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ECCSSafe – Exploring the contribution of
civil society to safety
Proposal of guidelines for larger-scale
Stéphane Baudé (Mutadis, France)
Gilles Hériard Dubreuil (Mutadis, France)
Drago Kos (University of Ljubljana, Slovenia)
Nadja Železnik (Regional Environmental Center for Central and Eastern Europe – Slovenia
Zsuzsanna Koritár (EnergiaKlub, Hungary)
Table of contents
2. Identification and characterization of the contribution of civil society to safety and safety
3. Safety as a public affair and definition of the “public” associated to safety.......................6
4. Understanding of safety and safety culture.......................................................................6
5. Governance of hazardous activities and safety governance.............................................7
6. Controversies and co-framing of safety issues with stakeholders.....................................8
7. Trust ..................................................................................................................................9
Annex – Grid of analysis of the case studies .........................................................................11
From the 1990’s to now, the European context has been marked by the emergence and the
reinforcement of reflections and research on the contribution of civil society to the quality of
decisions concerning hazardous activities in risk governance studies (cf. TRUSTNET
European research projects series, the works of O. Renn, the works of the International Risk
Governance Council). It has also been marked by the development of various legal,
institutional and regulatory arrangements aiming to organise participation of civil society and
local stakeholders in decision-making concerning hazardous activities.
The interactions between civil society and local actors on the one hand and institutional
actors engaged in safety1
of industrial activities on the other hand are most often addressed
either through the general issue of stakeholder involvement, perception studies, risk
governance studies or through the more general issue of the exercise of democracy
regarding technical issues. Social and human aspects of industrial safety are addressed
through the analysis of human and organisation factors of safety that are focused either on
the analysis of single organisations (e.g. operators2
) and their safety culture or address a
safety system where safety is the result of the actions and interactions of operators,
regulators and experts.
We can currently observe that some regulators and technical support organisations, in
particular in the nuclear field (e.g. IRSN in France, SITEX network in Europe), are developing
new approaches where civil society is incorporated in the safety system as an additional
layer contributing to safety, moving from a 3-pillar safety approach (operators, regulators,
experts) to a 4-pillar conception including civil society.
In the same time, international organisations dealing with safety, in particular in the nuclear
field, are evolving from a vision of engagement of civil society purely focused on the issue of
acceptation of technological choices to an acknowledgement of a positive contribution of civil
society to safety culture and to safety itself3
In the field of radioactive waste management, the COWAM (Community waste Management)
European research project series4
have emphasised the contribution of civil society to safety
culture. In the nuclear field, empirical studies5
have also started to emphasise the role of civil
society as a contributor to safety. However, this renewed role of civil society as regards
safety has not yet been investigated from a theoretical point of view.
In this context, the ECCSSafe (Exploring Civil Society Contribution to Safety) research
aims to further explore the contribution of civil society to industrial safety by providing
a theoretical framework for the analysis of this contribution, analysing three concrete cases in
The concept of industrial safety is defined as the set of technical provisions, human means and
organisational measures internal and external to industrial facilities, destined to prevent accidents and
malevolent acts and mitigate their consequences.
In this document, the word “operator” refers to the whole organisation that operates a hazardous
facility (e.g. the electricity company operating a power plant).
See notably the report of the IAEA International nuclear safety group “INSAG-20: Stakeholder
Involvement in Nuclear Issues” (2006), which states that the “involvement of stakeholders in nuclear
issues can provide a substantial improvement in safety.
See the final reports of the European research projects COWAM, COWAM 2 and COWAM in
Practice available on the COWAM website www.cowam.com
See P. Richardson, P. Rickwood, Public Involvement as a Tool to Enhance Nuclear Safety,
International Atomic Energy Agency (IAEA), Vienna, 2012. The study notably concludes that “there
are tangible benefits to be gained from a more frank relationship between the nuclear power industry
and the public, … [which] appears to represent a possible untapped asset for enhancing and
ECCSSafe is supported by the French Foundation for a Culture of Industrial Safety (Foncsi)
the nuclear field and in other industrial fields in Europe and identifying key issues to address
in further research and proposing guidelines for a larger scale research.
ECCSSafe has developed and analysed three case studies:
• The engagement of the Local Information Commissions attached to nuclear sites in
the decennial safety reviews of the reactors of Fessenheim nuclear power plant
• The engagement of local actors and NGOs on the hazardous waste incinerator of
• The local partnerships for site selection for a low and intermediate level radioactive
waste in Slovenia
These case studies and their transversal analysis 7
revealed that, under favourable
circumstance, civil society can (and actually did in these cases) contribute to safety of
industrial activities and safety culture. The analysis of the case studies also led to the
identification of conditions favouring the engagement of civil society on safety issues and the
development of their contribution to safety and safety culture.
ECCSSafe is however an exploratory study with a limited scope and, as such, it does not
have a sufficient empirical basis to deliver an in-depth analysis of the issue of the
contribution of civil society to safety and safety culture. If some of the lessons learnt from the
case studies are of general application, their reduced empirical basis calls for confirmation
through larger-scale research. In particular all questions identified in the grid of analysis of
the ECCSSafe theoretical and methodological framework (see annex 1) should be
considered as questions open for further research.
The objective of the present document is to make propositions for larger-scale research on
the contribution of civil society to safety and safety culture. Based on the transversal analysis
of the 3 case studies developed in ECCSSafe, the current documents identifies different
issues that could be tackled in a larger-scale research.
see ECCSSafe deliverable 2: Case studies and transversal analysis.
2. Identification and characterization of the contribution of civil
society to safety and safety culture
Specification and typology of contributions of civil society to safety
The analysis of the case studies has led to identify five different contributions of civil society
• Stretching of regulators and organisations operating hazardous facilities;
• Identifying undetected safety issues;
• Pushing to reinforce some dimensions or include new dimensions in safety
• Acting as an additional layer of quality insurance of the safety system;
• Contributing to improve the transparency and readability of the safety system.
Larger-scale research could refine this identification further and try to establish a more
complete typology of the contributions of civil society to safety, based on a wider
Conditions for effective contribution of civil society to safety
The analysis of the case studies also enabled to identify different favourable conditions for
the contribution of civil society to safety:
• The existence of a clear and legitimate governance framework for he engagement of
civil society in safety issues;
• Access of civil society to information;
• Access of civil society to expertise, including independent expertise and institutional
• Technical mediation enabling to establish links between non-technical actors and
issues which include technical dimensions;
• Resources for empowerment of civil society actors;
• Balance of power between civil society and institutional actors.
Larger-scale research based on a diversified empirical basis could refine further this
identification of favourable conditions, and help sorting out what conditions are necessary
conditions for the contribution of civil society to safety and what conditions are only
favourable but not necessary conditions.
The analysis of case studies lasting over long durations (two of the processes of
engagement of civil society considered in ECCSSafe developed over several decades)
showed that the capacity of civil society to influence safety also depends on cultural and
political factors that constitute the background of these interactions.
While addressing the conditions for civil society contribution to safety, wider-scale research
should therefore not only investigate foreground conditions (procedures, existence of a
governance framework, of technical mediation, of resources available for he stakeholders,
etc.) but also address the cultural, political, structural background conditions of the
development of the contribution of civil society to safety. For this, the empirical basis
considered should have sufficient historical depth (typically decades) to catch the evolutions
of these background conditions.
3. Safety as a public affair and definition of the “public” associated
The three case studies has showed different processes of formation of a “public” associated
to safety issues, in John Dewey’s sense of the “public”, i.e. the people affected by an activity,
which progressively structure to investigate and influence this activity.
Larger-scale research can investigate further the social and political dynamics of formation of
such a “public” and the conditions that facilitate (or conversely hinder) its formation. In this
regards, several questions could be addressed:
• What is the dynamics of co-evolution between the constitution of the public of a safety
issue and the framing of the issue at stake?
• How do background conditions (cultural, political and historical background) and
foreground conditions (processes and procedures, means, resources…) affect the
dynamics of formation of a public?
• How does this public recognises itself as such? How is the heterogeneity of this
public dealt with (by this public and by institutions)? Are there different layers in this
public (e.g. civil society actors and non-institutional experts supporting them) and how
are they interrelated? Are there collective learning processes or processes of cultural
convergence at stake between the actors composing this public?
• What is the role of the divide between expert and lay people in the formation of this
public, and how knowledge and expertise are mobilised during the formation of the
These questions can be considered with different time scopes (particular processes of
mobilisation on safety issues or longer-term processes like the progressive emergence on
the CLIs and the ANCCLI as actor in the safety system in France), as well as with different
space scopes (a particular territory or a particular industrial site, or a wider national or
4. Understanding of safety and safety culture
The case studies considered in ECCSSafe showed that, provided adequate access to
expertise and technical mediation, civil society actors can develop their own understanding of
what determines the safety of an industrial activity or facility. In that sense, civil society actors
can develop a culture of safety, that is, a stable understanding of various factors determining
of safety (including human, social and organisational factors) combined to values
determining how these factors should be managed and what level of performance should be
associated to them.
If we consider culture in its broad definition of norms, values, knowledge, attitudes,
behaviours… shared among a group of people, larger-scale research can address the
question what is the safety culture shared by the different civil society actors engaging on a
same safety issue, at the local level (e.g. a hazardous facility) or at the national or supra-
national level (e.g. safety in a particular field of activity, or public policies related to safety).
This differs from safety culture in its usual definition, which stems from organisational culture
and is most often related to a considered organisation. One example of such organisation-
oriented definition of safety culture is the definition given by the IAEA INSAG 4 report:
“Safety Culture is that assembly of characteristics and attitudes in organizations and
individuals which establishes that, as an overriding priority, nuclear plant safety
issues receive the attention warranted by their significance.”
In order to describe the safety culture of civil society actors, other definitions of safety culture
need be used or developed, which are not related to a specific organisations, but to the
group of civil society actors engaging in a given safety issue, or the “public” of this safety
issue. In particular, the issue of the development of a public related to a safety issue can be
addressed together with the issue of the progressive sharing and development of a safety
culture shared within this public.
Finally, differentiating these two types of safety culture raises the issue of the interaction
between the two types of safety culture and how the corporate safety culture of operators of
hazardous facilities, regulators and their technical support organisations is and can
influenced by the safety culture of the “public” of the safety issues at stake (and conversely).
This hybridisation between these two safety cultures raises different questions that could be
addressed by larger-scale research:
• How can the safety culture of civil society actors and local actors be defined and
• How can processes of hybridisation of safety culture between civil society actors and
institutional actors be described and characterised grounding on empirical evidence?
• What are the social, political, historical and cultural factors that favour (or hamper)
this hybridisation of safety cultures? How do the different cultural systems (including
value systems) of institutional and non-institutional actors and social factors (including
social inequalities) influence this hybridisation process?
• What are the formal and informal processes through which this hybridisation takes
place? What is the influence of the legal, regulatory frameworks and more generally
the governance frameworks on the hybridisation of safety cultures.
5. Governance of hazardous activities and safety governance
The cases considered in ECCSSafe show examples of governance frameworks aiming to
enable the engagement of civil society in safety issues. Larger-scale research can rely on a
wider empirical basis to perform a comparative study of a variety of governance frameworks
aiming to the engagement of civil society in safety issues. A typology o these governance
system could be developed on this basis. The following questions could be addressed:
• What are the rationales for including civil society in the governance of the considered
hazardous activity or safety issue? Is civil society considered as a contributor to
safety? If it is not the case, how do civil society actors use the existing governance
framework for supporting their claims to engage in safety issues and contribute to
• Is safety a common good between all actors in the considered governance
framework? If it is the case, what are the formal or informal rules ensuring that this
status of common good is preserved and developed?
• How is the governance framework adapted or transformed as a result of the
engagement of civil society actors?
Regarding the latter question, some of the case studies showed that there has been in some
cases a co-evolution process in which three dynamics are interwoven:
• The evolution of the governance system related to a particular hazardous activity or
• The evolutions of the culture, organisation, objectives, … of each institutional or non-
institutional actor engaged in the governance of the considered hazardous activity or
• The engagement of civil society actors and the progressive formation of the “public”
associated to the considered hazardous activity or safety issue;
• The evolution of the framing of safety issues (cognitive evolutions);
However, this co-evolution could not be characterised or its determinants grasped through an
exploratory study like ECCSSafe. Larger-scale research could investigate these co-evolution
processes relying on an empirical basis with some historical depth, addressing the following
• Are the changes at stake of an adaptive or transformative nature? What are the
political, cultural, cognitive, organisational… ruptures that are observed and what are
• How are these evolutions related to the actions of civil society actors or to evolutions
of the political, cultural, social, economic… background?
• What are the foreground and background conditions that favour or at the contrary
hinder the co-evolution process?
• What are the mechanisms through which the different processes of change
constituting the co-evolution process are interrelated?
6. Controversies and co-framing of safety issues with stakeholders
Although the cases studies showed situations where there are diverging interpretations of the
framing of safety issues (e.g. including the issue of retrievability of radioactive waste in the
discussions about the low and intermediate level waste repository in Slovenia), they did not
give opportunities to observe processes of development (and possibly resolution) of
Yet, the issue of controversies while safety issues are addressed by a hybrid network
composed of both institutional actors and civil society actors is relevant for larger-scale
research. In particular, the Actor-Network Theory (ANT) as developed notably by Law, Latour
provides some relevant powerful tools and instruments to analyse this issue.
Some questions that can be addressed are:
• How do controversies develop and are dealt with in such networks of institutional
actors and civil society actors? What are the processes enabling to fruitfully integrate
the different framings of a same safety issue? What are the foreground (procedural)
conditions and background conditions (cultural, political, historical landscape)
enabling evolutions of this framing? Do the controversies result in a “social
construction of safety”?
• How are technical and non-technical aspects (legal, social, ethical, moral aspects)
addressed in these controversies? What are the conditions and means for mixing
these aspects? How are the issues related to the justification of hazardous activities
integrated in the safety debate?
• What are the conditions and means for interaction between institutional experts (i.e.
having a mandate in the institutional management of safety) and non-institutional
experts (e.g. academics, NGO experts…)?
• What are the conditions and means for interaction between expert and non-expert
Regarding the two latter issues, the case studies showed that for developing their own
analysis and framing of safety issues, civil society actors often need to be supported by
experts who support their process of investigation. Opening room for exchanges between
civil society actors is not a guarantee that the expertise will actually be at the service of civil
society investigations, as shows the case of the Local Partnerships in Slovenia.
Civil society actors need that experts will not only give them access to information and
See section 4.4 of ECCSSafe deliverable 1: Theoretical and methodological framework, which deals
with the actor-network theory and its possible application in the field of safety.
expertise, but also that this be made in a way in which the inputs from experts actually fit the
questions raised by civil society. In particular, the case studies also allowed identifying a
specific function of technical mediation, which established bridges between technical
information and expertise on the one hand and the questions posed by civil society in the
other hand (which are often not posed in technical terms). The French case study showed
that this could be made both by institutional and non-institutional experts. However, the
analysis of the case studies did not specify the conditions enabling experts to play this role.
Larger-scale research on this issue of access to expertise and interactions between expert
and non-expert actors could therefore address the conditions for expertise to actually support
civil society investigations. The function of technical mediation as such can be an object of
research. Moreover, there could be several layers of technical mediation interfacing the
general public, civil society organisations engaging in safety, knowledgeable actors, non-
institutional and institutional experts.
The French case showed that institutional actors (e.g. the Institute for Radiation Protection
and Nuclear Safety – IRSN) have developed specific processes, practices, know-how in
order to support civil society actors engaging in nuclear issues (including safety issues). The
conditions of development of such specific professional practices by institutional experts
could also be investigated in the framework of larger-scale research.
Researching the expert/non-expert divide and interface also requires addressing the
processes of development of knowledge, skills and even “lay expertise” by non-expert actors.
In effect, professional standards in dealing with technologies are valid, even obligatory for
experts, but the construction of sociotechnical relations are much more variable in other
social groups. The process of development of knowledge and framing of safety issues by
civil society actors and networks is not only a cognitive process but also depends on cultural
factors, values, social skills and resources, … This process of developing skills and
knowledge together with a framing of safety issues can result in the integration of new
economic, social, political, … dimensions (e.g. the financial capacity of operators and
influence of economic and financial aspect on the way firms operate hazardous facilities and
on safety culture).
Finally, as expertise is an object that is related both to knowledge and power (as showed in
the works of Michel Foucaul), the mutual relations between the processes of knowledge and
expertise building by civil society actors and the balance of power between civil society
actors and institutional actors in safety issues could also be considered.
The case studies have shown that trust is an important condition for the joint engagement of
institutional actors and civil society actors in safety issues. The type of trust that is at stake is
different from confidence (or blind trust); it is an informed trust fuelled by processes of regular
testing and checking of the trustworthiness of the actors and regular interactions between
these actors. This trust is two-sided: trust of civil society actors in the capacity of institutional
actors to be transparent, honest and to take into account their contribution equally important
as trust of institutions in the capacity of civil society actors to constructively engage in safety
issues. This type of trust is not a given but develops (or is damaged) through the interactions
between institutional actors and civil society.
The issue of trust mingles institutional aspects and personal interactions (see e.g. the trust
relations developed between staff members of the Dorog incinerator and members of the
Environment Protection Association of Dorog). Larger-scale research can further develop the
reflection on this mix between institutional and interpersonal aspects.
Following Luhman’s and Giddens’ works on trust9
, larger-scale research can also investigate
how trust relations enable integrating the (increasing) complexity of safety issues. Larger-
scale research can notably tackle the following issues: how is the intervention of civil society
is challenging the structure of the safety system? And what are the conditions and means
enabling the engagement of civil society actors to recompose the safety system with new
trust relations? Are there specific conditions or events that are more favourable to such
The issue of trust is also posed in the terms of trust of society at large (or trust of the public)
in the safety system. Here, the issue of proximity and distance is also at stake as too much
proximity between institutional actors (e.g. operators of hazardous facilities) and civil society
actors can damage the trustworthiness of civil society actors in the eye of the public as
analysed in the case of the Dorog incinerator. Larger-scale research can address the issue
of how the engagement of civil society, and possible ensuing recomposition of the safety
system and relationships between its actors, influences societal trust in this safety system.
See section 4.1 and 4.6 of ECCSSafe deliverable 1: Theoretical and methodological framework
Annex – Grid of analysis of the case studies
Understanding of safety and safety culture in the case study
• What is the implicit understanding of safety in the case study? Is it a question of
conformity with existing standards of safety?
o Are there elements of safety culture and of understanding of safety shared
between civil society actors and experts?
• How does civil society contribute to safety and safety culture?
o Identifying new questions that may impact safety that have been ignored or
neglected by experts?
o Questioning models and underlying hypothesis?
o Stretching the experts and regulators?
Definition of safety as a public affair and definition of the “public” associated
• Is safety meant to be addressed by operators and the authorities only? Or is safety
understood as belonging to the affairs of the public for it can be adversely affected?
o Is the expert/lay people divide in safety evaluations recognised as a problem or is
this divide interpreted as “normal”, inevitable, or ignored …?
• To what extent does “a public” exist as regards safety in the context of the case study?
• What are the conditions for the public to develop its inquiries regarding safety? Are these
conditions created by civil society? By public authorities? By the operators?
• What is the statute of expertise?
o To what extent does the public have access to existing expertise? To what extent
does the public have the capacity and resources to develop its own expertise?
o Are the players (and the public) in the position to make a distinction between facts
(or lack of facts) and value options?
Governance of hazardous activities and safety governance
• What kind of governance is supporting the management of safety? Does it include
explicitly or implicitly civil society as an actor in safety?
• Does the governance of safety include interactions of several categories of actors with
distinct and clear remits and deontological rules?
• To what extent is safety perceived as a result of balanced and fair interactions of several
public and private institutions together with components of the public?
• Is safety recognised as a common good by civil society actors and other actors? What
are the formal and informal arrangements used to manage in common safety as a
common good and how is common good management articulated with public regulation
and markets? How do actors contributing to safety adapt the existing formal and informal
governance system to fit evolving needs and emerging issues?
Controversies and co-framing of safety issues with stakeholders
• What are the identified controversies in the process? What is the degree of polarisation
of the participating public? Is the debate framed by a “pros and cons” implicit structure?
To what extent do the several concerned parties in the case study regard safety as a
common good beyond pro and cons positions?
• Are controversies of purely technical nature or do they mingle scientific, technical,
economic, legal and moral aspects? In this case, how is this mix dealt with? To what
extent are the values ruling the expertise, the safety trade-off and the information gaps
made explicit to the actors?
o Is so called “social construction of technological safety” recognised in expert
circles, activists and other stakeholders?
• How do civil society actors access to information about hazardous activities and safety
issues? For operators, authorities and experts, what are the rationales for making
information available or conversely for concealing information?
• Does the interaction with the public provoke some significant changes in the technical
concepts as well as in the framing of the questions at stake?
• To what extent does safety management take place in a larger perspective involving the
justification of the activity? Do interactions with the public open the way to the reframing
of the rationales that support this justification?
• How is addressed the dilemma between “contributing to safety maintenance” and
“avoiding the hazardous activity”?
• How rational and transparent are the conditions to establish trust in particular social
• Are there institutionalised possibilities to reinforce trust in industrial (technological)
• How much contingent outcome (unpredictable, undesirable events) are threatening trust
in safety of particular technology?
• How much this notion of trust as a link between faith and confidence is recognised and
how much it is threatening the stability of technology operation?
• How much trust in technology is dependent on trust in people who manage these
technology (and vice versa)?
• Is it possible to take “calculated risk” but be unaware of the dangers. How much these
blindness is present in particular situation?
• Is it possible to confirm this balance in particular social condition?
• Is this “socialization” of risk recognised and accepted as normal, or is recognised and
articulated as a problem?
• The opposite of trust is not simply mistrust. In its most profound sense, the antithesis of
trust is thus the state of mind which could best be summed up as existential angst or
dread. Are such extreme qualifications recognised in expert and public discourses?