3. Industrial safety and radiological protection: it’s behaviours that count

While indicators can be used to measure safety performance, they only tell part of the story, with the number of safety events being traditionally used. Lagging indicators do not capture the behavioural aspects, and using these as the sole measure of performance can render an organisation blind to the underlying factors. Leading indicators, however, help to identify organisational and behavioural gaps.

Leadership and behavioural safety programmes are designed to tackle behavioural causes. Field interactions help to understand the factors that influence behaviour and to create a collaborative approach. These programmes, which have been in existence since the early 1980s, have proved that leadership and the presence of management in the field increases workers’ commitment and their level of accountability, thereby improving safety performance and reducing the number of accidents.

During my visits, I again found that too much attention was paid to indicators and their management, compared to field observations and improving behaviours. I continue to observe events where behaviours were a contributory cause.

This recurring weakness is attributable to several factors common to both France and the UK, where recent safety programmes have solely focused on managers. High staff turnover and major recruitment programmes have led to a loss of experienced staff. In addition, there seems to be a lack of peer-to-peer challenge or reticence to challenge by workers who should be looking out for each other’s safety. Industrial safety and radiological protection are often perceived as a matter for experts rather than as an individual and collective responsibility.

Other factors are specific. In the UK, since the implementation of the Human Performance programme in the early 2000s, there has been no collective behavioural safety programme involving managers and workers. Over time, the departure of experienced employees has diminished this collective culture. In France, workers are still too inclined to implement countermeasures based solely on their perception of risks.

These shortcomings are recognised by Nuclear Operations and the Nuclear Production Division (DPN). The approach in the UK remains embryonic, with diverse improvement plans. In France, the improvement actions focus on training managers in the hope that they, in turn, will be able to positively influence employees and contract partners.

The safety indicators for DPN are achieving their objectives (see appendices). However, they are too dependent on administrative reporting procedures, and are difficult to compare with international standards. It is therefore essential to rely on the findings of field observations to enable comparison.

During my visits in France, I have noticed differences with the UK and the US. Safety expectations are still perceived by French workers as an obstacle to carrying out their work. Generational and social barriers persist: a young person still finds it difficult to challenge an experienced worker, and a subcontractor to challenge an EDF employee. Managers and supervisors are not aware of their legal responsibilities. Behind the signature on a risk analysis or accepting an isolation permit, do supervisors still have a clear understanding of the risks in the field and their responsibility to their teams?

In the UK, whilst the indicators are good (see appendices), there are indications that behaviours are declining. Nuclear Operations are aware of this trend, and I sense a real desire to arrest it with the aim of achieving international levels of performance.

Drug use is an offence punishable by imprisonment. Committing this offence in the course of one’s duties is an aggravating circumstance. The systematic drug-testing programme is designed to meet a number of objectives: employee health and safety, facility security and the Group’s reputation.

I note that the DPN now has a screening plan at all sites, but only two have implemented it in 2023. I am surprised to note that its deployment continues to be delayed by institutional and administrative resistance, particularly when reviewing draft amendments to the internal regulations. I call on all stakeholders, including the labour inspectorate and union partners, to ensure that 2024 can be the year in which these preventive tests are deployed at all sites for all staff, EDF and contractors alike.

I will be paying close attention to the measures taken on the Penly EPR2 site. I invite the project team to learn from the unfortunate experience of FLA3 and to draw inspiration from HPC’s good practices. These two sites are now carrying out tests that pose no acceptability problems; in 2023, approximately 11,000 tests were done at HPC, more than double of those done in 2022.

Since 2018, the procedures for carrying out testing have been included in the internal regulations of Framatome’s facilities.

Unlike conventional safety, the risks generated by ionising radiation or contamination are difficult to perceive. This characteristic affects workers’ behaviour. To remedy this, they need training, instructions and appropriate coaching. The aim is to influence behaviour by making the dangers clear and explaining the expectations.

In France, refresher courses (safety-security-quality-radiological protection) are not achieving their objectives. This is evidenced by a lack of understanding and respect for radiological work permits, forgetting to wear dosimeters and inappropriate actions when dosimeter alarms are activated. The shortcomings of these courses have been recognised by the DPN, who have asked the Operations and engineering training department (UFPI) to review the training arrangements.

The lack of consistency between sites in the application of radiological protection requirements adds to the confusion of contract partners. I request that this situation be remedied as soon as possible. Contractor personnel movements between sites are already significant and generate substantial risk without adding changing standards.

Three years ago, the DPN launched its radiological protection recovery plan, which has resulted in a reduction in the overall dose to workers and in the number of cases of contamination. However, although the radiological specialists have taken ownership of the plan, there are still major behavioural weaknesses in operations, maintenance and among contract partners. The self-declaration initiative for radiological controlled areas (RCA) implemented at certain sites is to be welcomed: it requires workers who do not have a fixed worksite to check themselves regularly and declare any contamination before exiting the reactor building.