NRC’s Safety Culture Trait Talk: Raising a Safety Concern

Bottom line, how your managers answers your safety concerns wholly depends on the difference of power between you and your boss. Generally how the hierarchy works, is the bottom line management filters out the troubling concerns of lower level employee to their managers. How the lower mangers get promoted is if they protect their bosses. To tell you the truth, confidentially and anonymity gives you the weakest hand against the powerful. I wonder why the NRC portrays this in your weakest hand...doing the bidding of the nuclear industry.

Safety Culture trait Talk: Environment For Raising Safety Concerns

Safety Culture trait Talk: Environment For Raising Safety Concerns

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 must not take adverse actions, such as retaliation and discrimination, against employees who have raised concerns, because it is unacceptable and potentially unlawful. 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 well-developed 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.

I am surprised the NRC’s tack on safety concern for everyone isn't “ transparency” and your safety concerns would be “guaranteed by the government to be “put in an non erasability in-house log or outside log”. To even think the NRC is talking anonymity and confidentiality says the government is powerless to stop safety concern intimidation. The NRC fears and knows there is widespread retaliations going on ...or a widespread fear of retaliation by lots of employee. All your bosses and executives (licensees and NRC) should be big enough to handle a safety concern on a totally open venue. A byproduct with watching this kind of full throated conflict in an open venue is the outsiders gains irreplaceable trust and respect of the Nuclear industry.

The NRC’s Adams document system is a credible and trustworthy log type vehicle. There are other forms of electronic and internet public logs. A newspaper or other news media is another form of a log. The limitation with the NRC internet Adams is it is under the control of the NRC. You have to be aware when your information is under your total control or when other powers control your message. But the NRC will let you put what you need on there.

Course, there is always your own blog. From my days, it is just amazing how much more miraculous inter-connectivity we have. With less inter-connectivity, means a smaller group of people wholly get to control your message.

Here is another thumb rule, those you trust and love the most will hurt you the quickest and deepest.  

Transparency is the tool that equalizes power and influence between the powerless and the powerful. It puts you on a fair playing field.

You won’t get much credit for this way…but I would put your information on a type of a log. I put my e-mail and phone number on the top of my blog for this reason. If you just want to get the problem fixed…just throw me some documents and information about your safety concern. I’d put it up on my blog without any connection to you. I promise you I’ll get your concerns written down on an agency process like the NRC Allegation Process or on the 2.206 process. I have connections with many NRC officials and high OIG officials. I promise I’ll get your concerns written down in your plants licensing docket. You just might get the NRC to make a response to your concern. I would be certain high NRC and licensee officials would carefully read your complaints or concerns. If they don’t respond to your concern and then fix it…when the shit eventually the fans they will pay a price. This is the power of transparency. The idea here, this stuff is really powerful; is to get the problem written down before the deterioration evident or before event or accident occurs. These officials know, pre-knowledge of a upcoming event or accident can be devastationally transformational to the organizations.

(steamshovel2002@yahoo.com, cell 1-603-209-4206) 

If I was an engineer, licensed operator or some other invaluable technical person…I want people to listen and respect what I say. I worked too hard to get to this position for you not to hear my opinions. I’d be working to raise my reputation and amplify my voice. I’d establish a relationship with the NRC. If you are working in a plant and are a technical person, the NRC will treat you with super professional respect. I wouldn’t get talking to my supervisor on the bigger safety concerns…I write up and submit a public 10 CFR 2.206. This forces the agency into a process, you would talk to in a meeting to maybe 10 to 15 officials…it would all get into the public record. The agency and your licensee will treat you with the utmost respect…they would allow you to paw over all their internal documents to support your assertions. The NRC would be required to answer you. Chances are they wouldn’t support your concerns, the NRC officials hardly ever support a full 2.206 to anyone…but everyone would see a facet of your character. You would develop a reputation in the plant unlike anyone else. I am convinced this would protect you from retaliation.

I would caution you it would have to be a legitimate safety concerns or at least cover new safety territory not discussed before. Like I said, even if denied, they would all fear your problem could show up in a future incident or accident. Then you hit a gold mine.

The best place to raise a safety concern is in a Catholic confessional booth with a priest. You get that don’t you, all the licensee and NRC is promising you, is the right to “raise”a safety concern to your supervisor. Nobody is talking about a fair and objective process to adjudicate your safety concern based on nuclear professionalism and following all the policies, rules and procedures in the plant and within the NRC. At best the NRC is promising you a confessional booth with a priest.