cnsc’s regulatory oversight of human and organizational factors … 2/np7_canada.pdf ·...

nuclearsafety.gc.ca

15th, December, 2015 e-Docs # 4873780

CNSC’s regulatory oversight of Human and Organizational

Factors (HOF) Alice F Salway

2 Canadian Nuclear Safety Commission

Overview

• CNSC - organization • regulatory framework • Safety and Control Area (SCA) framework • current approaches

– multidisciplinary approaches – scope of HOF considerations

• vision for human performance – human performance and human factors – individual-technology-organization – objectives and good practices – contemporary views of safety


CNSC Organization – Technical Support Branch

• Technical Support Branch – Directorate of Environmental and Radiation

Protection and Assessment – Directorate of Safety Management

– Management Systems Division – Personnel Certification Division – Human and Organizational Performance Division – Training Program Evaluation Division

– Directorate of Security and Safeguards – Directorate of Assessment and Analysis


CNSC Organization – Regulatory Operations Branch

• Regulatory Operations Branch – Directorate of Power Reactor Regulation – Directorate of Nuclear Cycle and Facilities

Regulation – Directorate of Nuclear Substances Regulation – Directorate of Regulatory Improvement and

Major Projects Management


CNSC Regulatory Framework and Human & Organizational Factors

Act

Regulations

Licences

Regulatory Documents

• policy on human factors

• minimum staff complement

• human factors engineering program plans; verification and validation

• certification of persons working at nuclear power plants

• training

All regulatory documents: nuclearsafety.gc.ca

• management system

• human performance

• procedures

• probabilistic safety analyses

• minimum staff complement

• training, certification and examinations


Safety and Control Area (SCA) Framework

• SCA framework is the set of technical topics CNSC staff use across all regulated facilities and activities to assess, evaluate, review, verify and report on licensee compliance with regulatory requirements

• SCA framework enables an integrated approach for gathering, collecting, managing and presenting information

• CNSC’s regulatory document structure links with the SCA framework


Current approaches

• HOF considerations are cross-cutting and apply across the SCA framework, through which the CNSC manages its regulatory activities

• HOF specialists are in the Directorate of Safety Management, Human and Organizational Performance Division (HOPD) – HOPD single points of contact for each licensee, to

understand the overview of HOF

• regulatory documents cover specific areas and topics

• multidisciplinary reviews and inspections


Example of a CNSC multidisciplinary review team

Technical Support Branch

Assessment & Analysis

Safety Management

Security & Safeguards

Environmental & Radiation

Protection & Assessment

Regulatory Operations Branch

Power Reactor Regulation

• Reactor behaviour

• Probabilistic safety & risk assessment

• Human & organizational performance (lead)

• Personnel certification

• Training

• Emergency Management Programs

• Environmental monitoring

• Radiation protection

• Site inspectors


Scope of HOF

• cross-cutting domain (CNSC P-119, Policy on Human Factors) – human factors are “factors that influence human

performance” – the CNSC recognizes that “human factors” can

affect the performance of facilities and activities it regulates

– breadth of HOF is formally acknowledged in CNSC’s regulatory activities


HOF in the SCA framework

Functional Area Safety and Control Area

Management 1. Management Systems 2. Human Performance Management 3. Operating Performance

Facility and Equipment 4. Safety Analysis 5. Physical Design 6. Fitness for Service

Core Control Processes

7. Radiation Protection 8. Conventional Health and Safety 9. Environmental Protection 10. Emergency Management and Fire Protection 11. Waste Management 12. Security 13. Safeguards 14. Packaging and Transport


Safety and Control Area Framework – Management

• Management (functional area) – Management System (safety and control area)

– Management system – Organization – Performance assessment, improvement and

management review – Operating experience (OPEX) – Change management – Safety culture – Configuration management – Records management – Management of contractors – Business continuity


SCA framework-Management (continued)

– Human Performance Management (safety and control area)

– Human performance program – Personnel training – Personnel certification – Initial certification examinations and requalification

tests – Work organization and job design – Fitness for duty


SCA framework – Management (continued)

– Operating Performance (safety and control area) – Conduct of licensed activity – Procedures – Reporting and trending – Outage management performance – Safe operating envelope – Severe accident management and recovery – Accident management and recovery


SCA framework – F & E

• Facility and equipment (functional area) – Safety analysis (safety and control area)

– Deterministic safety analysis – Probabilistic safety analysis

– Human Reliability Analysis (HRA) – Severe accident analysis

– Physical design (safety and control area) – Design governance

– Human Factors in Design (process) – Facility design – Structure design – System design – Component design


SCA framework – F &E (continued)

– Fitness for Service (safety and control area)

– Equipment fitness for service / equipment performance

– Maintenance – Aging management – Chemistry control – Periodic inspection and testing


SCA framework - Core Control Processes

• Core control processes (functional area) – Radiation protection – Conventional health and safety – Environmental protection – Emergency management and fire protection

– Conventional emergency preparedness and response – Nuclear emergency preparedness and response – Fire emergency preparedness and response

– Waste management – Security – Safeguards and non-proliferation – Packaging and transport


Human Performance Management

• Human performance program • Personnel training • Personnel certification • Initial certification examinations and

requalification tests • Work organization and job design • Fitness for duty


Future vision for HOF

• discussion paper on Human Performance is in progress

• human performance - the behaviours and the results of human activities when carrying out work tasks

• a broad range of human factors considerations supports or weakens human performance

• considering the breadth and integrated nature of human factors is key

• graded approach – tailored for different types of licensees


Human Performance (Program)

• may be a specific licensee’s program • can be a coherent view and way of

managing HOF within the licensee’s management system

• an overview of HOF considerations – formalises the view of HOF; human-centred and

systemic considerations – CNSC and licensees already consider HOF

elements individually but formalizing the overview is evolving


Human Factors

• Human Factors are those factors that influence human performance – influences that support workers to perform their

work tasks safely and effectively – influences that can detract from the desired

human performance and task outcomes – examples include: procedures, fitness for duty,

safety culture, training, design of systems and equipment, inherent characteristics of people in general, specific characteristics of individuals or groups…


Organization-Technology-Individual

Human Performance

Consideration of the individuals, organization and technology is the foundation that supports human performance.

Training, qualification & certification

Work practices: 3-way communication, procedure adherence, independent verification

Fitness for duty

Hours of work

Individual Organization Technology

Plant design

Equipment design & user interface

Task design and allocation

Physical work environment

Procedures

Management system

Safety Culture

Assessment & continuous improvement

Organizational Structure

Roles and Responsibilities

Minimum staff complement

Examples of factors that influence

human performance


Example: deployment of mobile emergency generator

• sufficient numbers of workers available to carry out the task

• workers are competent and qualified to perform the duties of their position

• workers who are fit to carry out the cognitive and physical work involved

• procedures in place that are correct and easy to follow


Example: deployment of mobile emergency generator (continued)

• provision and availability of all tools, protective clothing and equipment that are needed

• the appropriate amount of supervision and direction to carry out the task

• the physical environment in which the worker is expected to perform – working in snow, rain, extreme cold, high winds,

darkness or surrounded by debris is challenging

• the emergency generator and its couplings have been designed to be used by people in the environment where the deployment occurs


Example commentary

• factors that support human performance range across departments and lines of responsibility

• staffing, procedures, provision of equipment, supervision, design of systems and equipment, procurement

• consideration of environmental factors that are not subject to organizational control


Objectives of human performance programs • active support of human performance through

considering HOF, with the aim of achieving safe and effective outcomes

• integration of good practices for managing human performance throughout the licensee organization’s activities

• a human-centred focus that considers and supports people carrying out their work

• a systemic approach to managing human performance across the whole organization

• a maintained focus on considering the people in the organization when managing organizational, operational, and technical matters


Good practices

• consideration of human performance as it is actually carried out by individual workers (as opposed to an idealized view of work as it is anticipated or designed)

• providing appropriate resources to support human performance

• continual system improvement through considering and managing the broad range of HOF across the organization

• considering the roles of all levels and all departments in achieving the desired human performance outcomes


Good practices (continued)

• ensuring that human error is considered as a potential symptom of deeper issues instead of the sole cause of failure

• identifying the sources of human performance problems using a variety of methods, and correcting them

• continually striving to improve the organizational system that governs, manages and guides human performance


Integrated approach to Human Performance

management and supervision organization (structure and processes)

culture training

work organization and job design fitness for duty

procedures (development and use)

physical design (human factors in design)

performance assessment, improvement and management review

operating experience and lessons learned

personnel certification safety analysis (human actions)

reporting and trending behavioural safety initiatives and human performance tools


Links with contemporary views of safety

• support people’s work activities to go right • safety as an ongoing dynamic and adaptive

process (as opposed to an absence of negative events)

• work as it is done (as opposed to work as envisaged or designed)

• Safety I and Safety II • resilience • systemic approaches