Transcript ISO 19443 – update – Iain McNair

Birchwood – 24th July 2014
ISO 19443 - Update
Iain McNair
Reminder on what has been proposed
• September 2013 – Original proposal via BSI
from ISO - ISO/TC 85 - N1273
“Quality Management Systems - Specific requirements
for the application of ISO 9001 and IAEA GS-R
requirements by organizations in the Supply Chain of
the Nuclear Energy sector”
Proposal to base requirements on NSQ100 - Vers 0 Dec 2011- developed by
NQSA (AREVA and BV)
Supported by NucSIG SG as a starting point for drafting.
Development since (1)
• Paris meeting Mar 2014 – agreed that
generally supported internationally and
should proceed –
• ISO 19443 allocated as ref.
• Iain McNair from NucSIG and Phil Shaw from
UKAS adopted as experts to WG.
Development since (2)
• Drafting meeting set for ISO TC 85 meeting
Moscow, 2-4 June 2014 – Cancelled
• Meeting now scheduled for 15 October – Paris
• In the interim have set out what is happening
in newsletters and event at Stockton March
2014. Sought input from NucSIG members.
• Will submit to ISO WG after this event.
Government overview of UK
Nuclear Supply Chain - minutes of the UK
Government Departments of Energy (DECC) and Business (BIS) joint
ministerial led Nuclear Industries Council meeting on 14th April 2014
“Clarity on the scope, timing, and quality requirements of the
UK new build opportunities will allow improvement activity
to be appropriately timed.”
“There is a pressing need to establish a regime to qualify
products and systems for different technologies in the UK.”
“The supply chain has reported that they understand the
necessary quality requirements. However, on scrutiny it’s
clear that this is often not the case.”
Meeting with ONR Supply Chain and
Teleconf with members of NucSIG (1)
:
Issues that must be addressed specifically include
1. Nuclear Safety Culture (at all Tiers)
2. Leadership and Management for Safety principles
3. Must recognise Safety Categorisation / Classification – fits into Graded
Approaches see IAEA TECDOC 1740-2014 and SSG 30 – 2014 for latest guidance
4. Enhanced and encompassing vendor analysis. – transferability of
information. Recognition of what certification actually means.
5. Cascadability of requirements – document must be readable/
understandable down to nth level supply chain. Comes back to Contract
Reviews (and flows into Design Reviews)
6. Must understand the overarching responsibility of Licensees/Operators
and National laws applicable right down levels, regardless of globalisation
and internal / external contractual arrangements. As such must allow
Regulators / Licensee operators / Primary suppliers access to assure
throughout entirety of supply chain related to Management systems / QA
/QC, but going beyond in collaboration – eg BS11000 .
Meeting with ONR Supply Chain and
Teleconf with members of NucSIG (2)
7.
Integrated management taking in Safety, Security, Environmental etc
considerations.
8. Each level must be able to demonstrate it is an Intelligent Nuclear
Customer and then deliver to requirements.
9. Globalisation and Major, multi – body corporations / companies, in
multiple locations. All need addressed by requirements.
10.Non –Conforming, Counterfeit, Fraudulent and Suspect Items (NCFSI) –
Identification of and shared intelligence on. Include Reporting of Defects.
11.Operational Experience (OPEX) – Prompt sharing of information up and
down as well as across supply chain. Note this should also include knowledge
on matters arising on non-nuclear supply where the items are likely to be used in
the nuclear supply chain.
12.Lifetime records. Consideration needs to be given to latest developments
in Building Information Modelling/Management (BIM) or other labelled
Information system based approaches. Top down definition of what is
needed when, by whom, where and in what format.
Recent discussion with Chair of ConSIG
(1)
The most worrying story I am hearing is the lack of basic quality understanding in
many Tier 1/2 (depends where you sit how you label them) organisations and below;
and as such:
• Lack of ownership by them of nuclear safety categorisation / classification,
• Single discipline and holistic design reviews being glossed over and not including
Tier 3/4 specialist designers, Thus construction starting or even being completed
before the design is complete and resultant field changes / modifications or even
scrap and rebuild.
• Lack of flow down of safety / quality requirements - some Tiers not even
recognising the work is nuclear related.
• Failure to develop or use Quality Plans/ Programmes for the works - terminology is
an issue.
• Failure to use let alone comply with I&TP
Recent discussion with Chair of ConSIG
(2)
•
•
Failure to qualify special processes and operators despite the specifications calling
for these to be done. Failure to share Learning From Experience and notification of
non-compliances especially if found internally - commercial pressures applying
threats of legal action if the information is passed around has even been noted.
Lack of appreciation of "Suspect and Counterfeit Items". This is seen as a global
issue yet we are hearing of 'certified' materials and products that when received
bear no resemblance to the requirements. The resulting lack of confidence in
certification has led several UK Licensees / Operators to do independent
inspection and test of base materials on receipt. The other outcome is likely to be
much more intense assessment of suppliers and increased Independent I&TP.
Consequently documentation package requirements are not being cleared as work
progresses and thus products including structures are being quarantined until they
can be shown to conform.
I have even had reported to me a comment by a construction director - who
didn't last long on the project!
"You mean you expect us to deliver to the specification".
Conclusion
Everyone needs to go back to basics and ensures that
the whole of their management (CEO down to floor
level) understands exactly what is needed, and ensures
that clear management and technical requirements are
passed on and delivered against.
*************
“The man in charge must concern himself with details.
If he does not consider them important, neither will his
subordinates. Yes “the devil is in the details.”.”
Adml H Rickover; USNavy : 1982