- 200 - o the actual weight given to "best-bidder" criteria in the contracting process, in order to assess the consequences of the EDF buying policy on working conditions, safety, quality and application of social and labour laws. A lack of information concerning how EDF: o ensures that the outside companies working on the site take the defined preventive measures, in particular that appropriate information about the risks of ionising radiation is actually provided by the occupational physicians of the contractor companies, o deals with the qualification and monitoring of temporary contractor groups (GME), o evaluates the organisation put into place by the contractor companies (tier 1) to monitor the subcontractors of tier 2 or higher, and to qualify a subcontractor as deficient, thus triggering monitoring of its activities, through the production of a work evaluation form (FEP). The evaluation of the contractor companies by the qualification organisation is neither systematic nor performed on a multi-year basis. With regard to the contractor companies inspected and sanctioned, EDF does not give the frequency at which these penalties are applied, nor how such penalties are monitored. ASN also considers that the presentation of the monitoring procedures for activities subcontracted by EDF raises the question of the dilution of responsibility for monitoring contractors of tier 2 or higher (phenomenon of "cascaded" subcontracting). To conclude, ASN considers that in the CSA reports, EDF did not sufficiently demonstrate that the scope of the subcontracted activities, both in terms of the types of activities concerned and the internal skills preserved, is compatible with the licensee's prime responsibility for safety and radiation protection. The additional information to be requested from EDF on the basis of the elements presented in this chapter, will contribute to the IRSN analysis as part of the investigation carried out at the request of ASN on the topic of subcontracting oversight by EDF. The Advisory Committee for nuclear reactors will be asked for its opinion on the oversight of subcontracting by EDF in late 2013. Finally, ASN considers that the question of subcontracting must be considered in the same way as all aspects relating to humans and how they interact with systems (technical, organisational, etc.). This area of concern is referred to as "Organisational and Human Factors" (OHF). The lessons that could be learned from the Fukushima accident must thus be seen in the light of a detailed OHF analysis, on the one hand to understand the accident scenario (before the accident, during management of the dynamics of the accident and during the emergency management phase), and on the other, to validate the practical application of the measures resulting from the CSAs. ASN thus considers that the questions of subcontracting and OHF must be the subject of attentive, continuous review, implementing methodologies that are scientifically sound and going further than a simple documentary analysis. This review should in particular cover the following points: the link between subcontracting and the exercise of licensee responsibility, the effects on safety of particular contracting methods (cascaded subcontracting, internal or external subcontracting, best-bidder, etc.), the effects of contractor working and living conditions on safety, the risks relating to the potential loss of skills. ASN also recommends that research programmes be initiated, at both national and European levels.
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