 

research laboratory moved a high activity radioactive source 

to temporary storage area of the irradiation pool. He was 

not aware that, three days prior to moving the source, 

maintenance workers had removed a small section of the 

concrete shielding from the irradiation pool wall. This 

allowed the source to emit radiation through the unshielded 

section of the pool wall and create an unplanned high 

radiation area. The procedures for moving the source did not 

clearly require cross- checking with maintenance activities.

During the investigation of this incident, the research 

scientist told the investigator that he previously raised 

concerns to his supervisor about the adequacy of procedures 

for moving the source and ensuring that the source was 

appropriately shielded. Further, he noted that he had told 

the supervisor on numerous occasions that many of the 

procedures dealing with the safety of laboratory activities 

may be insufficient. After this incident, he told the supervisor 

that he was going to notify the facility administration about 

his concerns and the supervisor’s lack of response. The 

supervisor told the scientist that because of significant budget 

cuts in research programs, and subsequent reduction in staff, 

he did not have the resources to review and revise all of the 

procedures and he did not want to draw any more attention 

to the program. In addition, the supervisor said that if the 

scientist raised this concern with the administration, his 

“future employment” would be discussed. A few days later, 

the scientist discussed his concerns with the administration 

officials, and two weeks later, the scientist was laid off due to 

budget cuts. The remaining research staff was aware of the 

circumstances surrounding their colleague’s termination. The 

supervisor told staff members that any concerns they have 

should never be “taken up the chain of command.”

Continuing budget cuts and their colleague’s termination 

have resulted in the remaining research staff members 

being concerned about their jobs, the future of the research 

programs, and their safety while working at the research 

facility. Staff members have expressed reluctance to raise any 

concerns to their supervisor or the administration, and they 

continue to be worried about the adequacy of procedures 

and policies. This chilling effect prevents the staff from 

feeling free to raise nuclear safety concerns without fear of 

retaliation, and weakens the facility’s safety culture. 

 Thinking about the scenario discussed above, consider the 

following questions:

1. How does this scenario apply to the safety 

culture trait Environment for Raising Concerns?

2. What kinds of actions and behaviors would 

have reinforced safety as the overriding priority?

3. How could this situation have been handled 

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 5, December 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, and from the NRC Regulatory Issue Summary 

2005-18, “Guidance for Establishing and Maintaining A 

Safety Conscious Work Environment” (ML052220239).

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 TRAIT TALK

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.