What We Heard Report – DIS-12-07

Safety Culture for Nuclear Licensees

Preamble

Discussion papers play an important role in the selection and development of the regulatory framework and regulatory program of the Canadian Nuclear Safety Commission (CNSC). They are used to solicit early public feedback on CNSC policies or approaches.

The use of discussion papers early in the regulatory process underlines the CNSC's commitment to a transparent consultation process. The CNSC analyzes and considers preliminary feedback when determining the type and nature of requirements and guidance to issue.

Introduction

Experience in the international nuclear industry and in other industries over the past several decades has demonstrated the importance of a healthy safety culture in maintaining the safety of workers, the public and the environment. The CNSC has been active in this area, working with the nuclear industry and the international nuclear community to understand and promote the importance of safety culture. The CNSC continues to work at promoting licensees' engagement in and commitment to a healthy safety culture in their respective organizations.

A healthy safety culture is a key factor in reducing the likelihood of accidents. Creating and maintaining an environment conducive to a healthy safety culture is an ongoing process, requiring the attention of licensees and the CNSC.

In discussion paper DIS-12-07, Safety Culture for Nuclear Licensees the CNSC sets out a strategy for safety culture in the nuclear industry. The following summarizes the results of the CNSC's preliminary public consultation on this discussion paper.

Consultation process

The CNSC issued this discussion paper for public comment on September 5, 2012 for a 128-day comment period. The discussion paper sought input from stakeholders and the general public.  An invitation to comment on the discussion paper was posted on the CNSC's website, a notification was posted on the CNSC's Facebook page, and an information bulletin was forwarded to the CNSC's stakeholders. The notice of the consultation was also posted on the Government of Canada's "Consulting with Canadians" website.

On January 29, 2013 the CNSC posted the comments it received on its website, and issued an invitation to provide feedback for a 14-day period. The CNSC received a total of 17 submissions from stakeholders over the course of both comment periods.

This report provides a summary of the key comments received during consultation.

Summary of stakeholder comments

• There was general support for the industry to continue to "foster safety culture" and recognition of its impact towards nuclear safety.
• Several comments expressed strong support for the CNSC to actively engage in further consultation with industry on the development of the way forward.
• Several respondents communicated a general agreement with the principles and intent of CNSC's organization and management (O&M) review method and the discussion paper Appendix C (Proposed Safety Culture Self-Assessment Guidelines).
• There were several comments approving of a graded approach for smaller licensees while most recognized more work is required to develop specific graded requirements for each licensee type.
• Some respondents rejected the use of established behavioural-based tools citing a preference for existing industry self-assessment tools and guidelines.
• There was opposition to specific expertise requirements for team members of safety culture self-assessments.
• Licensee comments suggest the CNSC's oversight of safety culture should focus on three key concepts: understanding, dialogue and flexibility in order to align with International Atomic Energy Agency (IAEA) TECDOC 1707 Regulatory Oversight of Safety Culture.
• There was particular emphasis on providing flexibility to current licensee approaches including the use of the Institute of Nuclear Power Operators (INPO) traits/attributes and the IAEA safety culture characteristics.
• There was a general recognition and acceptance of previous and current INPO/World Association of Nuclear Operators (WANO) guidelines relating to fostering a healthy safety culture.
• Of note is the low participation rate by licensees of small nuclear facilities, licensees of Class II installations and licensees of nuclear substances and radiation devices.

Next steps

The CNSC will develop and publish a new regulatory document on safety culture. This REGDOC will be applicable to all CNSC licensees and will take into consideration the application of graded approaches. 

The regulatory document will detail requirements and guidance in support of licensees' fostering a healthy safety culture in their respective organisation. The REGDOC will clarify the language associated with safety culture and include a CNSCs definition and framework. Safety culture self-assessments guidance will also be included in the REGDOC.

The regulatory document will provide a degree of flexibility, allowing licensees to adapt the guidance to their own needs.

The CNSC will engage with licensees on the topic of safety culture to communicate the proposed graded approach that would be applicable to the different types of licensees.

In parallel to the activities noted above, the CNSC will continue to develop its safety culture oversight across its current regulatory activities.

The proposed path forward will add clarity for licensees with regard to the CNSC's safety culture expectations and its oversight approach, while remaining flexible to enable licensees to develop customized solutions in support of fostering a healthy safety culture.

Stakeholders will be provided with opportunities to further engage the CNSC in the development process of the proposed regulatory document.