Version No:

4

OG Status:

Fully Open

Author Section:

ND

Issue Date:

1 October 2007

Review Date:

01 October 2010

To:

ND Inspectors

 

1. Purpose & Scope

1.1  This guidance provides supporting information for procedure AST/004 - ND Issues Recording Process, and describes how the COIN Issues Database should be used to support it.

1.2  ND expects its Inspectors to discuss with the Duty Holder and resolve any Issues or points of clarification from their assessment before the assessment task is completed, and to ensure that there is a formal record of them and how they have been resolved. The guidance given in this document applies to assessment issues not resolved during the course of assessment, and to all other issues raised with Duty Holders.

1.3  The computer based COIN Issues Database is used to record details of ND Issues raised with Duty Holders by ND Inspectors. Detailed guidance on how to use the COIN Issues Database is contained in the ND - Recording Issues Guide [638KB] (See Associated Document 3.1).

2. Guidance

Definition of an ND Issue

2.1  An issue is a finding, concern or point of variance with a Duty Holder, identified during the regulatory process, which is considered important to safety and which requires action by the Duty Holder in order to satisfy the tests of adequacy or compliance in relation to a regulatory decision. As defined in 1.2 it becomes an ND Issue if there are significant points of concern or action for the Duty Holder following the completion of the assessment process. There is a strong link between ND Issues and recommendations for follow-up actions in completed assessment reports.  However the ND Issues database should not be used as a general action tracking system, so, for example, a recommendation agreeing to a permissioning activity would not be an ND Issue even though it is a recommendation in an Assessment Report.  ND Issues are mainly reserved for Assessment Report recommendations that are linked to further work being required of the duty holder or internally within ND.

2.2  There are a number of tests to assist in deciding whether an issue is an ND Issue. The first is, does the Duty Holder need to undertake further work, such as additional calculations, analysis, research etc. A request to provide further information on a topic, where this is work referenced in a report being assessed, or other information known to exist, would not be an ND Issue. This is simply an action placed on the Duty Holder, and should be managed as such, either on a Unit or individual basis.

2.3  If the potential ND Issue requires the Duty Holder to undertake further work, it should be nominated as an ND Issue only if the Originator sees it as essential that the matter be satisfied. If the associated activity is in the category of “desirable but could be dropped if other priorities intervene” then it should not be elevated to an ND Issue status.

2.4  If the potential ND Issue arises from assessment, and without resolution the Inspector is unable to determine whether a safety case is satisfactory, it is an ND Issue and should be entered in the database.

2.5  If the potential ND issue arises from compliance inspection, it will be included in the Visit Report for the inspection, and managed as part of the Site Inspector’s normal regulatory business. However, if the recording of the management and resolution of the issue would make a significant contribution to ND’s corporate memory it should be included in the database. This is expected to be the case for ND Issues arising from Team Inspections and Audits.

2.6  If the potential ND Issue arises from a technical inspection carried out by a Specialist Inspector, it should be processed as though it had arisen from assessment.

2.7 If the potential ND issue, from whatever source, is so important that, if it is not resolved to the satisfaction of NII, it would be expected that formal enforcement action would be considered, it is an ND Issue and should be entered in the database.

2.8 Other issues which do not pass any of the tests outlined in the previous paragraphs should be considered as actions on the Duty Holder, and managed on a Unit or individual basis by other means.

2.9 Other issues (see 2.8) on the Duty Holder may, as they develop significance, become ND Issues. When they do, they should be entered on the ND Issues Database.

2.10 ND Issues must have an originator who is responsible for taking it to closure. Normally the originator and therefore the owner is the author of the assessment report from which the ND Issue originated. Recommendations from Assessment Reports meeting the requirement of an ND Issue but placed on another inspector must only be made if the author has agreed the recommendation with the inspector in question and has an ND Issue number which must be entered into the Assessment Report. All other recommendations assigned to the Author of the Assessment Report meeting the requirements of an ND Issue can be entered into the COIN database after the report has been finalised but by no later than ten working days.

Categories of Significance of Issue

2.11  Within the COIN ND Issues Database, ND Issues are categorised as high, medium or low with its importance reflected by either: 

1. how safety critical is its resolution, or
   
2. how time critical is its resolution, or
   
3. if it is linked to a regulatory decision or hold point.

Originator of an Issue

2.12  All Inspectors, including SIs, can raise ND Issues. The Inspector raising an ND Issue is known as the Originator. 

Ownership of an Issue

2.13  The Owner of an ND Issue is the ND staff member responsible for ensuring that the issue is resolved and closed out. The Owner of an ND Issue will normally be the Originator. However, in some circumstances it may be appropriate for a Project Officer or Site Inspector to own an Issue. Examples of this are:

1. Where several ND Issues raised during the course of a multi-disciplinary assessment (e.g. PSR) are better progressed generically, or where the resolution of an issue cannot be achieved by normal technical discussions, it may be appropriate for the Project Officer to pursue them.
   
2. Where an ND Issue relates to a failure to comply with a Licence Condition or Licensee’s Arrangements, it may be appropriate for the Site Inspector to pursue it.

2.14  If the Owner of an ND Issue is transferred from the post in which the Issue was raised, a decision must be made, which must be endorsed by the Unit Head, on the future ownership of the Issue. If the responsibility for resolving and closing out the ND Issue is to be transferred to the incoming post holder or to another ND staff member, the present Owner must enter the change of ownership in the COIN ND Issues Database.

Recording an Issue

2.15  Once an ND Issue has been raised formally with a Duty Holder, it should be entered in the COIN Issues Database within ten working days; guidance on using the database is provided in the COIN: ND - Recording Issues Guide [638KB] (See Associated Document 3.1).

2.16  Once an ND Issue has been saved in the database, comments may be added. These are automatically numbered and dated when they are saved.

Managing the Progress of an Issue

2.17  Once an ND Issue has been entered on the Database, its progress towards resolution should be periodically recorded. The notes field of the database is used for this purpose, and periodic progress comments should give an indication of how close an Issue is to being resolved. This is particularly important if a “Required Completion Date” has been set. Heads of Unit shall routinely check the database to ensure that the system is functioning correctly and is being appropriately used by Unit staff, the frequency of this check should be no greater than once a quarter. Heads of Division shall review the position of the status of ND Issues assigned to their Division with Unit Heads at their mid-year and end-of-year reviews.

Closing Out an Issue

2.18  Once an ND Issue has been resolved it must be closed out on the ND Issues Database. This is done by entering the TRIM record where the closing reference can be found. This may refer to a letter, minute, meeting notes etc. in which case the TRIM reference must be stated, or it may be a free text entry giving a summary of how the issue was resolved.

2.19  Once a closing reference has been entered and saved in the database, it is no longer possible to edit the data, i.e. change any details or add further comments.  It is, therefore, important to ensure that all the details and comments are up-to-date before the closing reference is entered.

3. Associated Documents 

• 3.1 ND - Recording Issues Guide [638KB]
• 3.3 AST/001 - Assessment Process
• 3.4 AST/003 - Assessment Reporting
• 3.5 AST/004 - Issues Recording Process