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ARPANSA Inspection Outcomes 2017-18. John Ward Director, Safety Systems Regulatory Services ARPANSA. Licence Holder Forum 20 September 2018.
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ARPANSA Inspection Outcomes2017-18 John Ward Director, Safety Systems Regulatory Services ARPANSA Licence Holder Forum 20September2018
ARPANSA’s fundamental regulatory objective is to ensure that licenced facilities and sources are controlled and operated in an acceptably safe manner at all times. Regulatory Objectives ARPANSA is committed to the effective and efficient regulation. Our strategies are: Ensure compliance of Commonwealth entities with regulatory requirements Ensure regulatory actions are proportionate to the risk Provide timely and evidence based assessment of applications Promote international best practice in regulatory policy and practices Communication with regulated entities is clear, targeted and effective Contribute to the continuous improvement of regulatory framework and processes
Inspection Statistics • 2017/18 Figures • 42Inspections • 12 ScheduledFacility • 28 ScheduledSource • 2Augmented inspections • 13potential non-compliance • 113areas for improvement • 70Site visits to facilities • ARPANSA performance • 72% of inspections on schedule • 87% of inspection feedback is positive • 57% of corrective actions initiated within three months • 3/16 breaches self-reported • 84% of application decisions in agreed time
Inspection Findings COMMON OBSERVATIONS Data from 2017/18
Inspection Findings COMMON OBSERVATIONS • Status of facility equipment unknown • Maintenance and improvements not implemented • Change control not applied, implemented or followed • Change poorly categorised • Obstructions present • Contraband present • SIW not accurate/updated • Change Control – 3 of 5 observations were found to be breaches Data from 2017/18
Inspection Findings COMMON OBSERVATIONS • Surveys not undertaken (in 2 instances caused by upgrade to scheduling software) • Maintenance not undertaken • Health checks not performed • Training requirements not met • Unauthorised dealing • Oversight - central services, work as undertaken, reports and tests • Procedures not followed - 4 of 9 observations were found to be breaches Data from 2017/18
Inspection Findings COMMON OBSERVATIONS • Human factors not adequately factored into risk assessment • All risks not identified (incl. external risks) • Lack of analysis/no effective safety case • ‘improvements’ introduced without proper consideration of potential risks • Problems with internal review and oversight • Poor ‘selling’ of risk assessment (not believed) • Feedback of operational experience • Reporting arrangements not understood or poorly communicated • Safety events not widely known • Risk updates too localised Data from 2017/18
Inspection Findings COMMON CONTRIBUTING CAUSES OF ACCIDENTS • Leadership Issues • Operational attitudes and behaviours • Organisational (business) environment • Competence • Risk assessment and management • Internal oversight and scrutiny • Organisational learning • External regulation • Communication cuts across all of these issues Data from 2017/18
Safety Outcomes Incidents and Accident • Personal contamination (unsealed sources) • Unplanned release (exceedance of discharge limit) • Multiple failure of safety systems • Human error and verification error leading to exceedance of operating limit • Safety incident during emergency exercise • Uncontrolled/uncharacterised sources (unknown hazards) • Legacy management of sources
Points for Reflection • Is operational experience used to update risk assessments? Are real life behaviours anticipated and assessed conservatively? Do we understand what and why people do what they do rather than explain what they should do? • Do we look for organisational drift? • All changes (equipment and process) should be subject to risk assessment – regardless of how well-meaning they are
Bring risk assessments to life Living Assessments • The data on which risk assessment is based is updated. • New operational data becomes available (internally and externally). • Plant and equipment change over its lifetime. It ages, parts are replaced and it is put to new or changed use. • The processes used also change and efficiencies and other improvements are identified.(Change is usually driven by drive for efficiency at the cost of thoroughness.) • Organisational arrangements change that may have an impact on risk. Risk assessments need to be nurtured and looked after rather than left at a point in time. Arrangements and controls to mitigate risk need to be assessed and updated to be effective
Data on our inspection findings and other useful information is available from the ARPANSA website: www.arpansa.gov.au FURTHER INFORMATION
THANK YOU CONTACT ARPANSA Email: John.Ward@arpansa.gov.au Website: www.arpansa.gov.au Telephone: +61 2 9541 8350 Freecall 1800 022 333 General Fax: +61 2 9541 8348