IRRS follow-up mission to France - October 2017

25 4. MANAGEMENT SYSTEM OF THE REGULATORY BODY 4.1. IMPLEMENTATION AND DOCUMENTATION OF THE MANAGEMENT SYSTEM 2014 MISSION RECOMMENDATIONS, SUGGESTIONS R5 Recommendation: The ASN management system should be completed and fully implemented, in an integrated manner, for all processes needed to deliver ASN’s mandate. A systematic analysis for identifying the required processes should be conducted, taking into considerations all the relevant requirements. S6 Suggestion: ASN should consider updating relevant parts of the management system and associated processes to ensure the management system promotes and supports a strong safety culture in the regulatory body. Changes since the initial IRRS mission Recommendation 5: ASN’s management system includes 12 key processes divided into management, core and support processes. ASN’s management system has been further developed since 2014 and now seems comprehensive. ASN has published several new procedures since the initial IRRS mission especially related to the authorisation process. In addition, common procedures with ASN and IRSN are now formally included in the system. Some of the procedures are still under development (for example the procedure concerning PSRs of NPPs, see S8). Management system documents are available in an electronic format and can be accessed by any ASN staff member on the intranet. The quality policy statement is being updated to explicitly present ASN’s mission, values and the two main management system objectives: improving nuclear and radiation safety and improving the efficiency and consistency of ASN’s actions. Suggestion 6: ASN is drafting two new policy documents incorporating the aspects of safety culture: the first on oversight policy and the second on revised quality policy statement. In addition, ASN is drafting a collective commitment document linking the ASN values to the safety culture principles. ASN organised 18 internal staff seminars to discuss ASN oversight, including several safety culture aspects. ASN also used an external human factors expert to carry out an internal survey about the staff commitment and the culture of the organization. Another enquiry was lead with external counterparts to get some regulatory experience from them. The results from the seminars and from the enquiries were used when drafting the policy documents and the collective commitment. ASN considers that the draft policy documents are in line with the IAEA safety culture principles. In 2018, ASN plans to check the consistency of management system documents with the new policy documents and to update them as necessary. ASN also plans to include safety culture principles in the inspector training programmes. ASN has not yet made plans for carrying out safety culture self-assessments which they could use to further develop their safety culture. Status of the finding in the initial mission Recommendation 5 (R5) closed on the basis of progress made and confidence in the effective completion. Since the initial IRRS mission in 2014, ASN has continued to develop the structure of its management system and published many new procedures. The IRRS team found that the structure of the management system is comprehensive, however, some procedures still need to be published and the revised quality policy statement needs to be finalised.