Contexto

6.1. Requirement 12 of GSR Part 2 [5] states that “Individuals in the organization, from senior managers downwards, shall foster a strong safety culture. The management system and leadership for safety shall be such as to foster and sustain a strong safety culture.”

6.2. Senior management should be committed to developing a culture for safety, and should communicate this within the organization and demonstrate this through their own actions.

6.3. Paragraph 5.2 of GSR Part 2 [5] states:

“Senior managers and all other managers shall advocate and support the following:

(a) A common understanding of safety and of safety culture, including:

awareness of radiation risks and hazards relating to work and to the working environment; an understanding of the significance of radiation risks and hazards for safety; and a collective commitment to safety by teams and individuals;

(b) Acceptance by individuals of personal accountability for their attitudes and conduct with regard to safety;

(c) An organizational culture that supports and encourages trust, collaboration, consultation and communication;

(d) The reporting of problems relating to technical, human and organizational factors and reporting of any deficiencies in structures, systems and components to avoid degradation of safety, including the timely acknowledgement of, and reporting back of, actions taken;

(e) Measures to encourage a questioning and learning attitude at all levels in the organization and to discourage complacency with regard to safety;

(f) The means by which the organization seeks to enhance safety and to foster and sustain a strong safety culture, and using a systemic approach (i.e. an approach relating to the system as a whole in which the interactions between technical, human and organizational factors are duly considered);

(g) Safety oriented decision making in all activities;

(h) The exchange of ideas between, and the combination of, safety culture and security culture.”

6.4. Managers should also support the identification of relevant actual and potential incidents (including accidents) and non‑conformances and be involved in discussions on how these should be rectified and prevented in the future.

6.5. The highest level of documentation in the management system should make leadership for safety the utmost priority, forming a basis for promoting safety culture. The management system documentation should describe the responsibilities of leadership roles (e.g. senior managers, managers) and of the roles of workers for safety and for the development, implementation and fostering of a culture for safety. Internal communication relevant to fostering a culture for safety should cover aspects such as the following:

(a) Management policy, objectives and strategy;

(b) The management system documentation;

(c) Assessments of the culture for safety;

(d) Processes and procedures for conducting radioactive waste management activities;

(e) Organizational changes;

(f) The safety case for the facility and activities, the status of waste management activities, and plans for the future;

(g) Technical and quality management issues (e.g. problems and their resolution, planned improvements and innovations);

(h) Radiation protection issues (e.g. trends in occupational exposure and in releases to the environment, evaluation of incidents, including accidents);

(i) Regulatory and statutory issues (e.g. the preparation of information to fulfil regulatory requirements and licence conditions, preparation for new laws and requirements on radiation protection and safety, on waste management and on environmental protection).

6.6. A strong culture for safety supports the safe and successful conduct of activities in accordance with the management system. A culture for safety is also an important aspect of organizational effectiveness, safety performance and human performance. A questioning attitude to prevent mistakes, a ‘no‑blame’ attitude (including a commitment to the freedom to express ideas) and self‑reflection should be demonstrated by all individuals. The management system should include provisions to ensure that individuals can raise safety issues without fear of penalty, harassment, intimidation, retaliation or discrimination.

6.7. The management system should support the development, implementation and continued enhancement of a strong culture for safety, for example by promoting the adoption of best practices, regardless of the type, scale, complexity, duration and evolution of the waste management activities.

6.8. The management system should contain provisions to support a culture for safety throughout all levels in the organizations involved in the waste management process and for all stages in the lifetime of a waste management facility or activity.

6.9. Senior management should ensure that working conditions and arrangements promote a strong culture for safety and improve the motivation and competence of personnel. The management system should include provisions to ensure that the management and supervision of waste management activities encourage safe ways of working.

6.10. There are specific aspects of radioactive waste management to be taken into account when fostering a culture for safety, as follows:

(a) Individuals should not only consider immediate and short term safety, but should also consider the longer term safety implications of activities, which in some instances might not be manifested until several generations later; the management system should provide individuals with sufficient knowledge to do this. The management system should aim to engender and implement an enduring culture for safety, for example to ensure consistency in the production of high quality waste containers and waste packages, in the

monitoring of waste and facility degradation, and in the keeping of records over the potentially very long period of time for which the radioactive waste will remain hazardous.

(b) The waste hierarchy should be applied and the generation of radioactive waste should be minimized.

(c) Where radioactive waste is transferred to other organizations, the safety implications of the actions undertaken at a facility might impact on the receiving organization.

(d) Mistakes in radioactive waste management could lead to non‑conforming waste packages, which consequently may have no identified treatment or disposal route; although there might be no immediate safety consequence, a legacy could be left for subsequent generations to manage (see also paras 5.118–5.120).

(e) Personnel, particularly at underground facilities, can sometimes be exposed to non‑radiological safety risks that are greater than those posed by radiological hazards. The operating organization should ensure that risks are considered in an integrated manner and that effective overall controls are put in place.

(f) Personnel should use the safety case to determine an appropriate balance between operational safety and post‑closure safety at radioactive waste disposal facilities.

7. MEASUREMENT, ASSESSMENT AND