Transcript GSR Part 2 – Why it is different and how to cope!

GSR Part 2 – Why it is
different and how to cope!
Peter Mullins
ONR Professional Lead – Human and
Organisational Capability
ONR HOC Professional Group
• ONR specialists in:
– Human factors
– Quality management
– Leadership and management for safety
• Managed through matrix structure:
– Line management in specialism
– Work in programmes
GSR Part 2
• Why it is different to GSR-3
• Broadly, what’s changed
• What’s next
Why it has changed: 1
• More emphasis on leadership, and management for
safety
• Global major accidents, experience and research show:
– Major accidents happen where there is a sophisticated
management system
– Common mode failure is safety culture, and the priorities and
proficiency of the leadership that drives it.
– These are qualitative not quantitative, improved by looking direct
at them, not only by altering management systems.
• Charles Haddon-Cave:
•
Why it has changed: 2
• IAEA trying to bring consistent ‘architecture’ to
requirements and guidance.
• Requirements are binding and so should be
high-level what to achieve, not how to achieve it:
– How goes into guidance with a ‘comply or explain’
status
Why it has changed: 3
• Problems with application of GSR-3 in a number
of countries led to representations to IAEA, e.g.:
– ENISS concerns – GSR-3 not focussed enough on
safety
– Spain and other countries where GSR-3 became
legal requirements:
• Led to legal pressure to address management system
matters that had nothing to do with safety
• Emphasis should be on delivery of safety, with
the integrated management system as a means
not the end
How it was written
• DPP specifying structure of document produced
~ 2010
• ONR involved as drafting consultants from
January 2012 (team of about 12 invited
members)
• Member state consultation:
– Summer/Autumn 2013 (I coordinated UK response)
– Modified draft in response February 2014
• IAEA due process for requirements will take at
least until early 2015
How GSR Part 2 Compares - Outline
• GSR-3: 1. INTRODUCTION
2. MANAGEMENT SYSTEM
3. MANAGEMENT RESPONSIBILITY
Chapter 4:
4. RESOURCE MANAGEMENT
• Most of the main management
5. PROCESS IMPLEMENTATION
system
of GSR-3
6. MEASUREMENT, ASSESSMENT
AND features
IMPROVEMENT.
• Slightly less detail
• Slightly more mention of safety
GSR Part 2:
1. INTRODUCTION
2. RESPONSIBILITY for Leadership, Management and Safety Culture
3. LEADERSHIP FOR SAFETY
4. MANAGEMENT FOR SAFETY
5. SAFETY CULTURE
Comparison of the approach:
• GSR-3
“ Management at all levels shall demonstrate its
commitment to the establishment, implementation,
assessment and continual improvement of the
management system and shall allocate adequate
resources to carry out these activities.”
• GSR Part 2:
“ The senior management of an organization shall ensure
that managers at all levels, including themselves,
demonstrate effective leadership and implement an
integrated management system giving an overriding
priority to safety and fostering safety culture”
Next Step
• DPP for guidance to replace GSG 3.1 and GSG
3.5 developed December 2013
– Drafting begins Q4 2014
– Aims to complete 2017
• Proposed Title: Leadership and Management for
Safety in Nuclear Installations
• Specifically aims to include ‘how’ guidance from
GSR-3 that was taken out of GSR part 2
– Also intend to consider 50 C/SG-Q
How do we adapt?
• We need to get used to the new architecture and
structure
– Structure and English less clear than GSR-3
– But (I believe) change of emphasis and general
content is right for safety
• Quality community needs to get used to
guidance rather than requirements:
– Comply or be able to demonstrate that have reached
equivalent standard
– Similar to goal setting legislation that regulators have
lived comfortably with for 30 years