GSR Part 2 – Why it is different and how to cope!

Peter MullinsONR Professional Lead – Human and Organisational Capability

ONR HOC Professional Group

• ONR specialists in:– Human factors– Quality management– Leadership and management for safety

• Managed through matrix structure: – Line management in specialism– Work in programmes

GSR Part 2

• Why it is different to GSR-3• Broadly, what’s changed• What’s next

Why it has changed: 1

• More emphasis on leadership, and management for safety

• Global major accidents, experience and research show:– Major accidents happen where there is a sophisticated

management system– Common mode failure is safety culture, and the priorities and

proficiency of the leadership that drives it. – These are qualitative not quantitative, improved by looking direct

at them, not only by altering management systems.

• Charles Haddon-Cave:•

“It’s not the management system that makes you safe, people do…”

Why it has changed: 2

• IAEA trying to bring consistent ‘architecture’ to requirements and guidance.

• Requirements are binding and so should be high-level what to achieve, not how to achieve it:– How goes into guidance with a ‘comply or explain’

status

Why it has changed: 3

• Problems with application of GSR-3 in a number of countries led to representations to IAEA, e.g.:– ENISS concerns – GSR-3 not focussed enough on

safety – Spain and other countries where GSR-3 became legal

requirements:• Led to legal pressure to address management system

matters that had nothing to do with safety

• Emphasis should be on delivery of safety, with the integrated management system as a means not the end

How it was written

• DPP specifying structure of document produced ~ 2010

• ONR involved as drafting consultants from January 2012 (team of about 12 invited members)

• Member state consultation: – Summer/Autumn 2013 (I coordinated UK response)– Modified draft in response February 2014

• IAEA due process for requirements will take at least until early 2015

How GSR Part 2 Compares - Outline

• GSR-3: 1. INTRODUCTION 2. MANAGEMENT SYSTEM3. MANAGEMENT RESPONSIBILITY 4. RESOURCE MANAGEMENT 5. PROCESS IMPLEMENTATION6. MEASUREMENT, ASSESSMENT AND IMPROVEMENT.

GSR Part 2:1. INTRODUCTION2. RESPONSIBILITY for Leadership, Management and Safety Culture3. LEADERSHIP FOR SAFETY4. MANAGEMENT FOR SAFETY5. SAFETY CULTURE

Chapter 4: • Most of the main management system features of GSR-3• Slightly less detail• Slightly more mention of safety

Comparison of the approach:

• GSR-3“ Management at all levels shall demonstrate its

commitment to the establishment, implementation, assessment and continual improvement of the management system and shall allocate adequate resources to carry out these activities.”

• GSR Part 2: “ The senior management of an organization shall ensure

that managers at all levels, including themselves, demonstrate effective leadership and implement an integrated management system giving an overriding priority to safety and fostering safety culture”

Next Step

• DPP for guidance to replace GSG 3.1 and GSG 3.5 developed December 2013– Drafting begins Q4 2014– Aims to complete 2017

• Proposed Title: Leadership and Management for Safety in Nuclear Installations

• Specifically aims to include ‘how’ guidance from GSR-3 that was taken out of GSR part 2 – Also intend to consider 50 C/SG-Q

How do we adapt?

• We need to get used to the new architecture and structure– Structure and English less clear than GSR-3– But (I believe) change of emphasis and general

content is right for safety

• Quality community needs to get used to guidance rather than requirements:– Comply or be able to demonstrate that have reached

equivalent standard – Similar to goal setting legislation that regulators have

lived comfortably with for 30 years