1. IAEA Pilot Project on Safety Culture Assessment at Pakistan Nuclear Regulatory Authority (PNRA) Presented By: Mahboob Ali, Member (Executive) Regulatory Cooperation Forum (RCF), Plenary Meeting 18 September, 2015 IAEA, Vienna, Austria Pakistan Nuclear Regulatory Authority (PNRA)

2. Highlights of Presentation Importance of Safety Culture for Regulatory Body Core Values – Safety Culture at PNRA PNRA Safety Culture Self Assessment (SCSA) Conclusion 2

3. Importance of Safety Culture for Regulatory Body The concept of safety culture is essential part of management system (IAEA GS-R-3) which is applicable to all kind of organizations including operators, vendors, regulatory bodies, etc. After Fukushima accident, the role of safety culture in ensuring safety was re-emphasized and was also reflected in IAEA action plan on nuclear safety issued in 2011. As part of IAEA action plan on nuclear safety, regulators are also being encouraged to conduct safety culture assessment. 3

4. Utilizing Principles of Safety Culture at PNRA The consideration of safety culture principles remained an important part of regulatory business at PNRA in the form of core values since its inception. Following core values were defined in the initial stages of PNRA’s establishment; –Integrity –Transparency –Independence in Decision Making –Competence and Professionalism –Mutual Respect –Caring and Compassionate Attitude 4

5. Need for Safety Culture Self Assessment (SCSA) at PNRA In 2012, PNRA volunteered for SCSA in order to judge its safety culture systematically utilizing IAEA approach (i.e. in development phase) which is applicable for regulators, operating organizations etc. 5

6. Factors Considered for Conducting SCSA at PNRA Following were factors that were considered; –Identification of strong and weak areas of safety culture in comparison with international standards (i.e. Modified IAEA normative framework to make it applicable for regulatory body); –Elements contributing negatively towards safety culture at PNRA may be addressed to convert them into strengths; –To be role model for licensee’s 6

7. 7 Safety Culture Self Assessment (SCSA) Project at PNRA

8. SCSA Project with IAEA A Project was initiated with IAEA to conduct SCSA at PNRA with the help of international experts. IAEA prepared training material by involvement of international experts for conducting SCSA. In addition to formal meetings, video Conference of IAEA Team with PNRA Management was held in February 2013 before formal start of project: To discuss purpose of the proposed SCSA activity with top management. To seek commitment of PNRA 8

9. Team Selection IAEA shared criteria (i.e. in term understanding safety culture) for team selection with PNRA. PNRA selected multidiscipline team consisting of twenty two (22) officers with team leader representing management. Representation of almost all parts of organization with different thinking / perspective was made in the team to avoid unidirectional thinking. 9

10. IAEA Training Course on SCSA Methodology IAEA delivered training to team on SCSA methodology (April 2013): Understanding of Safety Culture and its importance for any organization including regulatory body Safety culture assessment tools (observations, focus group, interviews, survey and document analysis) Descriptive Analysis Normative Analysis 10

11. Workshop on Safety Culture for Senior Management IAEA conducted workshop for PNRA senior management to cover (April 2013): Understanding of Safety Culture and why it is important for regulatory body Purpose of SCSA activity and its effectiveness for PNRA Safety culture assessment tools (observations, focus group, interviews, survey and document analysis) Descriptive Analysis Normative Analysis 11

12. Bridging Seminar A seminar was conducted to bridge SCSA team with PNRA management (April 2013) The purpose of seminar was: –To convey expectations of SCSA team to PNRA management and vice versa –To clear doubts about SCSA process, its outcomes and effectiveness 12

13. Train the trainer for Safety Culture Assessment of Licensees The purpose of train the trainer for safety culture assessment of licensee was (May 2013): –Methodology of safety culture inspections of licensees –Design of training course for inspector responsible to conduct safety culture inspections –Training of inspectors for safety culture inspections 13

14. 14 Implementation of SCSA at PNRA

15. Planning for conducting SCSA at PNRA The plan / procedure for conducting SCSA at PNRA was documented and approved. (July 2013) Procedure addressed: –Plan for implementation of SCSA –Distribution of responsibilities –Timeline for implementation of SCSA 15

16. Awareness Campaign Awareness campaign was conducted for each / division of PNRA to share information about safety culture and SCSA (July – September 2013) Different modes were utilized for this campaign –Presentation sessions –e-mails describing SCSA process and its significance / usefulness for PNRA –Display of posters highlighting concept of safety culture and SCSA process 16

17. Dissemination of Information Two modes were selected for dissemination of information about progress of SCSA process: –Team meeting to share implementation of actions assigned to each team member –Meeting with PNRA senior management to share information regarding implementation status of SCSA process 17

18. Implementation of SCSA Tools Observations Interviews Document Analysis Surveys Focus Groups 18

19. Observations It was on going activity which continued through out the SCSA implementation phase Observations were made during activities such as; –Routine working –Formal and informal gatherings –Formal meetings with licensees and within PNRA –Organizational response / stance that presented time to time 19

20. Interview Preparatory material defining wide range of areas to be explored during interviews was prepared (August –September 2013) Interviews (October 2013 – September 2014) –70 – 80 personnel from different levels in the organization (horizontally and vertically) selected for interviews –The sample set included representation of every discipline in the organization (technical, support, managers, senior managers etc.) –Responsibilities distributed among SCSA team members for holding these interviews 20

21. Document Analysis Selection of documents for document analysis (September – November 2013) Document Analysis (December 2013 – September 2014) –40 - 50 documents selected –The sample set included representation of every type of documents (technical reports, procedures, performa’s, etc.) –Responsibilities distributed among SCSA team members for analysis of these documents 21

22. Surveys Preparation of survey questionnaire (July – November 2013) Surveys (December 2013 – August 2014) –Survey consisting of 60-70 questions was prepared –Each individual of organization was included for implementation of this tool (The turn out of survey was 250 out of 700) 22

23. Focus Group Preparatory material defining wide range of areas to be explored during focus groups was prepared (July 2014) Focus Groups (August – September 2014) –Total twelve (12) focus groups were planned, eight (8) at HQs and four (4) at regional directorates –Each focus group included 8-10 personnel from different levels in the organization (horizontally and vertically) –The sample set included representation of every discipline in the organization (technical, support, managers, senior managers etc.) –Responsibilities distributed among SCSA team members for holding these focus groups 23

24. Data Collections from SCSA Tools Data generated from SCSA tools was forwarded to team leader for its consolidated storage under the header of each tools Complete confidentiality of data was maintained by restricting its access 24

25. Descriptive Analysis Descriptive analysis (October - November 2014) –Almost 1900 cultural facts were collected during implementation of five SCSA tools. –Descriptive analysis was carried out for each of the SCSA tool separately and identified cultural themes. 25

26. IAEA Support Mission – November 2014 IAEA support mission was invited in November-2014 to review descriptive analysis carried out by SCSA team. IAEA experts shared valuable feedback to improve descriptive analysis; –The methodology of developing “bubble diagram” was shared by experts to explore cultural themes starting from visible part of culture i.e. cultural facts collected during implementation of SCSA tools to explores beliefs and finally basic assumptions at the deeper part of ice berg. –It was proposed by experts to refine descriptive analysis using bubble diagram methodology. 26

27. Sample Bubble Diagram 27

28. Refining Descriptive Analysis Descriptive analysis was refined (December 2014 – April 2015) using feedback of IAEA experts. – For each SCSA tool, cultural themes were highlighted. –Overarching cultural themes were highlighted from all tools of SCSA. 28

29. Normative Analysis Normative Framework –PNRA started with IAEA normative framework (i.e. referred in GS-G-3.5) and modified it to make it applicable for regulatory body. –The framework utilized for normative analysis at PNRA was consisted of five (05) safety culture characteristics and thirty six (36) attributes under these characteristics. –One attribute was deleted due to its non applicability on PNRA; “Individuals are convinced that safety and production go ‘hand in hand’” –Few of them were slightly modified to make them applicable appropriately to regulatory body. 29

30. IAEA Support Mission – April 2015 IAEA support mission was again invited in April 2015 to review analysis carried out by PNRA team. IAEA experts reviewed descriptive and normative analysis carried out by PNRA; –Overarching cultural themes were finalized from the descriptive analysis of all SCSA tools; –Normative linkages of these overarching cultural themes were established with modified IAEA normative framework. 30

31. Communication Session with PNRA Management After finalization of descriptive and normative analysis, the outcome of SCSA was communicated to PNRA management in communication session. The communication session was composed of; –Brief about SCSA activity carried out by PNRA team –Theory of Culture and its assessment –Overarching themes emerged from descriptive analysis along with basic assumption and factors driving these cultural trends –Normative linkages of these cultural trends with modified IAEA normative framework to highlight strong and weak areas of safety culture at PNRA. 31

32. Activities in Progress Development of SCSA report comprising of summary of process, its outcomes, lessons learnt, etc. and strategy for communicating these results to all domains of PNRA. Finalization of improvement activities for converting weak areas of safety culture to strengths. 32

33. Conclusion PNRA considers safety culture as important ingredient of its regulatory processes and conducted its self assessment. The importance for incorporation of safety culture principles in regulatory processes is growing day by day learning from lessons of experience feedback including Fukushima accident. PNRA Safety Culture Self Assessment (SCSA) provided opportunity to highlight strengths / weakness to make safety culture at PNRA at par with international standards. 33

34. 34