With the aim of preventing conflicts of interest, the rules in force at ASN more specifically include the following declaration obligations: ∙ Public Declaration of Interests (DPI) stipulated in Article L. 1451-1 (derived from Act 2011‑2012 of 29 December 2011 on strengthening the safety of drugs and health products) and Articles R. 1451-1 et seq. of the Public Health Code: the 4 July 2012 decision CODEP-CLG-2012-033820 by the ASN Chairman applies the DPI requirements to the members of the Commission, the management committee and the Advisory Committee for Radiation Protection for Medical and Forensic Applications of Ionising Radiation (GPMED). Until mid‑July 2017, the DPI were posted on the ASN website. The DPI are henceforth declared on the single on-line declaration site. About 60 people are subject to the DPI; ∙ Declarations of Interests and assets to the High Authority for Transparency in Public Life (HATVP) derived from Act 2013‑907 of 11 October 2013 on Transparency in Public Life: the members of the Commission submit their declarations on the HATVP website. The same applies to the Director General, the Deputy Director Generals, and the General Secretariat since 15 February 2017 following modification of the Act of 13 October 2013; ∙ “Civil service” Declaration of Interests introduced by Act 2016‑483 of 20 April 2016 into Article 25 of Act 83-634 of 13 July 1983 and governed by Decree 2016-1967 of 28 December 2016: the professional ethics officer and the ASN staff carrying out labour inspectorate duties in the NPPs are subject to this obligation; ∙ Management by the ASN Director General of his or her financial instruments in conditions which preclude all right of review on his or her part, pursuant to Article 25 quater of the 13 July 1983 Act and Decree 2017-547 of 13 April 2017: the ASN Director General submitted justification data to the HATVP before 2 November 2017. In a decision dated 28 January 2020, the ASN Chairman appointed Alain Dorison as professional ethics officer. Procedures for collecting internal ethics alerts from ASN personnel, pursuant to Act 2016-1691 of 9 December 2016 and Decree 2017-564 of 19 April 2017 were also put into place. The alert concerns an ethical problem, but also the case of a staff member witnessing a misdemeanour or serious prejudice during the exercise of their duties. In addition to the obligations recalled above, ASN defined a new internal monitoring procedure for staff wishing to work in the private sector or requesting permission to add a professional activity, in order to create or take over a company, in accordance with Act 2019-828 of 6 August 2019 on the transformation of the civil service and Decree 2020-69 of 30 January 2020. Actions to raise personnel awareness, in order to enhance the in-house ethics culture and prevent conflicts of interest were also carried out, such as placing practical documents on-line on the intranet (for example, on the prevention of conflicts of interest and the role of ethical supervision in the event of departures to the private sector), the inclusion of a module on professional ethics rules applicable to ASN staff during training sessions held for new arrivals and a video interview in which the professional ethics officer uses a few examples to explain professional ethics and which professional activities require particular vigilance. Financial resources ASN’s financial resources are presented in point 3. In its opinions of 27 April 2021 and 23 September 2021, ASN considers that the current budgetary set-up dedicated to the IRSN’s technical support for ASN is both fragile and lacking in transparency, and underlines the need to guarantee a level of the IRSN budget financing which enables it to continue to meet ASN’s technical support requirements in good conditions (see point 3). ASN management tools ASN’s management tools are more specifically evaluated during peer review missions (Integrated Regulatory Review Service – IRRS), devoted to analysis of the French system of regulation and oversight of nuclear safety and radiation protection (see box in the following page). The Multi-Year Strategic Plan The Multi-year Strategic Plan (PSP), produced under the authority of the ASN Commission, develops ASN’s strategic lines for a period of several years. It is presented annually in an operational guidance document that sets the year’s priorities for ASN, and which is in turn adapted by each entity into an annual action plan that is subject to periodic monitoring. This three-level approach is an essential part of ASN’s organisation and management. Available on asn.fr, the PSP for the period 2018-2020 comprises the following five strategic points: ∙ reinforce implementation of a graded and efficient approach to our regulation and oversight; ∙ improve the running of technical investigations; ∙ reinforce the efficiency of our actions in the field; ∙ consolidate our operation to the benefit of regulation and oversight; ∙ promote the French and European safety approach on the international stage. In the current context, this plan remains particularly valid and requires further action on each of the points recalled above. For example, the Covid-19 pandemic requires acceleration of the ASN’s digital transformation actions, which naturally fall under point 4 of the PSP. This is why the PSP was extended for a further two years. Throughout 2022, ASN will conduct a strategic study, in order to prepare its new PSP for a five-year period (2023-2027). The ASN internal management system Within ASN, there are many forums for discussion, coordination and oversight. These bodies, supplemented by the numerous cross-disciplinary structures, reinforce the safety culture of its staff through sharing of experience and the definition of coherent common positions. Quality management system To guarantee and improve the quality and effectiveness of its actions, ASN defines and implements a quality management system inspired by the international standards of the IAEA and the International Standard Organisation (ISO). This system is based on: ∙ an organisation manual containing organisation notes and procedures, defining the rules to be applied for each task; ∙ internal and external audits to check rigorous application of the system’s requirements; ∙ listening to stakeholders; ∙ performance indicators for monitoring the effectiveness of action taken; ∙ a periodic review of the system, to foster continuous improvement. Alain Dorison, Professional Ethics Off icer, appointed by the ASN Chairman in January 2020 ASN Report on the state of nuclear safety and radiation protection in France in 2021 133 02 – THE PRINCIPLES OF NUCLEAR SAFETY AND RADIATION PROTECTION AND THE REGULATION AND OVERSIGHT STAKEHOLDERS 08 07 13 04 10 06 12 14 03 09 05 11 02 01 AP
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