- 336 - With regard to the doctrine and procedures managing the use of contractors, their conditions for access to the various sites and their working conditions on these sites, AREVA stated that there is a group level doctrine, which comprises: the values charter, in which the contractors are identified as stakeholders and which promotes a sustainable partnership relationship to ensure the best possible level of services; the "nuclear safety" charter, which promotes identical treatment of the employees of the group and those of the contractors, with regard to safety and radiation protection; a sustainable development commitment applicable to the suppliers, requiring that a high level of safety, health and security be achieved in the subcontracted interventions; the "safety, security, health, radiation protection and environment" directive for contractor working conditions; the acceptance procedure for radioactive clean-up contractors; the instruction concerning the placing of contracts comprising radioactive clean-up and decommissioning services. On each site, this "group" doctrine is implemented through operating procedures or documents (the titles of these documents varies from site to site) covering the following general topics: safety; health and safety; radiation protection; what is expected of the contractors in terms of training, qualification, operational documents, working clothes, equipment, etc.; establishment of the work permit, which must be obtained prior to the beginning of the interventions. With regard to contractor training, AREVA stated in its reports that the competence, training and qualification requirements are stipulated in the technical and other specifications, but without checking to ensure that there is exhaustive verification of these skills, training and qualifications. AREVA stated that each site provides "visitor security" training to each new arrival on the site and, as applicable, takes steps to ensure awareness of or provides specific training for particular operations (glovebox work for instance). Only the Mélox report indicates that the training given by the site is mandatory in order to obtain a work permit on the site. Methods for monitoring subcontracted activities The ASN specifications for the CSAs asked for a description of the methods for monitoring the subcontracted activities, in particular how the licensee continues to guarantee its responsibility for nuclear safety and radiation protection. The main steps in contractor monitoring within the AREVA group are as follows: the work kick-off meeting; the progress checkpoints stipulated in the contract; the closure meeting which goes over feedback data; filling out of the licensee's internal contractor evaluation sheet. Contractor monitoring comprises three levels of surveillance: technical surveillance (level 0); independent evaluations specific to each licensee (level 1); independent evaluations by the group's general management (level 2).
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