[Federal Register Volume 61, Number 94 (Tuesday, May 14, 1996)]
[Notices]
[Pages 24336-24340]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 96-12028]
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NUCLEAR REGULATORY COMMISSION
Freedom of Employees in the Nuclear Industry To Raise Safety
Concerns Without Fear of Retaliation; Policy Statement
AGENCY: Nuclear Regulatory Commission.
ACTION: Statement of policy.
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SUMMARY: The Nuclear Regulatory Commission (NRC) is issuing this policy
statement to set forth its expectation that licensees and other
employers subject to NRC authority will establish and maintain safety-
conscious environments in which employees feel free to raise safety
concerns, both to their management and to the NRC, without fear of
retaliation. The responsibility for maintaining such an environment
rests with each NRC licensee, as well as with contractors,
subcontractors and employees in the nuclear industry. This policy
statement is applicable to NRC regulated activities of all NRC
licensees and their contractors and subcontractors.
DATES: May 14, 1996.
FOR FURTHER INFORMATION CONTACT: James Lieberman, Director, Office of
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-
0001, (301) 415-2741.
SUPPLEMENTARY INFORMATION:
Background
NRC licensees have the primary responsibility to ensure the safety
of nuclear operations. Identification and communication of potential
safety concerns 1 and the freedom of employees to raise such
concerns is an integral part of carrying out this responsibility.
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\1\ Throughout this Policy Statement the terms ``concerns,''
``safety concerns'' and ``safety problem'' refer to potential or
actual issues within the Commission's jurisdiction involving
operations, radiological releases, safeguards, radiation protection,
and other matters relating to NRC-regulated activities.
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In the past, employees have raised important issues and as a
result, the public health and safety has benefited. Although the
Commission recognizes that not every concern raised by employees is
safety significant or, for that matter, is valid, the Commission
concludes that it is important that licensees' management establish an
environment in which safety issues are promptly identified and
effectively resolved and in which employees feel free to raise
concerns.
Although hundreds of concerns are raised and resolved daily in the
nuclear industry, the Commission, on occasion, receives reports of
individuals being retaliated against for raising concerns. This
retaliation is unacceptable and unlawful. In addition to the hardship
caused to the individual employee, the perception by fellow workers
that raising concerns has resulted in retaliation can generate a
chilling effect that may discourage other workers from raising
concerns. A reluctance on the part of employees to raise concerns is
detrimental to nuclear safety.
As a result of questions raised about NRC's efforts to address
retaliation against individuals who raise health and safety concerns,
the Commission established a review team in 1993 to reassess the NRC's
program for protecting allegers against retaliation. In its report
(NUREG-1499, ``Reassessment of the NRC's Program for Protecting
Allegers Against Retaliation,'' January 7, 1994) the review team made
numerous recommendations, including several recommendations involving
issuing a policy statement to address the need to encourage responsible
licensee action with regard to fostering a quality-conscious
environment in which employees are free to raise safety concerns
without fear of retribution (recommendations II.A-1, II.A-2, and II.A-
4). On February 8, 1995, the Commission after considering those
recommendations and the bases for them published for comment a proposed
policy statement, ``Freedom of Employees in the Nuclear Industry to
Raise Safety Concerns Without Fear of Retaliation,'' in the Federal
Register (60 FR 7592, February 8, 1995).
The proposed policy statement generated comments from private
citizens and representatives of the industry concerning both the policy
statement and NRC and Department of Labor (DOL) performance. The more
significant comments related to the contents of the policy statement
included:
1. The policy statement would discourage employees from bringing
their concerns to the NRC because it provided that employees should
normally provide concerns to the licensee prior to or contemporaneously
with coming to the NRC.
2. The use of a holding period should be at the discretion of the
employer and not be considered by the NRC in evaluating the
reasonableness of the licensee's action.
3. The policy statement is not needed to establish an environment
to raise concerns if NRC uses its authority to enforce existing
requirements by pursuing civil and criminal sanctions against those who
discriminate.
4. The description of employee concerns programs and the oversight
of contractors was too prescriptive; the
[[Page 24337]]
expectations concerning oversight of contractors were perceived as the
imposition of new requirements without adherence to the Administrative
Procedure Act and the NRC's Backfit Rule, 10 CFR 50.109.
5. The need for employee concerns programs (ECPs) was questioned,
including whether the ECPs fostered the development of a strong safety
culture.
6. The suggestion for involvement of senior management in resolving
discrimination complaints was too prescriptive and that decisions on
senior management involvement should be decided by licensees.
In addition, two public meetings were held with representatives of
the Nuclear Energy Institute (NEI) to discuss the proposed policy
statement. Summaries of these meetings along with a revised policy
statement proposed by NEI were included with the comments to the policy
statement filed in the Public Document Room (PDR).
This policy statement is being issued after considering the public
comments and coordination with the Department of Labor. The more
significant changes included:
1. The policy statement was revised to clarify that senior
management is expected to take responsibility for assuring that cases
of alleged discrimination are appropriately investigated and resolved
as opposed to being personally involved in the resolution of these
matters.
2. References to maintenance of a ``quality-conscious environment''
have been changed to ``safety-conscious environment'' to put the focus
on safety.
3. The policy statement has been revised to emphasize that while
alternative programs for raising concerns may be helpful for a safety-
conscious environment, the establishment of alternative programs is not
a requirement.
4. The policy statement continues to emphasize licensees'
responsibility for their contractors. This is not a new requirement.
However, the policy statement was revised to provide that enforcement
decisions against licensees for discriminatory conduct of their
contractors would consider such things as the relationship between the
licensee and contractor, the reasonableness of the licensee's oversight
of the contractor's actions and its attempts to investigate and resolve
the matter.
5. To avoid the possibility suggested by some commenters that the
policy statement might discourage employees from raising concerns to
the NRC if the employee is concerned about retaliation by the employer,
the statement that reporting concerns to the Commission ``except in
limited fact-specific situations'' would not absolve employees of the
duty to inform the employer of matters that could bear on public,
including worker, health and safety has been deleted. However, the
policy statement expresses the Commission's expectation that employees,
when coming to the NRC, should normally have provided the concern to
the employer prior to or contemporaneously with coming to the NRC.
Statement of Policy
The purpose of this Statement of Policy is to set forth the Nuclear
Regulatory Commission's expectation that licensees and other employers
subject to NRC authority will establish and maintain a safety-conscious
work environment in which employees feel free to raise concerns both to
their own management and the NRC without fear of retaliation. A safety-
conscious work environment is critical to a licensee's ability to
safely carry out licensed activities.
This policy statement and the principles set forth in it are
intended to apply to licensed activities of all NRC licensees and their
contractors,2 although it is recognized that some of the
suggestions, programs, or steps that might be taken to improve the
quality of the work environment (e.g., establishment of a method to
raise concerns outside the normal management structure such as an
employee concerns program) may not be practical for very small
licensees that have only a few employees and a very simple management
structure.
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\2\ Throughout this Notice, the term ``licensee'' includes
licensees and applicants for licenses. It also refers to holders of
certificates of compliance under 10 CFR Part 76. The term
``contractor'' includes contractors and subcontractors of NRC
licensees and applicants defined as employers by section 211(a)(2)
of the Energy Reorganization Act of 1974, as amended.
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The Commission believes that the most effective improvements to the
environment for raising concerns will come from within a licensee's
organization (or the organization of the licensee's contractor) as
communicated and demonstrated by licensee and contractor management.
Management should recognize the value of effective processes for
problem identification and resolution, understand the negative effect
produced by the perception that employee concerns are unwelcome, and
appreciate the importance of ensuring that multiple channels exist for
raising concerns. As the Commission noted in its 1989 Policy Statement
on the Conduct of Nuclear Power Plant Operations (54 FR 3424, January
24, 1989), management must provide the leadership that nurtures and
maintains the safety environment.
In developing this policy statement, the Commission considered the
need for:
(1) Licensees and their contractors to establish work environments,
with effective processes for problem identification and resolution,
where employees feel free to raise concerns, both to their management
and to the NRC, without fear of retaliation;
(2) Improving contractors' awareness of their responsibilities in
this area;
(3) Senior management of licensees and contractors to take the
responsibility for assuring that cases of alleged discrimination are
appropriately investigated and resolved; and
(4) Employees in the regulated industry to recognize their
responsibility to raise safety concerns to licensees and their right to
raise concerns to the NRC.
This policy statement is directed to all employers, including
licensees and their contractors, subject to NRC authority, and their
employees. It is intended to reinforce the principle to all licensees
and other employers subject to NRC authority that an act of retaliation
or discrimination against an employee for raising a potential safety
concern is not only unlawful but may adversely impact safety. The
Commission emphasizes that employees who raise concerns serve an
important role in addressing potential safety issues. Thus, the NRC
cannot and will not tolerate retaliation against employees who attempt
to carry out their responsibility to identify potential safety
issues.3
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\3\ An employee who believes he or she has been discriminated
against for raising concerns may file a complaint with the
Department of Labor if the employee seeks a personal remedy for the
discrimination. The person may also file an allegation of
discrimination with the NRC. The NRC will focus on licensee actions
and does not obtain personal remedies for the individual.
Instructions for filing complaints with the DOL and submitting
allegations can be found on NRC Form 3 which licensees are required
to post.
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Under the Atomic Energy Act of 1954, as amended, the NRC has the
authority to investigate allegations that employees of licensees or
their contractors have been discriminated against for raising concerns
and to take enforcement action if discrimination is substantiated. The
Commission has promulgated regulations to prohibit discrimination (see,
e.g., 10 CFR 30.7 and 50.7). Under Section 211 of the Energy
Reorganization Act of 1974, as amended, the Department of Labor also
has the authority to investigate complaints of discrimination and to
[[Page 24338]]
provide a personal remedy to the employee when discrimination is found
to have occurred.
The NRC may initiate an investigation even though the matter is
also being pursued within the DOL process. However, the NRC's
determination of whether to do so is a function of the priority of the
case which is based on its potential merits and its significance
relative to other ongoing NRC investigations.4
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\4\ The NRC and DOL have entered into a Memorandum of
Understanding to facilitate cooperation between the agencies. (47 FR
54585; December 3, 1982).
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Effective Processes for Problem Identification and Resolution
Licensees bear the primary responsibility for the safe use of
nuclear materials in their various licensed activities. To carry out
that responsibility, licensees need to receive prompt notification of
concerns as effective problem identification and resolution processes
are essential to ensuring safety. Thus, the Commission expects that
each licensee will establish a safety-conscious environment where
employees are encouraged to raise concerns and where such concerns are
promptly reviewed, given the proper priority based on their potential
safety significance, and appropriately resolved with timely feedback to
employees.
A safety-conscious environment is reinforced by a management
attitude that promotes employee confidence in raising and resolving
concerns. Other attributes of a work place with this type of an
environment may include well-developed systems or approaches for
prioritizing problems and directing resources accordingly; effective
communications among various departments or elements of the licensee's
organization for openly sharing information and analyzing the root
causes of identified problems; and employees and managers with an open
and questioning attitude, a focus on safety, and a positive orientation
toward admitting and correcting personnel errors.
Initial and periodic training (including contractor training) for
both employees and supervisors may also be an important factor in
achieving a work environment in which employees feel free to raise
concerns. In addition to communicating management expectations,
training can clarify for both supervisors and employees options for
problem identification. This would include use of licensee's internal
processes as well as providing concerns directly to the NRC.5
Training of supervisors may also minimize the potential perception that
efforts to reduce operating and maintenance costs may cause supervisors
to be less receptive to employee concerns if identification and
resolution of concerns involve significant costs or schedule delays.
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\5\ Training of supervisors in the value of raising concerns and
the use of alternative internal processes may minimize the conflict
that can be created when supervisors, especially first line
supervisors, perceive employees as ``problem employees'' if the
employees, in raising concerns, bypass the ``chain of command.''
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Incentive programs may provide a highly visible method for
demonstrating management's commitment to safety, by rewarding ideas not
based solely on their cost savings but also on their contribution to
safety. Credible self assessments of the environment for raising
concerns can contribute to program effectiveness by evaluating the
adequacy and timeliness of problem resolution. Self-assessments can
also be used to determine whether employees believe their concerns have
been adequately addressed and whether employees feel free to raise
concerns. When problems are identified through self-assessment, prompt
corrective action should be taken.
Licensees and their contractors should clearly identify the
processes that employees may use to raise concerns and employees should
be encouraged to use them. The NRC appreciates the value of employees
using normal processes (e.g., raising issues to the employee
supervisors or managers or filing deficiency reports) for problem
identification and resolution. However, it is important to recognize
that the fact that some employees do not desire to use the normal line
management processes does not mean that these employees do not have
legitimate concerns that should be captured by the licensee's
resolution processes. Nor does it mean that the normal processes are
not effective. Even in a generally good environment, some employees may
not always be comfortable in raising concerns through the normal
channels. From a safety perspective, no method of raising potential
safety concerns should be discouraged. Thus, in the interest of having
concerns raised, the Commission encourages each licensee to have a dual
focus: (1) On achieving and maintaining an environment where employees
feel free to raise their concerns directly to their supervisors and to
licensee management, and (2) on ensuring that alternate means of
raising and addressing concerns are accessible, credible, and
effective.
NUREG-1499 may provide some helpful insights on various alternative
approaches. The Commission recognizes that what works for one licensee
may not be appropriate for another. Licensees have in the past used a
variety of different approaches, such as:
(1) An ``open-door'' policy that allows the employee to bring the
concern to a higher-level manager;
(2) A policy that permits employees to raise concerns to the
licensee's quality assurance group;
(3) An ombudsman program; or
(4) Some form of an employee concerns program.
The success of a licensee alternative program for concerns may be
influenced by how accessible the program is to employees,
prioritization processes, independence, provisions to protect the
identity of employees including the ability to allow for reporting
issues with anonymity, and resources. However, the prime factors in the
success of a given program appear to be demonstrated management support
and how employees perceive the program. Therefore, timely feedback on
the follow-up and resolution of concerns raised by employees may be a
necessary element of these programs.
This Policy Statement should not be interpreted as a requirement
that every licensee establish alternative programs for raising and
addressing concerns. Licensees should determine the need for providing
alternative methods for raising concerns that can serve as internal
``escape valves'' or ``safety nets.'' 6 Considerations might
include the number of employees, the complexity of operations,
potential hazards, and the history of allegations made to the NRC or
licensee. While effective alternative programs for identifying and
resolving concerns may assist licensees in maintaining a safety-
conscious environment, the Commission, by making the suggestion for
establishing alternative programs, is not requiring licensees to have
such programs. In the absence of a requirement imposed by the
Commission, the establishment and framework of alternative programs are
discretionary.
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\6\ In developing these programs, it is important for reactor
licensees to be able to capture all potential safety concerns, not
just concerns related to ``safety-related'' activities covered by 10
CFR Part 50, Appendix B. For example, concerns relating to
environmental, safeguards, and radiation protection issues should
also be captured.
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[[Page 24339]]
Improving Contractors' Awareness of Their Responsibilities
The Commission's long-standing policy has been and continues to be
to hold its licensees responsible for compliance with NRC requirements,
even if licensees use contractors for products or services related to
licensed activities. Thus, licensees are responsible for having their
contractors maintain an environment in which contractor employees are
free to raise concerns without fear of retaliation.
Nevertheless, certain NRC requirements apply directly to
contractors of licensees (see, for example, the rules on deliberate
misconduct, such as 10 CFR 30.10 and 50.5 and the rules on reporting of
defects and noncompliances in 10 CFR Part 21). In particular, the
Commission's prohibition on discriminating against employees for
raising safety concerns applies to the contractors of its licensees, as
well as to licensees (see, for example, 10 CFR 30.7 and 50.7).
Accordingly, if a licensee contractor discriminates against one of
its employees in violation of applicable Commission rules, the
Commission intends to consider enforcement action against both the
licensee, who remains responsible for the environment maintained by its
contractors, and the employer who actually discriminated against the
employee. In considering whether enforcement actions should be taken
against licensees for contractor actions, and the nature of such
actions, the NRC intends to consider, among other things, the
relationship of the contractor to the particular licensee and its
licensed activities; the reasonableness of the licensee's oversight of
the contractor environment for raising concerns by methods such as
licensee's reviews of contractor policies for raising and resolving
concerns and audits of the effectiveness of contractor efforts in
carrying out these policies, including procedures and training of
employees and supervisors; the licensee's involvement in or opportunity
to prevent the discrimination; and the licensee's efforts in responding
to the particular allegation of discrimination, including whether the
licensee reviewed the contractor's investigation, conducted its own
investigation, or took reasonable action to achieve a remedy for any
discriminatory action and to reduce potential chilling effects.
Contractors of licensees have been involved in a number of
discrimination complaints that are made by employees. In the interest
of ensuring that their contractors establish safety-conscious
environments, licensees should consider taking action so that:
(1) Each contractor involved in licensed activities is aware of the
applicable regulations that prohibit discrimination;
(2) Each contractor is aware of its responsibilities in fostering
an environment in which employees feel free to raise concerns related
to licensed activities;
(3) The licensee has the ability to oversee the contractor's
efforts to encourage employees to raise concerns, prevent
discrimination, and resolve allegations of discrimination by obtaining
reports of alleged contractor discrimination and associated
investigations conducted by or on behalf of its contractors; conducting
its own investigations of such discrimination; and, if warranted, by
directing that remedial action be undertaken; and
(4) Contractor employees and management are informed of (a) the
importance of raising safety concerns and (b) how to raise concerns
through normal processes, alternative internal processes, and directly
to the NRC.
Adoption of contract provisions covering the matters discussed
above may provide additional assurance that contractor employees will
be able to raise concerns without fear of retaliation.
Involvement of Senior Management in Cases of Alleged Discrimination
The Commission reminds licensees of their obligation both to ensure
that personnel actions against employees, including personnel actions
by contractors, who have raised concerns have a well-founded, non-
discriminatory basis and to make clear to all employees that any
adverse action taken against an employee was for legitimate, non-
discriminatory reasons. If employees allege retaliation for engaging in
protected activities, senior licensee management should be advised of
the matter and assure that the appropriate level of management is
involved, reviewing the particular facts and evaluating or
reconsidering the action.
The intent of this policy statement is to emphasize the importance
of licensee management taking an active role to promptly resolve
situations involving alleged discrimination. Because of the complex
nature of labor-management relations, any externally-imposed resolution
is not as desirable as one achieved internally. The Commission
emphasizes that internal resolution is the licensee's responsibility,
and that early resolution without government involvement is less likely
to disrupt the work place and is in the best interests of both the
licensee and the employee. For these reasons, the Commission's
enforcement policy provides for consideration of the actions taken by
licensees in addressing and resolving issues of discrimination when the
Commission develops enforcement sanctions for violations involving
discrimination. (59 FR 60697; November 28, 1994).
In some cases, management may find it desirable to use a holding
period, that is, to maintain or restore the pay and benefits of the
employee alleging retaliation, pending reconsideration or resolution of
the matter or pending the outcome of an investigation by the Department
of Labor (DOL). This holding period may calm feelings on-site and could
be used to demonstrate management encouragement of an environment
conducive to raising concerns. By this approach, management would be
acknowledging that although a dispute exists as to whether
discrimination occurred, in the interest of not discouraging other
employees from raising concerns, the employee involved in the dispute
will not lose pay and benefits while the action is being reconsidered
or the dispute is being resolved. However, inclusion of the holding
period approach in this policy statement is not intended to alter the
existing rights of either the licensee or the employee, or be taken as
a direction by, or an expectation of, the Commission, for licensees to
adopt the holding period concept. For both the employee and the
employer, participation in a holding period under the conditions of a
specific case is entirely voluntary.
A licensee may conclude, after a full review, that an adverse
action against an employee is warranted.7 The Commission
recognizes the need for licensees to take action when justified.
Commission regulations do not render a person who engages in protected
activity immune from discharge or discipline stemming from non-
prohibited considerations (see, for example, 10 CFR 50.7(d)). The
Commission expects licensees to make personnel decisions that are
consistent with regulatory requirements and that
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will enhance the effectiveness and safety of the licensee's operations.
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\7\ When other employees know that the individual who was the
recipient of an adverse action may have engaged in protected
activities, it may be appropriate for the licensee to let the other
employees know, consistent with privacy and legal considerations,
that (1) management reviewed the matter and determined that its
action was warranted, (2) the action was not in retaliation for
engaging in protected activity and the reason why, and (3) licensee
management continues to encourage them to raise issues. This may
reduce any perception that retaliation occurred.
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Responsibilities of Employers and Employees
As emphasized above, the responsibility for maintaining a safety-
conscious environment rests with licensee management. However,
employees in the nuclear industry also have responsibilities in this
area. As a general principle, the Commission normally expects employees
in the nuclear industry to raise safety and compliance concerns
directly to licensees, or indirectly to licensees through contractors,
because licensees, and not the Commission, bear the primary
responsibility for safe operation of nuclear facilities and safe use of
nuclear materials.8 The licensee, and not the NRC, is usually in
the best position and has the detailed knowledge of the specific
operations and the resources to deal promptly and effectively with
concerns raised by employees. This is another reason why the Commission
expects licensees to establish an environment in which employees feel
free to raise concerns to the licensees themselves.
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\8\ The expectation that employees provide safety and compliance
concerns to licensees is not applicable to concerns of possible
wrongdoing by NRC employees or NRC contractors. Such concerns are
subject to investigation by the NRC Office of Inspector General.
Concerns related to fraud, waste or abuse in NRC operations or NRC
programs including retaliation against a person for raising such
issues should be reported directly to the NRC Office of the
Inspector General. The Inspector General's toll-free hotline is 800-
233-3497.
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Employers have a variety of means to express their expectations
that employees raise concerns to them, such as employment contracts,
employers' policies and procedures, and certain NRC requirements. In
fact, many employees in the nuclear industry have been specifically
hired to fulfill NRC requirements that licensees identify deficiencies,
violations and safety issues. Examples of these include many employees
who conduct surveillance, quality assurance, radiation protection, and
security activities. In addition to individuals who specifically
perform functions to meet monitoring requirements, the Commission
encourages all employees to raise concerns to licensees if they
identify safety issues 9 so that licensees can address them before
an event with safety consequences occurs.
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\9\ Except for the reporting of defects under 10 CFR Part 21
and in the area of radiological working conditions, the Commission
has not codified this expectation. Licensees are required by 10 CFR
19.12 to train certain employees in their responsibility to raise
issues related to radiation safety.
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The Commission's expectation that employees will normally raise
safety concerns to their employers does not mean that employees may not
come directly to the NRC. The Commission encourages employees to come
to the NRC at any time they believe that the Commission should be aware
of their concerns.10 But, while not required, the Commission does
expect that employees normally will have raised the issue with the
licensee either prior to or contemporaneously with coming to the NRC.
The Commission cautions licensees that complaints that adverse action
was taken against an employee for not bringing a concern to his or her
employer, when the employee brought the concern to the NRC, will be
closely scrutinized by the NRC to determine if enforcement action is
warranted for discrimination.
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\10\ The Commission intends to protect the identity of
individuals who come to the NRC to the greatest extent possible. See
``Statement of Policy on Protecting the Identity of Allegers and
Confidential Sources.''
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Retaliation against employees engaged in protected activities,
whether they have raised concerns to their employers or to the NRC,
will not be tolerated. If adverse action is found to have occurred
because the employee raised a concern to either the NRC or the
licensee, civil and criminal enforcement action may be taken against
the licensee and the person responsible for the discrimination.
Summary
The Commission expects that NRC licensees will establish safety-
conscious environments in which employees of licensees and licensee
contractors are free, and feel free, to raise concerns to their
management and to the NRC without fear of retaliation.
Licensees must ensure that employment actions against employees who
have raised concerns have a well-founded, non-discriminatory basis.
When allegations of discrimination arise in licensee, contractor, or
subcontractor organizations, the Commission expects that senior
licensee management will assure that the appropriate level of
management is involved to review the particular facts, evaluate or
reconsider the action, and, where warranted, remedy the matter.
Employees also have a role in contributing to a safety-conscious
environment. Although employees are free to come to the NRC at any
time, the Commission expects that employees will normally raise
concerns with the involved licensee because the licensee has the
primary responsibility for safety and is normally in the best position
to promptly and effectively address the matter. The NRC should normally
be viewed as a safety valve and not as a substitute forum for raising
safety concerns.
This policy statement has been issued to highlight licensees'
existing obligation to maintain an environment in which employees are
free to raise concerns without retaliation. The expectations and
suggestions contained in this policy statement do not establish new
requirements. However, if a licensee has not established a safety-
conscious environment, as evidenced by retaliation against an
individual for engaging in a protected activity, whether the activity
involves providing information to the licensee or the NRC, appropriate
enforcement action may be taken against the licensee, its contractors,
and the involved individual supervisors, for violations of NRC
requirements.
The Commission recognizes that the actions discussed in this policy
statement will not necessarily insulate an employee from retaliation,
nor will they remove all personal cost should the employee seek a
personal remedy. However, these measures, if adopted by licensees,
should improve the environment for raising concerns.
Dated at Rockville, Maryland, this 8th day of May, 1996.
For the Nuclear Regulatory Commission.
John C. Hoyle,
Secretary of the Commission.
[FR Doc. 96-12028 Filed 5-13-96; 8:45 am]
BILLING CODE 7590-01-P
