Risk Management: Relationship between facility managers and regulators
05/012024
Author: Hideka Morimoto
In the environmental field, there are various regulations to manage risks. Inspections check whether regulatory measures are being properly followed. On-site inspections are the point of contact between regulators and facility managers. In what way should regulators and facility managers face each other or divide roles in order to enhance risk management?
For example, under the Air Pollution Control Act in Japan, facility managers are obliged to measure the concentration of air pollutants at the outlet and keep the data. Regulators have access to the data at all times and the authority to conduct on-site inspections from time to time, and to monitor and assess whether compliance with regulations is being carried out. It can be said that it is a way of involvement of regulatory authorities that encourages facility managers to take the initiative and is unique to end-of-pipe regulations.
In order to minimize risk, it is necessary for facility managers to maintain a high level of risk management awareness. What should they do? In the field of nuclear regulation, based on the reflection of the accident at TEPCO's Fukushima Daiichi Nuclear Power Plant in 2011, the regulatory and inspection mechanisms have been significantly revised.
Before the accident, regulators required facilities to be like this, and regulators checked the safety of facilities one by one. Every screw, every pipe, the inspector inspected it over and over again. This has been thought to increase safety.
However, there was a concern that the more thorough inspections were carried out in this style, the more unclear the primary responsibility of facility managers, and the more the mindset became that "all you have to do is passing the inspection" . In addition, it was pointed out that there are multiple overlapping and crowded types of inspections, and that the inspection targets and timing of the inspections are determined in detail, so the facility management is busy dealing with them and does not pay attention to risk management from a bird's-eye view of the whole.
On the inspector side, too, since the checklist system was adopted, there was a possibility that the inspector could not focus on the important things at the time and could not demonstrate the originality of the inspector, so to speak, it became a routine and did not produce a fruitful check.
In short, it was strongly regretted that the system did not contribute to raising the risk management awareness of facility managers.
For this reason, the Nuclear Regulation Authority (NRA), which was established in the wake of the accident at TEPCO's Fukushima Daiichi Nuclear Power Plant, has completely reviewed regulations and inspections. First of all, it was clarified that the primary responsibility for managing risk rests with facility managers, and the regulatory structure has been revised. Specifically, instead of "Equip XXX facilities", it was switched to "performance requirements" (meet YYY standards). This has required facility managers to always move forward to ensure the level of regulatory requirements, rather than maintaining a set of facilities. Second, inspectors now have free access to all facilities and activities and can inspect anytime, anywhere without prior notice. They were given the authority to check all security activities at any time or point of view. Third, inspectors ensure compliance with regulatory requirements prior to commencement of service, but after the commencement of service, inspectors are responsible for "comprehensive" monitoring and evaluation of facility managers' security activities. The mission was not to judge the pass/fail of each machine part, but to monitor and evaluate the entire level of risk management of facility managers.
In this case, the subject of the inspection is not the function of the individual facility, but the ability of the facility manager (the expression "actual ability" may be appropriate). It is the duty of the inspector to strictly monitor and evaluate whether the facility manager has the real ability and intention to improve risk management.
It can be said that the aim is to link both the "effort (real ability + intention)" of the facility managers and the "evaluation of the effort" of the inspector as an opportunity for improvement activities, and to improve the safety of the nuclear facility as a whole.
These techniques, such as eliciting the mindset of facility managers to improve risk management, and evaluating the mindset are widely applicable to the environmental field.
Not only in the field of nuclear power, but also in the field of environmental conservation as a whole, technological advances and the degree of risk management required are in flux. Under such circumstances, in order to prevent risk management measures from becoming obsolete and stagnant, it is necessary for facility managers themselves to be aware of the need to continuously improve their risk management capabilities. There is no end to risk management. Regulators also need to focus on raising risk management