- 201 - 7.4 Measures envisaged by ASN to strengthen the requirements concerning the conditions for the use of contractor companies ASN shall be taking several measures to reinforce the supervision of and requirements concerning the conditions for the use of contractor companies. First of all, one observation is that the various elements presented by EDF in the CSA reports are sometimes contradicted by feedback from the "field", meaning that ASN's inspections of the use and management of contractors by EDF will continue in the coming year, through a programme of specific inspections. ASN monitoring of the "contractors" topic is being coordinated and performed jointly with regard to safety and labour inspection, as ASN is responsible for monitoring nuclear safety and labour inspection in the NPPs: occupational health ands safety, working conditions and quality of employment of EDF staff, its contractors or its subcontractors, in the same way as the safety of the facilities, are the subject of coordinated monitoring and inspection. In 2011, all the NPPs were inspected on the "contractors" topic, except for Golfech, which had been inspected in 2010. For the coming year, ASN monitoring will in particular look at the regularity of the labour relations. In addition, ASN will systematically review the follow-up of sub contractor-related inspections. As and when necessary, ASN will carry out inspections on the subcontractors. ASN will eventually extend the inspections to intellectual services and to the conditions of work by approved organisations carrying out the statutory checks and inspections. In the regulatory field, ASN submitted proposals to the ministers for nuclear safety, for the introduction of strengthened provisions concerning subcontractor monitoring into the order laying down the general rules for basic nuclear installations. ASN in particular proposed that this order stipulate that the monitoring of activities important for safety performed by an outside contractor must not be delegated. Furthermore, in the general operating rules (GOR) the licensee will have to specify the principles and the organisation underpinning this monitoring, as well as the resources devoted to it, and shall justify that these are sufficient in the light of the scale of the activities important for safety entrusted to the outside workers. Finally, this order explicitly states that the licensee shall take all steps to ensure that the outside workers can detect any deviations concerning them and bring them to the licensees attention as rapidly as possible. In 2011, ASN and the General Directorate for Labour (DGT) worked together on a draft order defining the conditions for certification of companies performing maintenance or other work on nuclear facilities or using equipment emitting ionising radiation. Article R. 4451-122 of the Labour Code stipulates that "The contractors performing maintenance or other work or using equipment emitting ionising radiation may only perform the activities specified on a list determined in the order, once they have obtained a qualification certificate proving their ability to perform work involving ionising radiation". Pursuant to article R. 4451-124 of the Labour Code, this order aims to enshrine in the French regulations the arrangements made by some licensees, while reviewing the list of activities or activity categories for which this certification is required, as well as the accreditation and certification procedures and conditions. With regard to radiation protection, ASN intends to make a contribution to harmonising international regulations concerning dosimetric monitoring of roaming foreign workers. Thus, the specific question of subcontractors from abroad has been examined since 2007 by the HERCA association of European radiation protection regulatory bodies. Consideration is being given to creating a European dosimetric passport, which would mean that the dose received by persons having worked in a nuclear power plant abroad would be known in France. Finally, all the additional information to be requested from EDF on the basis of the elements presented in this chapter, will contribute to IRSN's analysis as part of the investigations conducted at the request of ASN on the topic of management of safety and radiation protection during unit outages and the oversight of subcontracting by EDF.
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