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Intervention planning

Site inspection and enforcement

INS/008 - Issue 3

Issue date:

2009/03/02

Review date:

2013/03/02

Open Government status:

Fully open

Approved by:

R Gray

1 Purpose and scope

1.1  This procedure sets out ONR’s expectations for the development and delivery of off and on-site planned regulatory interventions. Its aim is to ensure that ONR is making the best use of its resources by incorporating into ONR practice the principles developed in 2007/8 by the Operational Strategy Disciplined Delivery (OSDD) project.

2 Policy

2.1  All regulatory intervention plans should be subject to the associated  programme strategy and programme management oversight. 

2.2  The regulatory activity of all Inspectors should align with the relevant intervention plan.

2.3  Decisions on resource allocation will be informed by established Directorate prioritisation tools.

2.4  ONR regulatory philosophy is to:

• Adopt a persuasive and influencing approach in the first instance to the remedy of compliance deficiencies ^[1], while using powers under the licence and HASAW as appropriate in accordance with the Enforcement Policy Statement ^[2].
• Develop and sustain an open and effective dialogue with licensees and other stakeholders.
• Adopt a positive and enabling approach to the permissioning of activity when legal requirements have been met or the risk/compliance gap is such that it would be disproportionate not to grant a permission. 
• Act in a way that supports and strengthens licensees’ self-regulatory processes rather than provides a substitute for them.
• Adopt an approach to making and implementing regulatory decisions and intervention strategies that values all relevant Inspector inputs and ensures that agreed lines are followed by all once decisions are made.
• Concentrate on prevention of major nuclear accidents whilst at the same time regulating risks to workers.
• Encourage licensees to improve their process safety leadership, to learn from each other and to develop meaningful key performance indicators aimed at managing and improving process safety performance.

3 Responsibilities

(NB: the way in which accountabilities have been developed is set out in some detail in G/INS/008). An outline of these is given below.

3.1 Heads of Division ensure that:

• Programmes and projects are established and managed to deliver the planned regulatory interventions of Divisions necessary to meet Directorate objectives.
• Resource is allocated to best effect (proportionate, targeted, consistent) and re-allocated in-year within Divisions through regulatory review as necessary to secure delivery of objectives.

3.2  Programme Managers ensure that:

• Programme vision and strategy is established and reflected in Intervention Plans.
• Resources within programmes and projects are allocated/re-allocated  using agreed Directorate prioritisation and attention models.
• Timely delivery is achieved through delivery and regular review of plans and programmes, and initiation of any necessary remedial action.

3.3  Nominated Site Inspectors (Lead Inspectors for multi-Inspector sites): 

• Act as an interface with the site for the purposes of communications on regulatory interventions. 
• Ensure that the Intervention Plan for the relevant site to covers priorities agreed by the IPG and co-ordinate and report delivery.
• Co-ordinate the response to unplanned events, liaising with the IMG over any potential threats to delivery of planned interventions.  

3.4  Nuclear Safety Inspectors:

• Carry out interventions in accordance with Interventions Plans and projects as agreed.
• Provide IIS intervention data in accordance with Divisional processes.

3.5  Divisional IIS co-ordinators:

• Ensure IIS intervention data is provided and collated.
• Provide routine IIS reports to Heads of Division in accordance with Divisional procedures.

4 Definitions (more detail is given in G/INS/008)

4.1  Intervention. Any interaction by Inspectors and other ONR staff to influence licensees/duty-holders, industry representatives, partners and stakeholders to achieve an outcome to secure safety. This includes both planned and reactive interventions. 

4.2  Programme. A framework for achieving identified outcomes over the long term, consisting of activities and projects managed as a whole over a prolonged period by a programme management team.

4.3  Project. A particular way of managing activities to deliver specific outputs over a specified time and within cost, quality and resource constraints.

4.4  Regulatory review. A process, carried out at regulatory review meetings (RRMs), to check progress with Integrated Intervention Strategies (IISs) and associated Intervention Plans (IPs) and make adjustments to plans and resources as necessary.

4.5  Intervention Management Group. A generic term to cover the various management groups (ISGs, IPGs, RRMs) that exercise oversight over the development and delivery of the various intervention plans established under programmes and projects.

4.6  Integrated Intervention Strategy (IIS). This is both a general and a specific term. In a general, Directorate, sense it is the process for incorporating information from various sources (compliance inspection, permissioning inspection, OEF and corporate interventions) to determine appropriate future co-ordinated regulatory interventions. At an operational level it is the output of the programme level regulatory review process (as modified by Divisional and Directorate RRMs), used to inform and guide the development of intervention Plans and co-ordinate the activity of individual Inspectors.

4.7  Leverage model. A conceptual aid to the selection of interventions to maximise influence and the likelihood that outcomes will be achieved, see Annex D of G/INS/008.

4.8  Intervention Plans (IPs). This is a generic term to describe the in-year delivery plans that embody and give effect to the IIS.

4.9  Inputs, Outputs, Outcomes and Milestones are key steps determined by Divisions that indicate satisfactory progress towards Directorate objectives.

4.10  Integrate/integration means assembling parts into a coherent whole, bringing together and blending several things into one. The IIS aims to integrate multiple information sources in strategy making and to integrate activity of Inspectors in delivery to achieve optimum impact.  

4.11  Reactive work. The guidance in this document relates primarily to planned activity. It is therefore appropriate to define what constitutes reactive activity so that it is clear what is within the scope of this guidance. Broadly, reactive work is intervention work that is not planned. G/INS/008 expands on this. Nominated Site Inspectors, in liaison with Programme Managers, are expected to balance the competing priorities of proactive and reactive work.

4.12  Cornerstone inspections. The minimum level of compliance inspection considered necessary by the IMG to provide assurance of adequate control of nuclear safety by the licensee. They are intended to be proactive, in-depth examinations of compliance against benchmarked internal ONR guidance. Programme Managers should ensure that Intervention Plans include appropriate cornerstone inspections, most likely to be targeted at LC 7, 12, 19-22, 23, 24, 26, 28 and 36 although not all these will always be most appropriate.

4.13  Regulatory Nuclear Interface Protocol (RNIP). This is a protocol agreed amongst licensee CEO’s and senior regulators in 2008 that seeks to underpin effective working between regulator and regulated. More detail is given in G/INS/008 Annex H.

5  Procedure

5.1  See lower section of the attached flowchart at Figure 1, which shows how operational delivery and strategic direction link together.

5.2  Programme priorities and strategies. ONR has identified a number of programmes within which regulatory interventions are determined and guided. Programme Managers (SI lead or co-lead) should ensure that they provide sufficient guidance for the development of coherent intervention plans as in para 5.3 and also to give a clear idea to duty-holders of medium term regulatory expectations and intentions. Terms of Reference for programme management groups are given in G/INS/008 Annex C.

5.3  Intervention plans. Nominated Inspectors/Lead Inspectors (multi-Inspector sites) are responsible for developing Intervention Plans for their sites that align with programme strategies and priorities.  Annex A gives detail. Intervention plans for other activities will be developed by a nominee established by the IMG.  More detail is given in G/INS/008 Annex E and F.

5.4  Delivery of plans. As they implement plans to deliver regulatory outcomes, Inspectors should ensure that they follow Divisional processes designed to facilitate collection and collation of IIS data, in liaison with Divisional IIS co-ordinators. G/INS/008 Annex G gives details.

5.5  Conduct of interventions. Inspectors should follow the Regulatory Nuclear Interface Protocol (RNIP) when carrying out interventions, see G/INS/008 Annex H.

6 Accountabilities

See Annex A of G/INS/008.

7  Associated documents

G/INS/008 Guidance on Intervention Planning
Regulatory Nuclear Interface Protocol (RNIP) see TRIM 1.2.3.262.

• Figure 1: Strategic Direction and Operational Strategy [38KB]

Annex A – Intervention Plans

These should:

• Set out detail of the agreed minimum level of planned cornerstone inspections to be included in site intervention plans.
• Use opportunities for partnering wherever appropriate (eg with other regulators, internal licensee regulators, stakeholders).
• Use the Leverage Model to identify appropriate interventions.
• Be developed in consultation with duty-holders and stakeholders through open and effective dialogue so that there is a clear,  understood and realistic rationale for the planned interventions.
• Identify longer term outcomes and the inputs, outputs and milestones that indicate adequate progress towards outcomes – ie what it is intended to do to make progress towards ONR’s aims.
• Identify who will lead the intervention.
• Take due account of Directorate interests identified through Divisional planning by programme managers.
• Include permissioning, periodic safety review, licensing/re-licensing/activity and team/specialist inspection requirements where known.
• Establish an appropriate balance of attention in three areas:
  • improvement areas identified by Safety Performance Indicators and OEF when available.
  • assurance, gained through compliance and permissioning inspection (and re-licensing/re-structuring controls) within which the programme managers should agree and set a minimum  level of cornerstone inspection.
  • ALARP improvements in compliance arrangements, implementation of compliance arrangements, safety management and culture, plant/facility hardware.
• Integrate intelligence and information from compliance inspection, permissioning inspection, OEF and corporate/other interventions.
• Ensure that intervention attention is informed by knowledge of the key hazard controls identified in safety cases.
• Be formally approved by programme managers by 1 April each year.

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