Nuclear Safety Technology and Regulation
2022

Effective Nuclear Regulationand Safety Management ina Pandemic

NE AEffective Nuclear Regulationand Safety Management in a Pandemic
Since March 2020, the COVID-19 pandemic has been
disrupting almost every facet of global activity. Governments
have imposed measures, especially sanitary ones, in an
attempt to contain the spread of COVID-19. These actions
have in turn changed how industries operate and challenged
their ability to ensure safe business continuity. The global
nuclear industry responded effectively to the pandemic:
nuclear power plants, for example, continued to operatesafely, providing energy when the world needed it most,and nuclear regulators adapted their processes to ensure
continuous oversight. The experience gained in managing
activities during this global health emergency neverthelessoffers valuable learning opportunities for industries beyond
the nuclear sector.
Two years on from the outbreak of the global health crisis, it isimportant to analyse how the nuclear industry progressively
developed business continuity modalities within a constrained
context (which may include sanitary measures, limited staff
availability, supply chain complications, the shutdown and/or restarting of some nuclear facilities and/or services) andto explore the long-term impact of COVID‑19 on safety
management. New safety paradigms have emerged. It isessential to consider what has changed, why, and which of
the new approaches has had a positive impact and should bemaintained for the future.

• attract, develop and retain key competencies that areneeded in the sector and will be indispensable in thecase of unexpected challenges;• compare the response of the nuclear sector to major
crises to that of other sectors.

Panellists
Over 40 experts from the CNRA and the CSNI from15 countries and international organisations came together
to listen to three guest speakers and participate in thepanel session. Mr Pascal Luciani, Deputy Director of theFrench Civil Aviation Safety Authority gave a presentation
on “Shutting down and starting up again safely: The Caseof Civil Aviation”. Mr Pascal Garel, Chief Executive of theEuropean Hospital and Healthcare Federation (HOPE) thenprovided insights into “Industrial continuity in overflow
context: The Case of Hospital Management System”. The
final guest speaker, Mr Luis Soriano Martinez, Directorof the World Association of Nuclear Operators’ (WANO)
Paris Centre, examined “Perspectives from the commercial
nuclear power sector”.

Special topical session
On 1 June 2022, the NEA Committee on Nuclear Regulatory
Activities (CNRA) and the Committee on the Safety ofNuclear Installations (CSNI) brought together the operational
experiences of three guest speakers from the aviation,
health and nuclear sectors. The speakers participated ina panel session that discussed lessons learnt from theCOVID-19 pandemic. The lessons learnt related to, among
other things, ensuring business continuity during a healthcrisis and long-term risk management, and identified new
initiatives to potentially build upon. NEA Director-General
William D. Magwood, IV, moderated the discussion, which
was opened by Petteri Tiippana and Jean-Christophe Niel,
the Chairs of the CNRA and CSNI, respectively.
The discussion highlighted several challenges andopportunities, particularly the need to:• identify lessons learnt in order to enhance the resilienceof the nuclear sector, its main actors, organisations andpractices in preparation for both expected and unexpected
future challenges;• develop tools to increase trust within each organisation
and among external stakeholders and as a key componentof future resilient responses;

EFFECTIVE NUCLEAR REGULATION AND SAFETY MANAGEMENT IN A PANDEMIC, © OECD 2022

Left to right: Petteri Tiippana, Chair of CNRA and Director General, STUK;William D. Magwood, IV, NEA Director-General; Pascal Luciani, Deputy
Director, French Civil Aviation Safety Authority; Pascal Garel, Chief
Executive, HOPE; Luis Soriano Martinez, Director, WANO Paris Centre;
Jean-Christophe Niel, Chair of CSNI and Director General, IRSN.

1

Nuclear safety and regulatory
challenges since the COVID-19
pandemic began
Continue to monitor the long-term effectsof the pandemic and facilitate constructive
dialogue with other sectors
At the height of the pandemic, many similarities were foundbetween industries that are strictly regulated by high safety
standards. These standards mostly relate to adaptationsof safety practices that were essential to operate withlockdown measures in place, manage organisational andhuman factors and ensure a state of preparedness forcoping with unexpected situations.
Analysing the experiences gained over two years ofoperation during the pandemic crisis proves enlightening.
However, the long-term effects are still not fully known.
It would be beneficial to establish a dialogue with otherhighly regulated industries in order to share views on
strengthening safety and resilience and develop initiatives
to increase the reliability of managing such events.

Review and streamline safety practices toconsider unexpected or unprecedented
situations
The pandemic challenged conventional safety practices.
For example, there were severe restrictions and limitations
with regards to on-site surveillance and inspection, periodic
qualification testing and in-person training, particularly whenstrict lockdown measures were in place. Remote practices
had to be implemented and some requirements had to bewaived.

“These challenges underlined the need for enhanced trust
between regulators and operators and for discussions on
the possible adaptation or “modernisation” of conventionalsafety practices for the future. These adaptations included,
for example, the adoption of remote working and use ofvirtual reality technology where possible and whereeffective.
Shared experience on inspection practices: There isno substitute for in-person inspections and oversight tocapture safety-related information. Remote inspections rely
on indicators that only give a partial view of the situation
but can provide much more flexibility and data. Therefore,
the scope of the “modernisation” of inspection practices
in normal and non-normal situations still needs to be
discussed between regulators and operators. In addition,
it could be beneficial to share this discussion with otherindustry sectors.
Shared experience on derogation with substantial
safety margins: Regulators have put mechanisms in place
to address derogations during the pandemic, with the needto accompany waiver decisions with a risk assessment
before implementing mitigation measures and monitoring
the impact of the waivers. With regard to operator requests
to regulators to waive certain requirements, in principle
waivers should be kept to a minimum. The objective isfor operations to remain within the safety margins in spiteof the waiver. It could be beneficial to share experienceson the approaches and decision-making processes for
managing derogations that have been applied in different
sectors.

Prepare for the unexpected
There is evidently a need to be able to respond tounexpected situations, including challenging situations suchas pandemics and high impact natural disasters. Existingprocedures provide correct responses and courses of action
and should remain in place. However, it would be beneficial

It’s not just about COVID-19 but how we respondto the unexpected and to challenges in ournormal practices.
…. It’s not so much planning for the next
pandemic but it’s learning how to adapt and be
more resilient.
William D. Magwood, IVNEA Director-General

EFFECTIVE NUCLEAR REGULATION AND SAFETY MANAGEMENT IN A PANDEMIC, © OECD 2022

2Group photo taken at the OECD Boulogne Building on 1 June 2022.

to review and enhance current working practices in orderto ensure that they can offer a better response to theunexpected. In the case of unexpected events, it is clearlydifficult to define a “worst-case scenario”. Nuclear actors
nevertheless have an obligation to maintain high levels ofnuclear safety in these situations. In doing so, they should
evaluate the following:• How to develop “intrinsic” knowledge (scenario-thinking
based on analysis and understanding of situations)in addition to “procedural” knowledge (linked to theapplication of existing procedures). “Intrinsic knowledge”
would allow initiatives and innovation to add value. Both theCOVID-19 pandemic and the Fukushima Daiichi Nuclear
Power Plant accident are considered to be examples of
unexpected situations where scenario-thinking was usefulfor making the right decisions.

• How to train dedicated teams for unexpected situations(for example, through exercises and situations that are
unforeseen in procedures). This could be a practical andoperational way forward. Although it is not possible toguarantee that the next crisis would be covered by such
exercises, such training should increase the flexibility,
initiative and capacity for innovation of response teams.

• How to better account for the emergence of unexpectedfactors and changes to the environment (such as lockdown
measures and the adaptation of the natural environment
during the COVID-19 pandemic) in a systemic approach.

• How to ensure direct access to reliable and high-quality
data that can support decision making during crisis
situations as well as how to use available data more
effectively in non-crisis situations in order to better
prepare for possible crises.

EFFECTIVE NUCLEAR REGULATION AND SAFETY MANAGEMENT IN A PANDEMIC, © OECD 2022

Anticipate loss of competencies, isolationand communication issues
The pandemic and lockdown measures prevented face-toface contact between individuals for long periods of time.
There was therefore an observed tendency for people tobe more isolated and for the communication of potentiallycrucial informal information to be limited. These changes
negatively affected the efficiency of maintenance, thecontinuous training of employees and workers, and thedevelopment of organisations’ collective knowledge andculture, in particular the safety culture and the preservationof several heritage aspects. The maintenance of strong
leadership in the absence of personal contact with staff
remained a challenge that required the application ofinnovative solutions. Moreover, the integration and trainingof new people, including mentoring, was clearly moredifficult to achieve during the pandemic. It is still difficult
to measure the impact of all these restrictions and newsolutions. The monitoring of any related degradationthat is not visible today and the implementation ofcountermeasures could help mitigate long-term effects.

Organisations could benefit from improving andstrengthening ethics guidelines cultivating
professionalism in such situations
Professionalism and the development of ethics inmanaging unforeseen situations, with a focus on safety,
are fundamental when dealing with a crisis. In terms ofhuman factors, individuals experienced stressful situations
during the pandemic (for example, isolation, the impactof the pandemic on relatives and the worry of potential
exposure to the virus) that each person could tolerate to3differing degrees. Maintaining staff motivation and wellbeing was a challenge for team leaders. Limited face-toface contact resulted in managers feeling unable to gauge
their employees’ state of mind. Leadership challenges also
emerged related to the decision-making process at several
levels: the hierarchy between the institutions in chargeof public health recommendations and nuclear safety
requirements could be questioned in several practical cases.

Guidance on managing individuals and teams
in a changing and stressful environment would
help to better prepare for future crises
Guidance could also address how individual mental healthand personal focus can be an issue in highly stressful
situations that take place over a significant period of time.
It should also include the process for dealing with situations
where organisations do not have the capacity to replacestressed staff and, for example, whether psychologists
should be involved to help manage these situations.

In general, there is a clear need for organisations’greater resilience for dealing with unexpected situations.
An important concern is how flexibility and adaptability canbe mobilised by the licensees while keeping the highest
standards to manage the safety of nuclear facilities. Whileaiming to implement adequate flexibility and adaptability
in facilities, licensees should justify ensuring nuclear
safety. Regulators should review their licensing andapproval processes, including operational oversight, to beable to consider these evolutions and assess them. For
example, a risk-informed approach implies greater trust
between licensees and regulators. Another trust factor
is the harmonisation of how key principles and limits areunderstood and the value of exceptional rules being
discussed collectively. Creating a risk-informed approach
emerges as an area for future discussion and the NEA
already includes it in its programme of work. Such a
discussion could assess how to better implement riskinformed regulation and improve trust between regulatorsand licensees.

Increase flexibility, adaptation, trust andlong-term resilience
The understanding that the environment can change
radically, acceptance of unexpected situations leading
to unusual measures and confidence in the ability todeal with the unexpected are essential in the nuclear
sector. Previous contingency plans failed to anticipate thespecifics of pandemics and there was no clear roadmap
to recovery. Planning and decision making evolved in
response to the pandemic. People and systems wereevidently able to adapt quickly to new situations, measures
could be implemented in the short term and there was a
rapid switch to a revolutionary approach of work, wherepossible. One important lesson learnt is that measures canbe implemented faster than expected if adequate decisionmaking processes are in place.
Specific decision-making processes were implemented
during the pandemic with dedicated structures which
proved to be efficient and were closed down when normal
operations resumed. Although this may be appropriate inmost cases, in some cases new decision-making processes
could remain valid and be used to optimise normal operationprocesses.

EFFECTIVE NUCLEAR REGULATION AND SAFETY MANAGEMENT IN A PANDEMIC, © OECD 2022

Implementing dedicated decision-making
structures, including flexible processes, intothe general organisational procedures tosupport the implementation of faster andmore effective responses in future crises
should be advanced.
Moreover, the key assumptions for safety
rules and management should be reassessedin detail in order to identify areas whereunexpected external factors could prevent
their application or may require flexibility inthe application of rules aiming to achieve theintended safety objectives.

Discussions could also address the principles regarding
the exceptional rules to be followed during a global crisis,with the aim of making them easier to accept and to thenconsider them in country-specific decision processes.

4September 2022

Cover page photos: Meeting (Monkey Business Images/Shutterstock); Helmets (Nuei57/Shutterstock); Group of people wearing masks (petovarga/Shutterstock).

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