ENISS Initiative for Safety Management: Feedback and Recommendations

ENISS - Initiative 33rd NUSSC Subgroup Comments on the current orientation and potential issues of DS456 Leadership and Management for Safety

ENISS - Initiative DPP 456: Justification Main reasons for revising the GS-R-3 from 2006 to reinforce safety, better align it with the Safety Fundamental SF-1-Principles 1 & 3 and at the same time take into account the feedback on experience of application from member states. to reflect the new long-term structure for safety standards. In order to facilitate the implementation of the new requirements by the users, the part dedicated to the integrated management system will keep as much as possible the structure of the existing document 2 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative DPP 456: The requirements established in the new publication may be used by organizations in the following ways: As the basis for organizations directly responsible for operating facilities and activities and providing services; As the basis for the regulation of these facilities and activities by the regulatory body; By the licensee, to specify to a supplier, via contractual documentation, any specific requirements of this Safety Requirements publication that must be included in the supplier s management system for the supply of items and services. 3 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative General feedback on GS-R-3 Implementation - Member states and facilities: Safety must be the fundamental basis of this document and shall have the highest priority; it must not be misunderstood to be considered as a product. The safety management objectives stated in INSAG 13 and other INSAG documents should be considered. Line management responsibility and accountability for safety should be emphasized. Interaction between line management and process management should be addressed. Clarification on the applicability of this document to vendors, contractors and suppliers should beprovided. 4 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative General feedback on GS-R-3 Implementation - Member states and facilities: Reinforce integration in such a way that other businesses do not reduce or impact safety and of course the review of the management system shall be done in that way. As a management system standard, GS-R-3 could bring out the importance of organizational learning, good communication of safety issues, a sense of reality around prioritization, clarity about organizational structure and accountability on what has to be performed. GS-R-3 could address the importance of leaders' performance in terms of organizational behaviours, leadership behaviours and individual behaviours. 5 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative General feedback on GS-R-3 Implementation - Member states and facilities: GS-R-3 could bring out the importance of organizational learning, good communication of safety issues, a sense of reality around prioritization, clarity about organizational structure and accountability.. be clearer on subjects related to improvement, resource management, management oversight, problem identification and resolution, managing organizational change. include items on organizational learning, use of experience benchmarking (inside and outside the nuclear industry), questioning attitude, human performance, configuration management Oversight of the management system could be strengthened from the perspective of organizational effectiveness assessment. 33rd NUSSC Subgroup V1 2012-11-18 6

ENISS - Initiative Current orientation of the draft of GSR Part 2 The scope of the safety requirements document has been changed from management system to leadership and management. The future GSR part II can be applied together with: ISO 9000 focus on quality and customer satisfaction ISO 14000 focus on the environment ISO 18000 focus on industrial safety or other similar standards 7 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative Current orientation of the draft of GSR Part 2 The application of DS456 is focused on license holders operating a facility or conducting an activity that give rise to radiation risk activities. This is in line with the scope of SF-1 as well as principle 1in SF-1. The reduction of the number of requirements has lead to more general expressions. However, there are challenges to develop short expressions with broad coverage. The intention is an integrated Management System, where Safety Management is integrated and Nuclear Safety is not compromised. The management system is described as a tool with its components and not as a self standing purpose. 33rd NUSSC Subgroup V1 2012-11-18 8

ENISS - Initiative Current orientation of the draft of GSR Part 2 The intention is that the process implementation and other tools are not over emphasized and in a balance. By giving Safety Culture its own chapter is the importance of this issue is emphasized. New requirement 11 - Management of contracted parties underline the licensee overall responsibility for safety which is in line with the requirements in SSR-1. 9 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative Potential Issues Common answers The structure/sequence of the requirements should be reviewed to ensure that the integrated management of Nuclear Safety is well understood. A minimum of the needed effective generic processes needed should be added, e.g. purchasing and the non-conformance control . Detailed comments on the wording, made by Member states and observers should be considered. The same structure of GS-R-3 and GS-G-3.1 3.5 was user-friendly. The expression performing activities safely refers to industrial safety. That Nuclear safety is not compromised should be clearly expressed. 10 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative Potential Issues Differing answers The users of the requirements document are not clearly specified The new arrangement of the requirements and the general nature of the requirements makes it difficult to assess the gap between conventional requirements for the management systems. The basis for many requirements placed on the licensee and vendors disappears. The reduction of the number of requirements has led to more general expressions, which in some cases are difficult to understand. 11 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative ENISS/WNA Recommendations The users of the GSR part II should primarily be the license holders. However, GSR part II should clearly put a requirement on the licensee that the management system shall include routines and processes that ensures that any relevant safety requirement is imposed on vendors and contractors. ENISS/WNA considers the current draft well balanced, emphasising nuclear safety and highlighting safety culture. However, the draft could be further enhanced by considering the general recommendations and the detailed comments on the wording made by Member states and observers. The same structure of GS-R-3 and GS-G-3.1 3.5 is user-friendly. GS-G3.1 3.5 will adopt the same structure like GSR part II. 12 33rd NUSSC Subgroup V1 2012-11-18

ENISS - Initiative BACK UP 13

ENISS - Initiative DPP456: Objectives for revising GS-R-3 Principle 1: Responsibility for safety The prime responsibility for safety must rest with the person or organization responsible for facilities and activities that give rise to radiation risks. Principle 3: Leadership and management for safety Effective leadership and management for safety must be established and sustained in organizations concerned with, and facilities and activities that give rise to, radiation risks. 14 33rd NUSSC Subgroup V1 2012-11-18