The main legislation governing the safety of employees and members of the public at nuclear installations is the Health and Safety at Work etc. Act 19741 and its associated relevant statutory provisions, which include parts of the Nuclear Installations Act 1965 (as Amended)2 and the Ionising Radiations Regulations 19853 (now replaced by the Ionising Radiations Regulations 1999). Under the Nuclear Installations Act no site may be used by persons for the purpose of installing or operating any nuclear installation unless a nuclear site licence has been granted by the HSE. NII is that part of HSE responsible for administering this licensing function.
The Nuclear Installations Act requires that the licensee shall be the user of the site, which NII interprets as meaning that BNFL should be in day to day control of the site, process and activities, and should have staff who manage the operation of the site.
NII must also be satisfied that the licensee has in place an adequate management structure and resources to discharge the obligations and liabilities connected with the holding of a nuclear site licence.
NII expects that the management structure and resources will include the following attributes:
Section 4 of the Nuclear Installations Act 1965 provides the Health and Safety Executive with powers to attach such conditions as may be necessary or desirable in the interests of safety to a nuclear site licence. All nuclear site licences contain a standard set of 36 licence conditions which remain in force throughout the life of a nuclear installation and cover construction, commissioning, operation and decommissioning. Of particular relevance to the conduct of this team inspection are those licence conditions (lc) concerned with:
It should be noted that the management of change licence condition was introduced in the Summer of 1999 and will come into full effect in April 2000.
These conditions require the licensee to put in place arrangements to address the key safety activities associated with each particular topic. In their totality, the licence conditions require the licensee to make adequate arrangements for managing safety.
HSE expects its licensees to manage facilities to the highest standards. To enable its inspectors to form judgements on the adequacy of licensees' arrangements, a variety of documents are available defining standards and providing guidance. Amongst the primary documents, The Tolerability of Risk4 and Safety Assessment Principles5 are used by NII inspectors to determine the adequacy of the safety case for the operation of a plant. Inspectors also use published HSE guidance such as Notes for Applicants for a Nuclear Site Licence6, Successful Health and Safety Management7 and Managing for Safety at Nuclear Installations8 to assess the adequacy of other safety related maters. In the field of conventional safety, many of the regulations have published Approved Codes of Practice or guidance notes which indicate the standards of compliance expected from employers. Internal guidance notes are available as to what is expected from licensees in complying with conditions attached to the nuclear site licence.
Added to the HSE website 0n 18th February 2000