Experiences of a Regulatory Agency with Safety Culture Assessment

Abstract

Three elements determine the safety performance of a company: the technical integrity of its installations, its safety management system, and its safety culture. The first requirement for good safety performance is that the technical installations are designed properly, inspected regularly and maintained well. This will assure their technical integrity. The way in which a company operates these installations is documented in the company’s management system, and for safety this is the safety management system. More recently, it has become clear that attitude and behavior are also essential aspects for controlling major-accident risks, whereas the core values of a company and its way of communicating are important as well. Altogether, these constitute the third element of the model: safety culture. Big differences exist between companies, particularly regarding safety culture, which therefore justifies safety culture to be a separate element of the safety performance model. Moreover, a weak safety culture has been identified as a major contributor to industrial accidents. DCMR Environmental Protection Agency acts as competent authority for environmental regulation in the Rotterdam-Rijnmond region, on behalf of the province of South-Holland and 15 municipalities. Key responsibilities include environmental licensing of high-risk companies and the associated supervision and enforcement. There are no legal requirements for having a good safety culture, but the importance of that third element for good safety performance stimulated the province of South-Holland to include safety culture assessment in its supervision policy and to require DCMR to make safety culture part of its supervision activities. The safety culture program of DCMR started in 2012 with an exploratory project by the Netherlands Organisation for Applied Scientific Research TNO. This turned out to be successful, and in 2013 DCMR carried out a pilot project in order to get a feeling about the feasibility of this addition and to develop an operational approach. Since 2014, safety culture assessment is formally included in the yearly work program. It is added as a separate activity to selected inspections, and carried out by safety experts since the findings cannot be translated into enforcement actions. Consequently, the primary objective is to stimulate these companies to introduce a safety culture program, or to continue it should they already have such a program in place, by “confronting” them with the findings of the assessment. In 2014 and 2015, safety culture assessments were carried out at 12 and 18 Seveso companies, respectively, with the addition of two non- Seveso companies in 2015, following the decision to expand the program to include that category. Most of these 32 companies were already paying attention to their safety culture or intending to do so, and also appeared to be amenable to suggestions for improving their safety culture.