ONR attended GE Healthcare's Amersham site for a 1-day inspection on 29 September 2014 of the licensee's compliance with licence conditions 6 (documents, records, authorities and certificates), 12 (duly authorised and other suitably qualified and experienced persons) and 26 (control and supervision of operations).
The inspection comprised an examination of relevant documentation purporting to demonstrate compliance with those licence conditions, and targeted discussions with relevant members of the licensee's staff.
I was content that responses to my questions provided a good demonstration that the licensee was fulfilling the intent of licence conditions 12 and 26 in practice, and I judged that conformance with a significant proportion of the guidance was apparently good in practice (responsibilities, control of contractors, qualifications, experience, training and understanding). Separate discussion with a supervisor provided good verbal corroboration that training and supervision is effective, and that staff would be supported by the company if safety or training concerns were raised.
I observed that individual operations affecting safety within one of the licensee's decommissioning projects are neither defined nor listed. Posts for the control and supervision of operations are defined, but the qualifications and experience required of duly authorised persons and suitably qualified and experienced persons are not. It was therefore not possible for me to check that actual qualifications, experience and training records met any particular defined standard for the posts.
I inspected the licensee's documented principles and process for archiving business records and observed evidence of good practice in relation to retention of hard copies on site and in a specialist archive provider, rapid retrieval to site (5 hours), in-house destruction, electronic workflow processes, retention period management, local dedicated resource and representation in each business area and provision of management information. I observed that responsibilities for the tasks within the business records process were not cascaded into role profiles or job descriptions, and that the licensee does not carry out any direct auditing of the content of its archived records for compliance with licence condition 6.
I concluded that the licensee was complying with the spirit of licence conditions 12 and 26 and that good practice was demonstrated in many areas which resulted in effective control and supervision of operations. However, aspects of the licensee's arrangements were not in conformance with expectations set out in regulatory guidance in relation to the definition of operations affecting safety, and the qualifications and experience required of SQEPs appointed to posts for the control and supervision of operations. Although strictly not a shortfall in regulatory compliance, I considered that there was room for improvement and raised this as an issue for the licensee to consider; it agreed to do this.
I concluded that on the basis of the information provided and to the extent of the inspection carried out, the licensee has effective arrangements under licence condition 6 for making and preserving records required to demonstrate compliance with the other licence conditions. However, aspects of the licensee's arrangements required additional visibility, transparency and auditing to provide fuller confidence in this conclusion, and I raised this as an issue for the licensee to consider; it agreed to do this.