Renewed strategy for monitoring and enforcement by the Authority for Nuclear Safety and Radiation Protection
As the Authority for Nuclear Safety and Radiation Protection, how do we monitor nuclear safety, security of nuclear facilities and radiation protection? And how do we intervene if we think a situation is not safe? What do we do if we see a situation we think sets a good example within the sector? We go into this − and more − in our renewed Regulation and Intervention Strategy.
Modernisation of strategy from 2017
It concerns a modernisation of the strategy from 2017. The new Regulation and Intervention Strategy more succinctly describes how we carry out our monitoring task as an independent authority. Examples include our monitoring of nuclear facilities such as the nuclear power plant in Borssele, but also of hospitals, dental practices and transport of radioactive materials. The strategy was written by and for employees of the Authority for Nuclear Safety and Radiation Protection who are involved in monitoring, and is available to anyone interested in how we work.
Our key principle: safety first
Laws, rules and nuclear licenses lay down compliance requirements for nuclear safety and radiation protection in the Netherlands. Companies and organisations that use ionising radiation or nuclear technologies are responsible for safety themselves. Our inspectors not only monitor proper compliance, but they also see to it that everything is done – and continues to be done – safely.
In the new strategy, we have made it clearer how we put safety first. In monitoring, inspectors first look at whether laws, rules and licence requirements are complied with. They also take action if they see a situation that does meet the standards, but that is not safe (or does not appear to be safe), or if they see something that could lead to an unsafe situation. In such cases, our inspectors may state their key concerns to a company or organisation, or provide information on working more safely.
We may also point out to those who created the laws, rules and licences that these are no longer sufficient or feasible.
Monitoring the most important risks
Our monitoring is in line with the steps of the Plan-Do-Check-Act (PDCA) cycle. Every year we make a plan for our monitoring. One thing we do to this end is take stock of the biggest risks. We also take societal concerns into account and exchange information with other inspectorates.
In the monitoring plan, we determine which kinds of monitoring we will use and how we will go about achieving our goals. For instance, are we looking at general safety within a sector, or are we focusing on a specific topic, such as dealing with radioactive waste? And do we carry out administrative inspections or do we pay announced (or unannounced) visits? We draw attention to the results of our monitoring. This way, not only the companies that are directly involved but also other companies and organisations in the field can use them to learn and improve. We analyse the results and adjust our monitoring where required.
Interventions: encouragement as well as enforcement
If compliance or safety are inadequate, we intervene. There are several ways in which we can do so, for example by giving a warning or imposing a financial penalty order. Our method of intervention depends on the severity of the violation, on how we classify the organisation and on the circumstances of the violation. With an organisation that has demonstrated a willingness to follow the rules, for example, we will use different measures of enforcement than with an organisation that deliberately or structurally breaks the rules.
If we see a situation anywhere that does comply with the rules but that does raise some concerns or have room for improvement, we indicate this. This is our way of continuously encouraging improvement of safety. Also, if the situation exceeds our expectations based on the rules, we mention this as a positive.
Policy of tolerance
The strategy also covers our views on tolerance, i.e. temporarily allowing a situation that does not comply with the rules. We only do this in certain circumstances, and only if it does not lead to greater environmental and safety risks.
Finally, after an intervention we look at whether the goal we set has actually been achieved.