Using fault tree analysis to identify causes of non-compliance: Enhancing violation outcome data for the purposes of education and prevention

An enhanced coding system for the characterization of notices of violation (NOV's) issued to radiation permit holders in the State of Texas was developed based on a series of fault tree analyses serving to identify a set of common causes. The coding system enhancement was retroactively applied to a representative sample (n = 185) of NOV's issued to specific licensees of radioactive materials in Texas during calendar year 1999. The results obtained were then compared to the currently available summary NOV information for the same year. In addition to identifying the most common NOV's, the enhanced coding system revealed that approximately 70% of the sampled NOV's were issued for non-compliance with a specific regulation as opposed to a permit condition. Furthermore, an underlying cause of 94% of the NOV's was the failure on the part of the licensee to execute a specific task. The findings suggest that opportunities exist to improve permit holder compliance through various means, including the creation of summaries which detail specific tasks to be completed, and revising training programs with more focus on the identification and scheduling of permit-related requirements. Broad application of these results is cautioned due to the bias associated with the restricted scope of the project.