CPUC workshop examines how to adapt large-utility safety-culture framework for small utilities
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Summary
At a CPUC Safety Policy Division workshop, staff reviewed the safety-culture assessment framework originally adopted for large investor-owned utilities and invited small utilities and an outside expert, Dr. Mark Fleming, to discuss how assessments should be scaled and tailored to companies with few employees or multi‑jurisdiction operations.
The California Public Utilities Commission’s Safety Policy Division hosted a workshop to consider how the safety‑culture assessment framework adopted for large investor‑owned utilities should be adapted for small and multi‑jurisdictional gas and electric utilities and independent gas storage operators. Ben Menzies, an advisor to Commissioner Darcy Houck, opened the session and said safety culture “is a top priority for the commission,” noting the proceeding aims to produce assessments that are reasonable, feasible and promote accountability.
Carolina of the Safety Policy Division presented the framework the commission adopted and described its main features: goals and guiding principles, working definitions of safety and safety culture, a normative framework adapted from U.S. Nuclear Regulatory Commission and INPO traits, a comprehensive assessment cycle intended once every four years, interim self‑improvement evaluations, and a safety‑culture working group for collaborative refinement. Carolina emphasized that the CPUC’s definition treats safety culture as a subset of organizational culture that encompasses collective beliefs, values and norms, and that assessments are designed to capture safety risks to people, assets and the environment — not only occupational safety.
Dr. Mark Fleming, the workshop’s subject‑matter expert, told participants that safety culture is a constructed concept used to explain how low‑probability, high‑consequence events occur and why organizations with strong written controls sometimes nonetheless experience catastrophic failures. “Safety culture is an important construct, but it’s not an object,” Dr. Fleming said, arguing that robust assessments reach beneath artifacts and perceptions to understand the underlying assumptions that shape behavior.
SPD described the comprehensive‑assessment methodology it envisions for large IOUs as multi‑method and third‑party led, combining surveys, document reviews, interviews, focus groups and site observations with concurrent data collection and triangulation to surface systemic cultural patterns. Staff also summarized responses to a 04/23/2025 information ruling from ten small utilities (three electric, three natural gas, four independent gas storage operators), noting a wide range of workforce sizes (from seven employees to several thousand at the largest entities referenced) and extensive use of contractors.
Across presentations and the roundtable, two consistent themes emerged: first, small organizations often cannot rely on perception surveys alone because low employee counts undermine anonymity and statistical reliability; second, qualitative methods — document review, field observation and focused interviews — frequently provide more actionable insight for smaller operators. Dr. Fleming recommended that, when scaled down, assessments for small utilities should emphasize observations and document analysis and be short and tailored: “If I was gonna drop a method off, it would probably be surveys,” he said.
Small‑utility representatives described how their size both helps and hinders safety work. Several speakers said smaller organizations can communicate quickly and put leadership in close proximity to front‑line staff, enabling faster action after a near miss; others cautioned that close interpersonal ties can suppress candid reporting or create blind spots. Utilities with parent‑company structures reported using company‑wide surveys plus local interviews to track trends, while very small distributors (seven employees) said they manage safety largely through routine, face‑to‑face communication and would need flexible, low‑burden assessment options.
The workshop closed with a procedural note: SPD and the assigned administrative law judge will post reference materials and schedule filings. ALJ Chang said he will file a ruling setting dates for comments and for party proposals on scaled approaches in the coming week. Carolina said the record will accept party proposals and that another workshop will follow to vet proposals for assessments of small utilities.
Next steps: parties will file comments on the workshop and proposals for how to conduct safety‑culture assessments for small utilities; SPD will continue refining the scope and practical guidance for tailoring assessment methods to organization size and complexity.
