What We Heard Report – DIS-16-05
DIS-16-05, Human Performance
Discussion papers play an important role in the selection and development of the regulatory framework and regulatory program of the Canadian Nuclear Safety Commission (CNSC). They are used to solicit early feedback on CNSC policies or approaches.
The use of discussion papers early in the regulatory process underlines the CNSC's commitment to a transparent consultation process. The CNSC analyzes and considers preliminary feedback when determining the type and nature of requirements and guidance to issue.
Human performance is an important aspect in the way people carry their work on a day-to-day basis. Effective human performance management by all licensees is essential to the safety of nuclear operations. DIS-16-05, Human Performance, sought feedback on the proposal to create a new regulatory document on human performance, and on CNSC requirements and guidance that may be introduced.
As part of the CNSC's commitment to continuous improvement, DIS-16-05, Human Performance, opened a dialogue with interested stakeholders on how the CNSC considers human performance in its regulatory framework. The CNSC intends to use the feedback received on DIS-16-05 to inform its approach to regulating human performance.
The CNSC published DIS-16-05 for a 120-day public comment period on October 19, 2016, and received comments from 19 organizations and individuals. These comments were posted on the CNSC's website for feedback from March 15 to April 5, 2017, during which time the CNSC received 1 feedback submission.
Summary of stakeholder comments
A wide variety of comments were received in response to DIS-16-05. Stakeholders expressed their concerns about the potential administrative burden of the proposed new regulatory document on human performance. Stakeholders also requested more guidance and clarification on several sections of the discussion paper.
Comments received fell into three general themes and each theme is discussed below. Priority areas for further examination and next steps are also identified.
Theme 1: Human performance program and management system
Summary of comments
Many stakeholders expressed their concerns and disagreement with the creation of a regulatory document on human performance and the requirement to have a stand-alone human performance program. They stated that implementing a human performance program would not generate more safety benefits than the current practice, but could increase administrative burden on licensees.
Multiple stakeholders indicated that the elements of the human performance program listed in DIS-16-05 are already part of their existing management systems. They recommended that the CNSC not require the human performance program as a separate program, but rather integrate its elements into the established management system structure.
Stakeholders also indicated that human performance components are already covered in licence conditions handbooks and that DIS-16-05 seemed to be repeating what already exists.
Keeping in mind the concerns raised regarding administrative burden, the CNSC intends to develop a regulatory document that will clarify requirements and provide more specific guidance in the area of human performance, and replace P-119, Policy on Human Factors. Licensee practices may in some cases already be sufficient. The comments received on DIS-16-05, Human Performance will be taken into account in the development of a future draft regulatory document on human performance.
Theme 2: Definitions
Summary of comments
Multiple stakeholders disagreed with the CNSC's proposed definitions for human performance and human factors, whereas some agreed with these proposed definitions. Some stakeholders said that the definitions were vague and overly broad.
Some stakeholders also mentioned that a description of each element in the overall human performance program would have been helpful to gain insight into what is included in each element. They also found that the elements, objectives and practices of the human performance program were too prescriptive and formal.
Stakeholders indicated that some definitions were incomplete, and asked the CNSC to host a workshop to present their views on potential alternate definitions.
The definition of human factors in DIS-16-05 was not new and was taken from previous CNSC documents. The CNSC believes that its developing view of human performance is broad, but not vague. However, the CNSC routinely reviews literature on the topic and is open to considering additional information. More practical guidance on the application will be considered for inclusion in a future draft regulatory document on human performance.
Theme 3: Graded approach
Summary of comments
Numerous stakeholders supported the implementation of a risk-informed, graded approach to the human performance program, indicating that they believe it is important and appropriate, and that all licensees would benefit from such an approach. Some stakeholders who are specialists in managing human performance raised concerns with implementing a graded approach, and emphasized the need to be clear on how risk is to be considered in any grading decisions.
Stakeholders said that it would be difficult to implement a graded approach with specific goal-setting objectives, elements and practices. They are having trouble seeing how licensees would implement such a program and how the CNSC would enforce it. They also suggested that a high-level approach to the human performance program's objectives, elements and practices would be easier to put in place in a graded manner.
The CNSC will consider including more detail on the graded approach in a future draft regulatory document on human performance, including objectives, elements and practices intended to be high-level guiding concepts.
The CNSC intends to develop a draft regulatory document that will clarify requirements and provide more specific guidance in the area of human performance, and replace P-119, Policy on Human Factors. The CNSC will provide opportunities for the public, Indigenous peoples, and stakeholders to comment on the draft regulatory document. In addition, the CNSC is always looking for ways to improve its regulatory framework and welcomes feedback at any time.
Canadian Nuclear Safety Commission
P.O. Box 1046, Station B
280 Slater Street
Ottawa, ON K1P 5S9
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