A robust compliance and safety organizational culture (where leaders and individuals emphasize compliance and safety over competing goals) and a safety conscious work environment (SCWE) (where personnel feel free to raise safety and other critical concerns) is mission critical to highly regulated, safety significant industries. Preventing, detecting and correcting cultural weaknesses enhances employee morale, public confidence and regulatory margins as well as benefiting safety. Conversely, because SCWE and safety culture gaps often are leading indicators of more significant performance deficiencies, the failure to detect and correct SCWE and safety culture deficiencies can result in regulatory intervention at substantial corporate and site expense in resources and reputation.

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Compliance/Safety Culture and SCWE Assessments

Paul has developed and led numerous assessments whether at a facility’s own initiative or to satisfy U.S. Nuclear Regulatory Commission (NRC), U.S. Department of Energy (DOE) or other federal agency commitments. The scope of these assessments can range from individual workgroups to departments, to entire workforces. 

 

The events and circumstances that lead to the need for an assessment can vary considerably. Paul designs assessments with a scope and methodology tailored to the issues presented and to the workgroup or department to be assessed and with the goals and needs of the client utmost in mind. 

 

Paul conducts assessments in the most efficient and effective manner possible, often teaming with a highly experienced non-lawyer nuclear consultant having expertise in organizational effectiveness, change management and leadership development. Recent work includes the assessments of the safety culture of security departments of seven nuclear power plants, and a site-wide safety culture assessment required by the NRC to evaluate the site’s suitability to be removed from the NRC multiple/repetitive degraded cornerstone column. 

 

While conducting assessments, Paul remains sensitive to ancillary issues, events and information that could implicate legal, regulatory or procedural requirements. As with his work conducting investigations, Paul prefers to perform assessments while maintaining his role as legal counsel to the company, ensuring that he can have privileged discussions of such issues with officers, executives and in-house counsel. 

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Compliance/Safety Culture and SCWE Monitoring and Improvement

The NRC has made it clear through various announcements, guidance and policy statements that it expects licensees to monitor their sites’ SCWE and safety culture. Paul evaluates monitoring programs and processes and develops actions to improve program effectiveness. For example, Paul recently assessed a client’s nuclear fleet’s corporate and site safety culture monitoring processes and based on his findings, developed a strategic plan that improved the program’s capability to anticipate, prevent, detect and correct culture gaps and challenges. 

 

Paul also assists clients ensure that disciplinary and other employee actions do not violate, or are perceived to violate, whistleblower protection laws and regulations. These include management and supervisor training and the development and implementation of disciplinary and executive review boards (ERBs). Paul develops and refines ERB charters and procedures, observes and critiques ERB meetings, helps develop chilling effect mitigation plans and provides advice and counsel to ERB members. 

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Compliance/Safety Culture and SCWE Training

Paul has developed training in various key areas: compliance/safety culture, SCWE, effective communications, prevention and detection of retaliation and willful misconduct, completeness and accuracy of information, and other more specialized areas. Paul has trained thousands of supervisors, managers, licensee and contract staff and other groups at numerous sites across the country. Participants have praised Paul’s training, noting his real-world experience, substantial technical background, presentation style, the pragmatic information presented, the use of case studies developed from actual situations and engaging class interaction. Paul works with in-house counsel, managers and other representatives to tailor his training and ensure it meets his clients’ needs.