- 193 - 7 Conditions concerning the use of outside contractors (excluded from the scope of the European "stress tests") The Fukushima accident showed that the ability of the licensee and, as necessary, its contractors, to work together in a severe accident situation is a key factor in managing such situations. This ability to work together is also crucial for the maintenance of the facilities, the quality of their operation and the prevention of accidents. The conditions concerning the use of subcontractors are thus of particular importance and must enable the licensee to retain full control over and responsibility for the safety of its facility. This importance was also underlined by the stakeholders, particularly the HCTISN, right from the beginning of the ASN process to draft the specifications for the CSAs. The ASN specifications thus asked the licensees to analyse the conditions for the use of contractor companies. In addition, and more generally speaking, ASN considers that integrating socio-organisational and human factors into the safety approach is vital and this aspect is considered both in the checks carried out by ASN and on the occasion of the periodic safety reviews of the facilities. Experience feedback from the Fukushima accident will also be taken into account in this respect. With its experience in the field of labour law oversight as well as in nuclear safety, ASN has already initiated a campaign of targeted inspections on the topic of subcontracting of activities within the EDF nuclear power plants. These inspections, carried out by teams comprising labour and nuclear safety inspectors, will be continued in 2012 and expanded to take in the nuclear facilities of other licensees, jointly with the ministry for labour. ASN had already made plans to conduct more detailed examinations of the conditions concerning the use of subcontracting in EDF's nuclear power plants on the occasion of the two scheduled meetings of the advisory committee for nuclear reactors: one concerning safety management and radiation protection during reactor outages, the other specific to examining the oversight of the subcontracted activities. The additional requests submitted by ASN following the CSAs on those points which, given the time allotted for these evaluations, would not have been sufficiently detailed in the EDF reports, will in particular be investigated during this indepth examination, for which ASN is calling on the expertise of IRSN and the opinion of the advisory committee for nuclear reactors. 7.1 Scope of activities concerned by subcontracting The ASN specifications for the CSAs require a description and justification of the scope of the activities concerned by subcontracting, demonstrating that this scope is consistent with the licensee's full responsibility for nuclear safety and radiation protection. In the CSA reports, EDF defines the contractor company as the company holding a contract and a subcontractor as an individual or corporate body who has received from the contractor company a part of the contract concluded with the client (in this case, EDF). For EDF, contractor personnel refers to the employees of a company, regardless of the level of subcontracting (contractor company or subcontractor). EDF announces that the activities subcontracted annually involve 20,000 external employees, including 18,000 working in the controlled area52, 5,000 at a local level and 15,000 at a regional or national level. Temporary and fixed-term contract (CDD) workers account for 15% of the outside contractor personnel working in the controlled area. 6 to 7% of the total number of contractor personnel are foreigners, or some 1,200 workers. These 20,000 employees of outside contractor companies are reinforcements for the 10,000 internal employees of EDF, who handle daily maintenance, preparation, oversight and verification of the correct performance of maintenance work during reactor outages. EDF explains that the activities are subcontracted when there is a need to call on rare skills and specialised manpower, as well as to deal with activity peaks and the particularly seasonal nature of reactor outages. With respect to the nuclear power plants in operation, these requirements regarding activities subcontracted to contractor companies concern maintenance work, but also, for example, "security radiation protection" and 52 As defined in article R.4451-18 of the labour code
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