Oversight of contractors

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4.48.

Where contracted services are an integral part of construction, there are specific challenges to the oversight of contractors to ensure safety during all stages in the lifetime of the installation (see para. 4.3). The use of contracted services tends to be greater in the following situations: an insufficient availability of nuclear expertise within the licensee; a supply chain that extends to other States; first-of-a-kind projects; and turnkey projects. These situations create challenges relating to: the retention of expertise; the effective management of the interfaces between the licensee, the construction organization and its contractors;

and the oversight of the quality of manufacturing by contractors in the context of greater multinational diversity and supply chains that extend to other States.

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4.49.

The extent of oversight of a contractor’s activities by the licensee and/or the construction organization should be based on a graded approach. The extent of oversight will depend on the following:

  • The safety significance of the item or service;
  • The experience of the licensee and the contractor in relation to the products or services being procured;
  • The presence of any first-of-a-kind features;
  • The complexity of the work or service;
  • The expertise needed to carry out the work or service;
  • The extent of evidence available that the appropriate quality has been achieved;
  • The use of independent third party inspections;
  • Legal and regulatory requirements.
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The licensee should be notified of the results of the oversight performed by the construction organization on safety related matters and, if necessary, should be able to present the results to other interested parties.

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4.50.

Before initiating any activity following the award of a subcontract, the contractor should demonstrate to the construction organization, and to the licensee if required by the licensee, that the contractor is fully aware of all relevant requirements for the activities. The safety requirements specific to the subcontract should be specified, which should cover the following:

  1. Applicable safety requirements for the item to be manufactured or built;
  2. Interface arrangements;
  3. Arrangements for communication;
  4. Documents and information to be submitted, including non-conformance reports and evidence that the as built items meet the safety and quality requirements;
  5. The management system, including adequate safety culture and oversight and arrangements for supervision.

In addition, if the contractor(s) is working on the site, additional requirements should be specified, which should cover the following:

  1. Housekeeping;
  2. Security of the site;
  3. On-site training.

The arrangements that the subcontractor will make to satisfy these requirements should be finalized and agreed before the subcontractor starts the activity. The licensee should be notified of these arrangements, for its approval, as appropriate (particularly if the construction organization is not part of the licensee). An initial kick-off meeting attended by all parties, including the licensee, should be held to verify all these issues.

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4.51.

The construction organization should be informed of all the subcontractors selected by the contractor. Any new subcontractors appointed after the initial agreement is made should be made known to the construction organization and should be agreed before relevant work begins.

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4.52.

The construction organization should organize regular meetings with contractors and subcontractors to review and ensure implementation of the requirements of the construction organization.

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4.53.

Each contractor should conduct regular pre-job meetings to discuss work processes, the schedule, deviations and any other important aspects of work relevant to safety and quality.

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