1. GSR Part 2 – Why it is different and how to cope!
Peter Mullins
ONR Professional Lead – Human and Organisational Capability

2. ONR HOC Professional Group
ONR specialists in:
Human factors
Quality management
Leadership and management for safety
Managed through matrix structure:
Line management in specialism
Work in programmes

3. GSR Part 2 Why it is different to GSR-3 Broadly, what’s changed
What’s next

4. “It’s not the management system that makes
Why it has changed: 1
More emphasis on leadership, and management for safety
Global major accidents, experience and research show:
Major accidents happen where there is a sophisticated management system
Common mode failure is safety culture, and the priorities and proficiency of the leadership that drives it.
These are qualitative not quantitative, improved by looking direct at them, not only by altering management systems.
Charles Haddon-Cave:
“It’s not the management system that makes
you safe, people do…”

5. Why it has changed: 2
IAEA trying to bring consistent ‘architecture’ to requirements and guidance.
Requirements are binding and so should be high-level what to achieve, not how to achieve it:
How goes into guidance with a ‘comply or explain’ status

6. Why it has changed: 3
Problems with application of GSR-3 in a number of countries led to representations to IAEA, e.g.:
ENISS concerns – GSR-3 not focussed enough on safety
Spain and other countries where GSR-3 became legal requirements:
Led to legal pressure to address management system matters that had nothing to do with safety
Emphasis should be on delivery of safety, with the integrated management system as a means not the end

7. How it was written
DPP specifying structure of document produced ~ 2010
ONR involved as drafting consultants from January 2012 (team of about 12 invited members)
Member state consultation:
Summer/Autumn 2013 (I coordinated UK response)
Modified draft in response February 2014
IAEA due process for requirements will take at least until early 2015

8. How GSR Part 2 Compares - Outline
GSR-3: 1. INTRODUCTION
2. MANAGEMENT SYSTEM
3. MANAGEMENT RESPONSIBILITY
4. RESOURCE MANAGEMENT
5. PROCESS IMPLEMENTATION
6. MEASUREMENT, ASSESSMENT AND IMPROVEMENT.
GSR Part 2:
1. INTRODUCTION
2. RESPONSIBILITY for Leadership, Management and Safety Culture
3. LEADERSHIP FOR SAFETY
4. MANAGEMENT FOR SAFETY
5. SAFETY CULTURE
Chapter 4:
Most of the main management system features of GSR-3
Slightly less detail
Slightly more mention of safety

9. Comparison of the approach:
GSR-3
“ Management at all levels shall demonstrate its commitment to the establishment, implementation, assessment and continual improvement of the management system and shall allocate adequate resources to carry out these activities.”
GSR Part 2:
“ The senior management of an organization shall ensure that managers at all levels, including themselves, demonstrate effective leadership and implement an integrated management system giving an overriding priority to safety and fostering safety culture”

10. Next Step
DPP for guidance to replace GSG 3.1 and GSG 3.5 developed December 2013
Drafting begins Q4 2014
Aims to complete 2017
Proposed Title: Leadership and Management for Safety in Nuclear Installations
Specifically aims to include ‘how’ guidance from GSR-3 that was taken out of GSR part 2
Also intend to consider 50 C/SG-Q

11. How do we adapt?
We need to get used to the new architecture and structure
Structure and English less clear than GSR-3
But (I believe) change of emphasis and general content is right for safety
Quality community needs to get used to guidance rather than requirements:
Comply or be able to demonstrate that have reached equivalent standard
Similar to goal setting legislation that regulators have lived comfortably with for 30 years

12. Questions?