Government, regulators and industry unite on new efficient regulatory principles

The Department for Energy Security and Net Zero (DESNZ) has issued a Ways of Working document, developed collaboratively by government, ONR, the Environment Agency, and nuclear industry representatives.

It establishes nine principles to guide the application of ‘As Low As Reasonably Practicable’ (ALARP) and ‘Best Available Techniques’ (BAT) – the fundamental concepts underpinning UK nuclear safety and environmental regulation.

The document helps re-examine the regulatory framework and how the industry responds to ONR’s goal-setting approach and decision-making around tolerability of risk – ultimately exploring how the sector can work more efficiently together.

The principles sit upon one foundation block focused on optimisation and proportionate risk consideration, supported by the nine principles covering behaviour, communication and process.

ONR is committed to removing any unnecessary burden from the regulatory framework, while maintaining rigorous safety standards.

Key principles of the Ways of Working document include:

• Open-minded and flexible approaches to how ALARP and BAT are demonstrated, recognising that multiple valid methods may exist
• Mutual understanding between stakeholders about regulatory compliance judgements and decision-making processes
• Early and regular engagement between dutyholders and regulators to avoid surprises and identify issues early
• Clear communication with robust, well-presented evidence proportionate to the hazard
• Appropriate consideration of previous decisions, including the use of Relevant Good Practice (RGP) to avoid unnecessary first-principles analysis

The framework emphasises that effort expended in demonstrating compliance should be proportionate to the risk identified.

It notes that deterministic assessments of extremely low probability events can accumulate conservative assumptions, and stakeholders should understand the relationship between assessments and actual risk of harm.

Government has endorsed the Ways of Working principles and it was included in the Prime Minister’s Strategic Steer to the nuclear sector, following the Nuclear Regulatory Taskforce’s review.

ONR has long embedded the framework across its regulatory activities, but this publication will serve as a reminder and a new spur on how to implement and support effective and progressive operations within the nuclear sector.

To support the Ways of Working document, ONR has recently established a new Regulatory Policy Team to review key policy documents and address misunderstandings around concepts such as Relevant Good Practice through workshops for inspectors and industry.

RGP is a concept used by regulators and international bodies to describe methods, standards, or approaches that are widely accepted across the industry as being effective in delivering particular safety, security, or safeguards outcomes.

The Ways of Working principles apply across the nuclear sector, including licensees, the supply chain, requesting parties in Generic Design Assessments, government departments and environmental regulators.

Cathy Collins, who leads ONR’s Regulatory Policy Team, said:

“We welcome these re-established principles and we’re really pleased to have had the opportunity to contribute to developing them. This is a good time to remind us all of best practice when there’s so much change in the industry. Different types of reactors are entering the market, new organisations are joining the sector from different regulatory regimes abroad, and there’s a lot of people change so it’s key that expertise and knowledge is captured.”

The government’s recommendations implementation plan following the Taskforce’s final report is expected to be issued in the coming months.