- Date released
- 28 October 2020
- Request number
- 202009042
- Release of information under
- Freedom of Information Act 2000 (FOIA)
Information requested
ONR has just published its Annual Report for 2020.
As detailed on Page 59, the following is recorded with respect to "2019/2020 Regulatory Assurance"
"The Limited rating was assigned to the review of Regulatory Guidance, Documentation and Processes. Although adequate and effective in most areas examined, a weakness in governance and control was identified for the Safety Assessment Principles (SAPs).
This weakness received significant attention and was successfully addressed through the timely implementation of a recommendation."
Base on the above, could I have a:
A) Copy of the Regulatory Guidance , Documentation and Process Review which was given the "Limited" Assurance Rating.
B) Details of "the timely implementation of a recommendation"
Information released
I can confirm that under Section 1 of the FOIA we do hold the information requested and I am pleased to share the ONR Guidance, Documentation and Processes Regulatory Assurance review report.
A small amount of information has been redacted to remove personal data. The personal data has been withheld using the exemption section 40(2) of the FOIA. In particular, release of the information would breach principle (a) of GDPR (lawfulness, fairness and transparency) on the grounds that there is no lawful basis to process this data. In addition, releasing this personal data would also breach principle (b) of GDPR (purpose limitation) as the data was provided for the purposes of presentation ownership or circulation.
By way of further context, we hope you find the additional information below to be helpful, should you have any further questions please let us know.
Regulatory Assurance (RA) provides an internal audit function within ONR, which is independent from the Regulatory Directorate, thus enabling it to act impartially. This is an essential part of providing organisational assurance that ONR is fulfilling its declared strategic objectives and driving improvements in the way we regulate. The RA reviews conducted during 2019/20 identified no significant matters to challenge confidence that we are regulating the nuclear industry in accordance with our purposes set out in the Energy Act 2013. Importantly and as you would expect, the findings from all audits and reviews are used to improve processes and share good practice across the organisation, demonstrating our commitment to drive continuous improvement and raise standards. Our Audit and Risk Assurance Committee has oversight of this process, and further details on their role can be found in the ONR Corporate Plan 2020/21.
The review in question was undertaken in September / October 2019 and focussed on ONR guidance, documentation and processes. It made three recommendations and noted seven observations; our summary of actions is below.
Recommendations:
- Amend the revision status of the ONR SAPs and accompany this with a suitably scaled announcement to staff and stakeholders that includes an outline description of the changes made.
The SAPs document was revised during December 2019, formally signed off in January 2020 and communicated to staff and stakeholders.
Between the major revisions to the SAPs, alterations were minor in nature and, whilst important, did not involve shifts in regulatory policy.
- Conduct a wider and fully comprehensive review of ONR guidance to ensure that no similar document control anomalies exist. Also, identify and implement procedures to maintain robust document control of all such documents in future.
This recommendation is comprised of two parts; the first relating to live documents and the second to the process to control those documents.
Part 1
The assurance review sampled a small volume of guidance, so it was considered appropriate to recommend that the full range of guidance that ONR produces be examined to ensure similar anomalies were not present.
As you know, the primary source of guidance for ONR staff are the Technical Assessment Guides and Technical Inspection Guides, approximately 150 documents. ONR recently undertook a review of each of these and identified and corrected a small number of issues, which again did not affect regulatory policy or its application. A further collection of guidance documents are being reviewed and will be updated, where necessary, in due course.
Part 2
To further enhance ONR’s management system a ‘Control of Management System Documented Information’ procedure has been implemented. This sets out the process and requirements for the control of ONR’s documented information, including associated roles and responsibilities. This is to ensure that our documented information is correct and remains fit for use. In addition, we have recently consolidated master document registers, which identify each document and associated process owner by role.
- Observations 1-7 arising from this review should be sentenced and followed-up as appropriate.
The observations involved elements of process and proformas in the production of guidance. These were all sentenced and actioned, or folded into the scope of Recommendation 2, by the end of January 2020.
As part of ongoing regulatory assurance activities, the status of associated guidance documents is reviewed as a matter of course within each assurance review, and any anomalies identified to the process/document owners for resolution.
I hope you find this additional information reassuring as to the seriousness with which we take these recommendations and our actions to make the necessary improvements.
Exemptions applied
Section 40(2)
PIT (Public Interest Test) if applicable
N/A