Skip to content

MSC46: Counterfeit, Fraudulent & Suspect Items (CFSI) Management, adequacy of arrangements

  • Site: Hinkley Point C
  • IR number: 21-018
  • Date: July 2021
  • LC numbers: 17

Executive summary

Purpose of Intervention

The purpose of this intervention was to gain confidence in the management arrangements for the prevention and control of counterfeit and fraudulent items by NNB Generation Company (HPC) Ltd (NNB GenCo).

The intervention was undertaken remotely by Microsoft Teams, allowing on-line observation and interviews with staff responsible for aspects of the management arrangements.

Interventions Carried Out by ONR

The intervention related to Licence Condition 17, which requires a licensee to make and implement a management system that gives due priority to safety. ONR expects that the system should include arrangements to mitigate the risks of counterfeit, fraudulent and suspect items (CFSI) entering NNB GenCo’s supply chain.

The intervention follows up a previous one on the same topic, MSC10, completed in August 2020, which resulted in improvement action by NNB GenCo to implement their CFSI strategy and systemise their arrangements. The focus of this intervention was to check, by sample, that the improvements in CFSI management arrangements were in use.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

We found evidence that CFSI management arrangements, including improvements since MSC10, were in place and working in line with NNB GenCo’s revised strategy.

 The arrangements will be further improved and embedded by NNB GenCo. A system to make positive identification checks on materials received is in train. Proactive management of who should attend CFSI awareness courses will be introduced, alongside a plan for assurance activities to ensure the continued vitality of the arrangements.

Conclusion of Intervention

Overall, ONR concluded that a green inspection rating is appropriate. Therefore, the ONR Issue raised to track NNB GenCo’s actions in response to MSC10 has been closed.