This regulatory document establishes requirements and guidance for fostering and assessing safety culture. This document contains requirements and guidance for Class I licensees and uranium mines and mills. This document provides more specific requirements and guidance related to safety culture, as an elaboration on the management system requirements contained in the CSA standard CSA N, Management system requirements for nuclear facilities [2].
Class II and nuclear substance licensees have no formal requirements, but are recommended to use Appendix C, and the information of sections 1, 2 and 3. The following provisions of the regulations made under the Nuclear Safety and Control Act are relevant to this regulatory document:. SF-1, Fundamental Safety Principles [3]. SF-1 also underscores the importance of integrating safety and security. Key principles and elements used in developing this regulatory document are consistent with SF-1, as well as national and international standards, guides and practices.
In particular, this regulatory document complements:. Canada is a signatory to the Amendment to the Convention on the Physical Protection of Nuclear Material [11], which obliges member states to apply all Fundamental Principles described therein. One of these concerns security culture. Fundamental Principle F: Security Culture All organizations involved in implementing physical protection should give due priority to the security culture, to its development and maintenance necessary to ensure its effective implementation in the entire organization[11, pg5].
This will provide greater assurance of preventing, detecting, delaying and responding to theft, sabotage, unauthorized access, illegal transfer, or other malicious acts involving a nuclear substance, prescribed equipment or prescribed information use, storage, or transport. As mentioned, security culture and safety culture coexist and mutually reinforce one another.
Analysis of the characteristics and indicators of both cultures demonstrates significant alignment between the two. The differences are few and could be captured within a single embracing culture without significant process and material change to that in place to currently enhance safety culture. The combined approach to fostering these cultures in a mutually supporting framework or policy is anticipated to result in mutually supporting activities that foster and enhance an inclusive culture while reducing duplication of effort.
An approach of integration of these cultures provides an effective and efficient process which reduces the overall resources required for fostering culture and enables a more comprehensive and consistent approach to enhancement of the culture.
Sharing operational experience and knowledge of safety culture development and enhancement methods could assist in enhancing and fostering the security culture characteristics and traits within an existing and mature culture model.
Licensees shall document their commitment to fostering safety culture in their governing documentation. Licensees are responsible for fostering a healthy safety culture through promoting and reinforcing a collective commitment to safety that is responsive to the risk and complexity of the licensed activities.
To achieve this, licensees should use all available avenues, including a reliance on governing documentation e. This helps provide context to the requirements concerning safety culture found in CSA standard CSA N, Management system requirements for nuclear facilities [2].
The highest level of governing documentation should make safety the utmost priority — overriding the demands of production and project schedules and forming a basis for promoting a healthy safety culture, including a questioning attitude and a commitment to excellence in the performance of all activities important to safety. Governing documentation may describe the leadership role s encompassing the highest levels of responsibility for safety matters, as well as areas where workers share safety responsibility.
Leaders may use governing documentation to demonstrate key safety behaviours to workers, while ensuring workers understand their defined safety responsibilities, goals and performance objectives. Promoting and reinforcing a collective commitment to safety includes the continual improvement and practical use of all governing documentation.
Monitoring safety culture provides management the means as to how safety manifests itself in everyday discussions, decisions and actions. Licensees have many processes and activities providing insight on safety culture, some of which are listed below. Where monitoring activities identify improvement opportunities, consideration should be given to prioritizing and implementing these improvements.
Examples of safety culture monitoring data sources which management can leverage for discussion and analysis include:.
For licensees undertaking safety culture assessments, ongoing monitoring offers a complementary method for monitoring safety culture health between safety culture assessments. For example, these monitoring activities can inform future assessments, such as through trending indicators from previous safety culture assessments. Additionally, information from monitoring activities conducted can be analyzed and understood in the context of safety culture assessment results.
For example, insight from completed assessments may suggest new monitoring activities, or be used to refine existing monitoring activities. The three-stage safety culture maturity model described in appendix B is a useful tool to initially establish a safety culture maturity baseline and to monitor changes over time. Safety culture maturity progress can then be tracked with suitable records. Licensees shall conduct comprehensive, systematic and rigorous safety culture assessments at least every five years.
A safety culture assessment involves systematically gathering, reviewing and analyzing culturally relevant data, as well as identifying and implementing improvement actions. This is to promote safety, learn about organizational factors affecting safety, and to continually seek an understanding of how culture operates within the organization.
Principle 2 reads "Safety culture is influenced by external and internal factors including all workers". Organizations engaged in complex work involving many interdependent workers and processes can benefit from safety culture assessments. Principle 3 reads "Safety culture is complex and changes over time. A safety culture assessment provides an opportunity for organizational leaders to actively promote and foster a healthy safety culture.
Their support for engaging workers in open discussions, decisions and actions on safety ensures an environment of continual safety improvement. Shared space is a critical aspect of safety culture assessments; these assessments depend on the free flow of views and opinions in an environment of trust. Information on the concept of shared space, an important consideration in undertaking safety culture assessments, can be found in IAEA Safety Report Series 83, Performing Safety Culture Assessments, section 2.
Additional information on safety culture assessments can be found in section 3. Adhering to a set of criteria ensures that safety culture assessments are consistent and subsequent findings are reliable over time.
The following criteria apply to safety culture assessment approaches the overall means and methods the specific data collection and analysis tools. Although these are intended for assessments conducted in large organizations, any size or type of licensee may use them to develop, improve and refine safety culture assessments.
There are different approaches to conducting a safety culture assessment. It may be conducted independently by an external organization or contractor or as a self-assessment by workers within the organization. A safety culture assessment is generally a hybrid of these two types, using a blended team of external participants and workers who represent all areas of the organization.
Organizations that hire a contractor to conduct the assessment have the advantage of increased objectivity over the course of an assessment.
Consideration may be given to ensuring that the experience and insights gained from the assessment are retained within the organization. While self-assessments risk being less objective, they are more adaptable and offer learning and development opportunities for workers.
Safety and security are integrated goals for any nuclear facility. Although safety and security culture assessment methods are generally similar, a security culture assessment places additional emphasis on mitigating the risk likelihood and consequences of deliberate malicious acts.
As a result, the comprehensive safety culture reference framework Appendix A has three indicators specific to security culture: the belief of a credible threat, employee screening practices and ensuring sensitive information is classified and controlled.
While safety culture assessments could simultaneously assess security culture, licensees may choose to undertake independent assessments to assess security culture. Planning the assessment involves applying the chosen assessment method and associated framework, as well as finalizing details of how data will be collected, analyzed, interpreted and reported. Understanding that safety culture can change over time Principle 3 will help an organization to maintain and improve safety.
An overview of how the safety culture assessment relates to relevant organizational programs and practices e. The description of the scope can provide a rationale for the organizational areas included in the assessment e. Documents related to the planning phase can include organizational context size, risks, complexity considered in determining the breadth and depth of data collection and analysis, as well as an overview of each phase of the assessment including associated timelines.
Selection of an appropriate assessment team is essential to ensuring the continual development and improvement of the assessment process and outputs.
A best practice is to include representatives from another licensee organization or industry on the assessment team. Assessors involved in peer audits have more in-depth industry knowledge, and may also have an advantage relating to interviewees and interpreting data with greater objectivity. The overall team may reflect a balanced representation of the above, including consideration of worker demographics age, gender, seniority.
The assessment team lead s may be experienced and knowledgeable in safety culture, monitoring of safety culture, and assessment and improvement methods.
During the assessment, the team lead s may make decisions about all aspects of the assessment plan e. Documents related to team selection can include rationales of decisions regarding team membership. Licensees should develop and implement a communications strategy for the assessment, and consider proactively engaging workers and leaders throughout the assessment process.
Licensees can consider the timing and frequency of communications, potential communication vehicles, and how to tailor messaging to specific audiences. Communication with internal stakeholders may take place throughout the safety culture assessment, and the resulting planning and implementation of improvement initiatives.
Senior management should promote organization-wide participation in all aspects of the assessment via surveys, interviews and other assessment tools. For security culture, the communications plan must consider that some information is security sensitive; however, for the benefit of greater awareness, all aspects can be shared broadly even if this requires some incidents or lessons learned to be generalized.
A communications strategy can, at the various stages of an assessment and follow-up activities, include a summary of the assessment method, findings and improvement plans. The information should be shared with the following internal stakeholders to the extent possible:. Licensees can expect and encourage feedback from stakeholders.
Feedback can provide insight into the culture of the organization, and can be used to refine the communications strategy.
Documents related to the communication strategy can include the communications plan. Records related to the communications strategy can include the communications themselves. Principle 5 reads "Safety culture assessment and improvement activities are informed by a defined framework of key characteristics known to reflect a healthy culture". A safety culture framework provides a basis for the systematic review of safety culture against a defined set of characteristics.
It also provides a common vocabulary to facilitate communications, and aids in developing improvement plans to address the shared perceptions and attitudes of workers.
There are several culture frameworks currently in use across a variety of organizations and licensee contexts. Licensees should ensure that the safety culture assessment framework is mapped against the five safety culture characteristics see Appendix A of this document.
The assessment can address the shared beliefs and attitudes on safety and security — at all levels and functional areas of the organization. Assessments of safety culture may include specific language and data-gathering tools tailored to specific topics and workers. The primary methods used in safety culture assessments are well established social science tools being document review, surveys, focus groups, interviews and observations.
One key area of this work is participant confidentiality. Participant confidentiality is crucial in gaining information from participants in safety culture assessments, and the assessment team should take precautions e. Additional information on methods can be found in IAEA Safety Report Series 83, Performing Safety Culture Assessments, all of section 5 Methods , which explains the five data collection methods, including their limitations and risks [1, pg ].
The primary analysis method in safety culture assessments is a thematic analysis. Rather than a linear exercise to compile information to build a case, the analysis is iterative, using parallel streams of information to explore cultural influences. The focus is to analyze the collected data to understand the culture as opposed to exclusively measuring adherence to the framework. During the assessment, the team may need to refine its scope in order to identify possible patterns that warrant additional attention, data collection and analysis.
Emergent themes identified throughout the assessment may lead to supplementary analysis and reflection. The assessment team should periodically review assessment objectives such as those listed in section 3. Documents related to the assessment method and associated safety culture framework may include a discussion of how the data collection and analysis techniques applied are comprehensive, systematic and rigorous.
Assessment findings may concentrate on one specific area or topic, and should be based on organization-wide data. A description of the data and analysis can be included with each finding. Any insights that the team can provide on the underlying cause of the findings will help develop the improvement plan. Documents related to summarizing the findings may include the executive summary, a description of the assessment process, and the final assessment report.
Licensees should respond to assessment results by developing and implementing an improvement plan. This can include an analysis of the assessment results and offer opportunities for organizational leaders to reflect on these results. The process of translating assessment findings and insights into actions may be integrated into existing programs and processes, such as problem identification and resolution systems; corrective and preventive action programs; leadership critical reflective conversations about safety culture; safety culture monitoring panels; and other organizational improvement processes.
The licensee may articulate or reaffirm this vision in subsequent communications; the characteristics of a healthy safety culture can help articulate and refine this vision, which may be compared to the current safety culture state based on the assessment. Any gaps will inform management as to where to focus the improvement plan, and identify positive characteristics that should be protected and fostered.
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