ASN reviews the steps taken to deal with counterfeit, suspect and fraudulent items (CSFI)

Published on 08/06/2018 • 10:06 am

Information notice

Irregularities which could be considered to be falsifications were detected in early 2016 on nuclear components manufactured in the Creusot Forge plant, following a quality review requested by ASN. Irregularities of the same type had also been brought to light in other countries. Confirmed or suspected cases, some of which were detected by BNI licensees or the manufacturers themselves, only concern an extremely small part of the nuclear activities, but could nonetheless have significant safety implications.

This situation shows that neither the robustness of the monitoring and inspection chain, at the top of which are the manufacturers and the licensees, nor the high level of quality demanded in the nuclear industry, were able to completely rule out the risk of CSFI.

In order to improve how this type of irregularity is prevented and detected, ASN has assessed how to strengthen the requirements applicable to the industry and improve its own oversight system.

The resulting measures concern:

  • reinforcing the provisions made by the manufacturers and the licensees, who retain the responsibility for the quality of manufacturing and of operations, for example by requiring improved data security;
  • using external inspection organisations, to support the oversight of manufacturing activities, take samples and run cross-checks;
  • improving ASN’s oversight practices, more particularly its inspection methods;
  • requiring that any fraud detected by the licensee be systematically reported to ASN;
  • implementing of a system for collecting alerts from whistle-blowers.

At the end of 2017, ASN brought the licensees and manufacturers together to remind them of their obligations and their responsibilities in terms of preventing, detecting and dealing with cases of CSFI. In a letter of 15th May 2018, it explained the applicable regulatory requirements on this subject. ASN more particularly asked that greater consideration be given to the risk of CSFI in the integrated management system[1] that the licensees are required to implement. ASN also requires the licensees and manufacturers to propose the monitoring actions they will be entrusting to external inspection organisations. The licensees and manufacturers shall notify ASN of the implementation of these measures before 1st September 2018. ASN will check their correct application during the course of inspections. In the meantime, ASN has included a search for CSFI in approximately ten inspections performed in recent months.

Arrangements enabling a whistle-blower[2] to send ASN a report of potential CSFI are being prepared and will be in place in the second half of 2018. ASN also intends to hire two anti-fraud specialists in 2018 and supplement the training of its inspectors on this topic.

 

[1] Integrated management system: management system ensuring that the requirements concerning protection of persons and the environment are taken into account in the management of the facility (article L.593-6 of the Environment Code).

[2] The process for taking account of such an alert into the oversight process shall comply with Act 2016-1691 of 9th December on transparency, the fight against corruption and the modernisation of economic life and shall allow a robust analysis of the information transmitted.

Date of last update : 03/07/2018