This essay argues that: (1.) The concepts of both “safety” and “safety culture” are under-developed in organizational analysis. This has led to ambiguity and confusion in our understanding of the causal connection of both to specific elements of organizational structure. (2.) There is more complexity in the link between structure and safety culture as features of organization than might be supposed. The actual content of structural elements such as roles and rules, functional lines and limits of authority, accountability and communication – can themselves require closely supporting cultural norms of acceptance to actually function as formally described. Otherwise a formal organization chart can be a highly misleading picture, as they often are, of actual transactions occurring within a functioning organization. (3.) But the relationship between structure and safety culture can be different in the different phases of (1) the initial change of cultural or sub-culture features that undermine safety, (2) safety culture development and finally, (3) the challenge of the continued maintenance of a safety culture over time in an organization. (4.) Both specific safety management structures and a reinforcing safety culture are essential within an organization to reach across the scope of activities and time frames necessary for reliable safety performance. The implications of these points are explored for both future safety research and regulatory practice concerning organizational structure and safety culture and, ultimately, to connecting both to the improvement of safety performance.

In December of 2018 the California Public Utilities Commission (CPUC), the major utility regulator in the state of California issued an order to investigate the Pacific Gas and Electric Company (PG&E), one of its largest regulated utilities, to “determine whether PG&E’s organizational culture and governance are related to PG&E’s safety incidents and performance record, and if so, to what extent.” (CPUC, 2018). The underlying idea was to investigate whether restructuring the utility in both its overall corporate organization (as a single integrated investorowned utility) as well as its internal governance and corporate management structure would allow PG&E “to develop, implement, and update as necessary a safety culture of the highest order.” Structural options to be considered included breaking up the utility into separate smaller, regional entities; or separate electric and gas utilities; or even reconstituting PG&E as a publicly owned utility or utilities. Governance restructuring questions to be asked in the investiation included should the utility’s Board of Directors be accountable for safety apart from its other fiduciary responsibilities?