Nuclear Equivalence

Approved by:

Ian Britten

Author Unit/Section:

ND

Target Audience:

ND Staff

1 Purpose and scope

1.1 This procedure provides a framework against which the nuclear skills, knowledge and experience of potential Nuclear Safety Inspectors in ND should be judged. It is primarily intended to be used to decide when and if Inspectors with a non-nuclear background have developed sufficiently to justify designation as Nuclear Safety Inspectors. It can also be used to assist Unit Heads with the routine continuous professional development of existing Nuclear Safety Inspectors

2 Policy

2.1 It is ND policy to ensure that Nuclear Safety Inspectors have the necessary competencies to fulfil their various roles, in particular in administering the Nuclear Installations Act 1965 (as amended) and in securing high standards of nuclear safety and radio-active waste management on licensed sites in Great Britain. The justification of this designation, and any associated pay benefits, will be based on a determination of whether they are sufficiently capable in terms of relevant nuclear skills, knowledge and experience.

2.2 From time to time, inspectors or specialists join ND from other parts of HSE to fulfil a role that requires them to develop into Nuclear Safety Inspectors. Staff in ND who are not currently designated for roles as Nuclear Safety Inspectors are also encouraged to develop towards Nuclear Safety Inspector provided that this aligns with business needs and personal career development interests.

2.3 The nuclear competence framework to which this guidance refers is also intended to inform the development action plans of existing Nuclear Safety Inspectors as part of the routine HSE career development process.

3 Definitions

3.1 Nuclear safety technical/expert competence. The combination of technical/expert qualifications, skills, knowledge and experience necessary for an HSE Inspector to effectively judge and influence the adequacy of nuclear licensees nuclear hazard control measures as embodied in nuclear safety cases, plant design features, facility operating frameworks and licensees organisations. (NB: for a Nuclear Safety Inspector to be fully competent, these capabilities will need to be complemented by additional regulatory and core capabilities but these are outwith the normal equivalence process).

4 Responsibilities

4.1 Line managers are responsible for using this guidance to guide nuclear CPD and to make business cases for nuclear equivalence.

5 Procedure

Introduction

5.1 Pay in HSE is determined by a number of factors including job weight, specialist skills and knowledge, and marketability. Job weight is determined by the nature of the job and its range of responsibilities. HSE recognises that for certain roles, additional skills, knowledge and experience are required to achieve maximum effectiveness. Additionally, the peculiar nature and impact of the nuclear licensing regime and the environment in which Nuclear Safety Inspectors operate require mature judgements to be made that take account of a wide range of issues based predominantly on an in-depth understanding of the nuclear technology involved. In most cases these additional requirements are obtained by recruiting staff directly from a particular industry or sector. Such recruits are paid on a scale which recognises the salary needed to attract them into the Directorate and retain them.

5.2 Staff moving to ND from other parts of HSE on level transfer may not in the first instance have the same marketability as staff recruited directly from the nuclear industry. They will therefore continue to be rewarded on their current basis until they have acquired the necessary skills, knowledge and experience to operate at full effectiveness with regard to nuclear technical/expert competence.

Basis for the nuclear equivalence framework

5.3 Competence framework. The learning and development framework for ND Nuclear Safety Inspectors is set out in detail in BSS/HRM/030. This framework identifies competency requirements, together with training and development provisions that are intended to help meet those requirements. This considerably enhances previous guidance in BSS/HRM/024 (now withdrawn) and identifies expectations in technical areas. It also sets out Training and Development and Competence Records that should be used by Inspectors and Line Managers respectively to monitor progress. The Training and Development Record should be used as the basis of a business case for nuclear equivalence.

5.4 Nuclear TIMS. In the past, a generalised set of criteria has been developed for the recruitment of all HSE specialists and used for nuclear/high hazard recruitment (Technical Indicative Marking Scheme TIMS). These have been found with experience to need a certain amount of interpretation to meet ND needs. It has also been recognised that it will be important to minimise the future ND training burden by seeking as good a match as possible on expectations for nuclear competence between the capabilities of those joining from HSE and the capabilities of existing Nuclear Safety Inspectors. In addition, there is a need to secure an equitable approach to requirements for external and internal recruits. For these reasons, the first three generalised TIMS have been replaced by nuclear/high hazard TIMS, BSS/HRM/030. These TIMS should be used to complement the nuclear competence framework in BSS/HRM/030 when making nuclear equivalence judgements for HSE recruits and in guiding professional development for existing Nuclear Safety Inspectors.

Judging equivalence

5.5 See Nuclear Equivalence flowchart. When posts are designated as ones that have to be filled by Nuclear Safety Inspectors then the onus is on line managers to ensure that the post-holders possess the necessary nuclear technical/expert competence. Line managers should use the competence frameworks in BSS/HRM/030 to do this as part of the normal HSE Development Action Plan process. As noted at para 2.2 it may also be appropriate to do this for non-nuclear post-holders provided business and personal development interests indicate that this is appropriate, for example as part of overall workforce and succession planning.

5.6 Inspectors/Line Managers concerned may wish in due course to make a case for a member of staff to be designated as a Nuclear Safety Inspector. As noted above, the Training and Development Record and the nuclear TIMS should be used to establish the business case for nuclear equivalence. This puts the onus onto the Inspector/Line Manager concerned for assembling the information on which the business case is based. When it is judged that a business case can be made for equivalence then line managers should prepare it in accordance with HSE equivalence guidance on the Intranet, consulting NTLs as necessary.

5.7 The HSE guidance refers to the need to judge an applicants ability to carry out the full range of duties of staff already in the discipline; and also to judge the applicants levels of skill, knowledge, qualification and experience against other staff already in discipline. In the context of equivalence, discipline refers here to the nuclear safety discipline. In by far the majority of cases, staff joining ND will start in the assessment function. The comparison should be made against existing Nuclear Safety Inspectors in Assessment Units who are judged by their line managers to be carrying out a range of duties to an effectiveness that represents acceptable nuclear capabilities against the framework in BSS/HRM/030. Exceptionally, new staff may be considered for site/project inspection, in which case the comparison should be made against Nuclear Safety Inspectors in site or project inspection Units in the same way. It should be noted that Band 2 Nuclear Safety Inspectors require additional knowledge and understanding of nuclear regulation.

5.8 Once the line manager and NTL are satisfied that the state of development meets ND requirements, the business case should be submitted to the Head of Division 4 who will arrange for it to be considered by an internal ND Equivalence Panel before onward submission to HR for endorsement and subsequent action. The Equivalence Panels judgement will be made against the Training and Development Record set out BSS/HRM/030. The Equivalence Panel will consist of a Deputy Chief Inspector, or a nominee agreed by the Chief Inspector, the relevant NTL, and a third NSD nuclear-qualified HM Superintending Inspector independent of the applicants line management. Where the NTL is also the individuals line manager, then the NTL should arrange an alternative nuclear SI and provide a brief for the panel on the discipline aspects of the business case.

5.9 If the panel is not satisfied that equivalence has been demonstrated, written feedback will be provided and the line manager will be expected to revise development arrangements accordingly, in liaison with the relevant NTL and, if necessary, the individual concerned. Exceptionally, if a case cannot be made, the circumstances will be referred by the Equivalence Panel to the CDRG process for consideration.

5.10 Once the case is cleared by the Equivalence Panel, it will be forwarded to HR for consideration.

5.11 It is not possible to be prescriptive about timescales for achieving equivalence because different individuals will have different starting points and different learning rates, particularly where learning is based on on-job training. However, as a guide, it is suggested that it could take at least 18 - 30 months and possibly longer depending on circumstances.

6 Associated documents

6.1 BSS/HRM/030 - Competence framework and training and development of ND staff.

6.2 HSEs Equivalence Arrangements

Nuclear Equivalence Flowchart