IRRS follow-up mission to France - October 2017

36 of establishing and implementing an effective supply chain oversight strategy. In addition, in 2017 ASN began exploring how to better identify problems with CSFI. The IRRS team noted that it is essential to plan resources for the inspection of vendors, through a graded approach. Regulatory bodies need to emphasis to licensees that the responsibility for the oversight of suppliers and vendors lies with the licensees. Licensees are responsible to ensure that the suppliers and vendors are providing products and services in accordance with the required quality assurance standards and that the safety related requirements are communicated through the supply chain. The regulatory bodies should confirm that the licensee is meeting this obligation. The team also confirmed that regulatory bodies must have the legal authority to inspect vendors and suppliers. All contractors must understand that they can be inspected at any time. ASN should continue to work with international organizations such as the IAEA and NEA and with other countries to promote the exchange of information regarding the vendor inspection findings. This is particularly important as more and more vendors begin to provide products and services to the nuclear industry without previous experience in the industry. Regarding developing the ability to identify CSFI the IRRS team agreed with ASN that it is very difficult to identify the counterfeit equipment and components and the falsification of records and human behaviour cannot be predicted. The problem is not only for mechanical components but covers a wide area including the digital, electrical and computer components (including software) which can lead to cyber security issues. In addition, the regulatory body require sufficient enforcement tools (e.g., significant civil penalties and the possibility of additional legal action). Lastly, the IRRS team provided its views on the best methods for communicating the CSFI issues to interested parties. The team agreed with ASN that there are significant legal challenges of when and how CSFI issues can be introduced to the public. The IRRS team offered that ASN will need to closely coordinate with enforcement officials before communicating with interested parties.