1.2.5 Operating Experience Feedback Operating Experience Feedback (OEF), which contributes to “Defence in Depth”, is one of the essential safety management tools. It is based on an organised and systematic collection and analysis of the signals emitted by a system. It should enable acquired experience to be shared so that the organisation can learn (that is through the implementation of preventive measures in a structure that learns from past experience). The first goal of OEF is to understand, and thus ensure progress in technological understanding and knowledge of actual operating practices, so that whenever pertinent, a fresh look can be taken at the design (technical and documentary). As OEF is a collective process, the second goal is to share the resulting knowledge on the basis of the date of detection and recording of the anomaly, the lessons learned from it and how it was rectified. The third goal of OEF is to act on working organisations and processes, on working practices (both individual and collective) and on the performance of the technical system. OEF therefore encompasses events, incidents and accidents occurring both in France and abroad, whenever their assessment is relevant to enhancing nuclear safety or radiation protection. 1.2.6 Social, human and organisational factors The importance of Social, Human and Organisational Factors (SHOF) for nuclear safety, radiation protection and environmental protection The contribution of humans and organisations to safety, radiation protection and environmental protection is decisive in the design, construction, commissioning, operation and decommissioning of facilities, as well as in the transport of radioactive substances. Similarly, the way in which people and organisations manage deviations from the regulations, from the baseline requirements and from the state of the art, plus the corresponding lessons learned, is also decisive. Therefore, all those involved, regardless of their position in the hierarchy and their functions, make a contribution to safety, radiation protection and environmental protection, owing to their ability to adapt, to detect and correct errors, to rectify degraded situations and to counter certain difficulties involved in the application of procedures. ASN defines SHOF as being all the aspects of working situations and of the organisation which have an influence on the work done by the persons involved. The elements considered concern the individual (training received, fatigue or stress, etc.) and the organisation within which they work (functional and hierarchical links, joint contractor work, etc.), the technical arrangements (tools, software, etc.) and, more broadly, the working environment with which the individual interacts. The working environment for instance concerns the heat, sound or light environment of the workstation, as well as the accessibility of the premises. The variability in worker characteristics (vigilance varies with the time of day, the level of expertise varies according to the seniority in the position) and in the situations encountered (unexpected failure, social tension) explains that these workers constantly need to adapt how they work in order to optimise effectiveness and efficiency. This goal must be achieved at an acceptable cost to the persons concerned (in terms of fatigue or stress) and provide a benefit to them (the feeling of a job well done, recognition by both peers and the hierarchy, development of new skills). Thus, an operating situation or a task achieved at very high cost to the operators is a potential source of risks: a small variation in the working context, human environment or working organisation can prevent the persons concerned from performing their tasks as expected. Integration of SHOF ASN considers that SHOF must be taken into account in a manner commensurate with the safety implications of the facilities and the radiation protection of workers during: ∙ the design of a new facility, equipment, software, transport package, or the modification of an existing facility. ASN in particular wants to see design focusing on the human operator, through an iterative process comprising an analysis phase, a design phase and an evaluation phase. Therefore, ASN resolution 2014-DC-0420 of 13 February 2014 concerning physical modifications to BNIs requires that “the design of the physical modification envisaged shall, when it is applied and put into operation, take account of the interactions between the modified or newly installed equipment on the one hand and the users and their needs on the other”; ∙ operations or activities performed by the workers during the commissioning, operation and decommissioning of nuclear facilities, as well as during the transportation of radioactive substances. ASN also considers that the licensees must analyse the root causes (often organisational) of the significant events and identify, implement and assess the effectiveness of the corresponding corrective measures, on a long-term basis. ASN’s SHOF requirements The Order of 7 February 2012 setting the general rules for BNIs, requires that licensees define and implement an Integrated Management System (IMS) designed to ensure that the safety, radiation protection and environmental protection requirements are systematically taken into account in all decisions concerning the facility. The IMS specifies the steps taken with regard to all types of organisation and resources, in particular those adopted to manage important activities. ASN thus asks the licensee to set up an IMS able to maintain and continuously improve safety, notably through the development of a safety culture. 124 ASN Report on the state of nuclear safety and radiation protection in France in 2022 • 02 • The principles of nuclear safety and radiation protection and the regulation and oversight stakeholders 02
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