Hazards: Technology and Fairness (1986)

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THREE MILE ISLAND AND BHOPAL: LESSONS LEARNED AND NOT LEARNED 201 original typesetting files. Page breaks are true to the original; line lengths, word breaks, heading styles, and other typesetting-specific formatting, however, cannot be About this PDF file: This new digital representation of the original work has been recomposed from XML files created from the original paper book, not from the retained, and some typographic errors may have been accidentally inserted. Please use the print version of this publication as the authoritative version for attribution. the utility industry. However, the concept has had a long history of acceptance in the airline industry. 4. Hazardous technologies require highly competent managers. Admiral Rickover had a justified reputation as a superb manager of highly complex technical operations. His criteria for a good manager include the following (Rickover, 1979): • "A person doing a job—any job—must feel that he owns it and that he will remain on that job indefinitely." • "Along with ownership comes the need for acceptance of full responsibility for the work. . . . Unless the one person truly responsible can be identified when something goes wrong, then no one has been really responsible." I note that high-risk industries seem to structure themselves so there is no one person responsible. • "If the boss is not concerned about details, his subordinates also will not consider them important. . . . It is hard, monotonous, and onerous to pay attention to details; most managers would rather focus on lofty policy matters. But when the details are ignored, the project fails." • "Establish simple and direct means to find out what is going on in detail in [your] area. . . . Most managers avoid keeping up with details; instead, they create 'management information systems.'" • "Resist the natural human inclination to hope things will work out, despite evidence of doubt to the contrary. . . . Face the facts." Rickover also has said, and I agree (Ahearne, 1983, p. 382), that technical training is necessary to manage any technical operation competently. 5. Beware the growing influence of lawyers and the courts. According to Harvard President Bok, "Since laws seem deceptively potent and cheap, they multiply quickly. Though most of them may be plausible in isolation, they are often confusing and burdensome in the aggregate, at least to those who have to take them seriously. . . . For established institutions, in particular, the typical result is a stifling burden of regulations, delays, and legal uncertainties that inhibit progress and allow unscrupulous parties to misuse the law to harass and manipulate their victims" (Bok, 1983, p. 12). Hazardous technology industries can see the outlines of their future in auto accident awards, car manufacturers settling out of court for large sums, and medical malpractice suits. The chemical industry, for example, has some hard days ahead with respect to lawsuits (see Huber, in this volume). LESSONS FOR REGULATORS The following are lessons from Three Mile Island for regulators: 1. Prepare for accidents. Washington, D.C., is a fishbowl. When an accident occurs, pressures on federal regulators are enormous— pressures 

THREE MILE ISLAND AND BHOPAL: LESSONS LEARNED AND NOT LEARNED 202 original typesetting files. Page breaks are true to the original; line lengths, word breaks, heading styles, and other typesetting-specific formatting, however, cannot be About this PDF file: This new digital representation of the original work has been recomposed from XML files created from the original paper book, not from the retained, and some typographic errors may have been accidentally inserted. Please use the print version of this publication as the authoritative version for attribution. from the news media and from Congress. During an accident is not the time to decide what to do in an accident. Regulators should be prepared even for low-probability events if the consequences can be severe. When the TMI accident occurred, the NRC had a two-room ''emergency center" that was primarily a place where key staff could gather. The NRC had no detailed information readily available on the plant or on the surrounding area. Its only link to the plant was by telephone, a link that was often noisy. The NRC had no prearranged plans about who should be at the plant or how to deal with the plant crew, and only sketchy plans for dealing with state and other federal officials. Since then the NRC and related state and federal agencies (particularly the Federal Emergency Management Agency) have made major changes in preparing for nuclear plant emergencies. For example, utilities and surrounding local and state governments are required to exercise their emergency plans at least once every two years. (It is the refusal of the local county government to do so that has kept the Shoreham. plant on Long Island from being licensed for operation.) Regulators in EPA and other agencies involved with chemical and biological products should consider now the accidents to which they may be called upon to respond, and plan how to react. 2. Share the problems. Regulators may believe they have no allies. Certainly they should not expect anyone to give them the benefit of the doubt. But actually the public can be a strong source of support—and sometimes will even support unpopular actions if those actions are carefully explained and the public is involved in the decisions. This public involvement offers the best chance of significantly improving regulatory policy. An excellent example was when EPA Administrator William Ruckelshaus directly involved the citizens of Tacoma, Washington, in EPA decisions regarding a smelter that released arsenic into the ambient air (Ruckelshaus, 1985, p. 33). Regulators should push industry to accept more responsibility. The regulators cannot operate plants. Plant operators must recognize they are ultimately responsible for safe operation. Regulators also should work with the Congress—at times a seemingly impossible task—to explain their agency's regulatory philosophy and try to get the Congress to either endorse the philosophy or modify it. Of course, the regulators must be able to describe clearly what is their regulatory philosophy. 3. Recognize the courts' influence. The Nuclear Regulatory Commission prepares decisions knowing they will be under almost immediate attack in the D.C. Circuit Court of Appeals. The commissioners themselves also are liable to lawsuits. After the NRC allowed venting of the containment building several months following the Three Mile Island accident, suit was filed against NRC commissioners as individuals for causing harm to the populace