Health and Safety
Executive
The Regulation of Safety,
Security and Safeguards in UK
Mark Bassett
HM Deputy Chief Inspector
Office for Nuclear Regulation
Contents
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Office for Nuclear Regulation
Legislative and Regulatory Framework
Joined-up Regulation
Some Thoughts
Office for Nuclear Regulation
ONR Mission: Secure the protection of people and society from the
hazards of the nuclear industry
We regulate safety, security, radioactive materials transport and
have responsibilities for safeguards
Currently an agency of Health and Safety Executive
The Energy Bill is currently going through Parliament for ONR to
become an independent public corporation
Target for “vesting” April 2014
Legislative and Regulatory Framework
Safety
Health and Safety at Work Act 1974
General duty on all employers to reduce risks So Far As Is Reasonably
Practicable (SFAIRP) – often known as ALARP
Goal-setting, non-prescriptive
Dutyholders should identify and implement reasonably practicable
measures to improve health and safety
HSWA enables number of regulations
e.g. Ionising Radiations Regulations – sometimes more prescriptive
Nuclear Installations Act 1965 Relevant Sections
Legislative and Regulatory Framework
Safety continued
Prescribed Installations – Licensed
36 Standard Licence Conditions – shall make and implement adequate
arrangements
e.g. LC14 production and assessment of safety
LC23 safety case to set limits and conditions
LC11 Emergency arrangements.
Permissioning Regime – e.g. Consents and Approvals
Inspectors appointed under S19 of HSWA and powers e.g. S20 plus
enforcement powers
Internal guidance to our inspectors – Safety Assessment Principles
Legislative and Regulatory Framework
Security
Anti-Terrorism, Crime and Security Act 2001.
Nuclear Industries Security Regulations 2003 (amended 2006).
Places obligations on operators of civil licensed nuclear sites.
– physical security measures
– security of sensitive nuclear information
– vetting of staff and contractors
– movement of nuclear material by road and rail
– (and now in 2013) obligations on new build
Legislative and Regulatory Framework
Security - continued
Secretary of State sets the “risk appetite”
ONR developed National Objectives, Requirements and Model
Standards (NORMS)
Sets Objectives and Requirements – and recommends model standards
(or adopt others that demonstrate meet the objectives)
Design Basis Threat – Nuclear Industry Malicious Capability Planning
Assumptions
ONR formally approves Nuclear Site Security Plan (NSSP) compromises a security case and an integrated protection solution (IPS)
ONR inspects against the plan
Legislative and Regulatory Framework
Security - continued
NSSPs in process of being written by dutyholders.
All Cat 1 sites to have approved plans by November this year. Lower
category sites by August
Security was more prescriptive than safety but NORMS part of the
journey towards more goal-setting approach
Inspectors appointed under S19 HSWA
– S20 powers as applied by regulation in NISR
– some sections of the IRRs
HSWA S2 and 3 don’t apply e.g. SFAIRP
But where appropriate we consider “as secure as reasonably
practicable”
Legislative and Regulatory Framework
Safeguards
Safeguards – measures to verify that countries comply with
international obligations not to use nuclear materials for nuclear
explosives
UK safeguards obligations:
– Euratom Treaty
– Safeguards agreement between UK, IAEA and Euratom in
connection Non-Proliferation Treaty
The safeguards “regulators” are the international safeguards
inspectorates of the IAEA and the European Commission, not ONR
Legislative and Regulatory Framework
Safeguards - continued
International safeguards regime:
– reporting (declaration)
– assessment and inspection (verification).
What does ONR do?
– works with Euratom and IAEA inspectorates and UK organisations
so that obligations are met in an proportionate manner
– fulfils the safeguards related obligations that are the direct
responsibility of the UK Government
– provides advice and support to DECC and OGDs on safeguards
implementation and policy development.
Joined-up Regulation
Programme working;
– Same approach to strategy, planning, resource and monitoring,
risk and issues management
New Operating Model
– integrated structures based on matrix working
e.g. Sellafield Programme – safety, security, safeguards being
integrated into our governance arrangements, all feed into our
strategic themes e.g. leadership and management (for 3S), asset
management, disciplined operations
Security-informed nuclear safety (SINS) team
Joined-up Regulation
Specific Examples
Materials Consolidation – Dounreay to Sellafield (one project integrating
safety, security, transport, safeguards) “one-stop shop”
Generic Design Assessment and New Build (Safety/Security – safeguards
piggy-backing)
Emergency Arrangements – joint safety and security exercises
Security enhancements – potential conflict between security and hazard
reduction. What’s the overall holistic solution?
Joined-Up inspection with Euratom on new Pu stores prior to permissioning
operations.
Linkage/leverage with licensees – multi-level messaging
Reporting and OPEX
Some Thoughts
It’s still a journey – More to do and want to learn from others
Main barriers are cultural and our thinking – not legal structures etc.
Need for overall safety/security/safeguards culture
Think 3S – Mutual awareness and understanding