“Time to stop talking and start acting”: Prospect responds to final report of the Nuclear Regulatory Taskforce
The Nuclear Regulatory Taskforce, an independent commission set up by the government, has published its final report, calling for a ‘radical reset’ of nuclear regulation in the UK.
The report includes 47 recommendations intended to speed up delivery, reduce costs and strengthen safety of building new nuclear.
Among the recommendations is call to establish a ‘one-stop shop’ for nuclear decisions to avoid duplication and streamline the regulatory process.
See the taskforce report and recommendations in full.
Sue Ferns OBE, Prospect Senior Deputy General Secretary, responding to the publication of the Nuclear Regulatory Taskforce’s report, said:
“There is scope for streamlining work on nuclear licensed sites, but we reject the description of systemic regulatory failure. Regulatory barriers, real or perceived, are not the greatest challenge to the UK’s nuclear future and priority must be given to ensure a stable and secure investment climate. We also need a firm commitment and funding for long-term construction, training and supply chain programmes.
“Whatever changes are brought forward must not be at the expense of safety. Unions have been at the forefront of making the nuclear energy a safe place to work and must be involved in the drafting and implementation of new rules.
“There are however many important and potentially effective recommendations in the report. The concept of a lead regulator could work well, but merging DSNR with ONR will inevitably cause further uncertainty and time to work through. Urging more action from the Nuclear Skills Delivery Board is also important but it does not include any trade union representation so it is difficult for many stakeholders to judge how effective it is.
“Finally, the report rightly points out the disconnect between pressure being put on regulators to facilitate growth, and their ability to attract and retain talent through adequate pay. This report is now the latest in a series of government-commissioned reports that makes this point – it is time to stop talking and start acting. If the Chancellor is serious about using regulatory levers to drive growth she also has to use this Budget to back the people and organisations responsible for delivering on these objectives.”
Prospect position statement on nuclear regulation
Prospect is the union representing professional workers across the civil and defence nuclear sectors and their regulatory bodies. Prospect supports the development and safe deployment of a range of nuclear technologies and continued progress of the decommissioning mission.
Our members are always willing to consider genuine improvements to the way in which these sectors are regulated, However, polarisation and politicisation of these issues is not helpful. The regulatory framework is built on optimising balance.
For example, we recognise that there is scope for streamlining some work on nuclear licensed sites where this does not involve nuclear technology, for example in relation to civil infrastructure work. Regulation should be applied by operators based on critical evaluation of what is actually required, rather than prevailing culture or behaviours. It is important to distinguish between the need for systemic change and the application of systems The ALARP (As Low As Reasonably Practicable) principle is about finding a balance. It is not an exact science.
The Nuclear Regulatory Task Force and other commentators have focused on the need for a proportionate regulatory approach but have not fully explored what this will look like in practice. For instance, it is important to distinguish between first of a kind (FOAK) and many of a kind (MOAK) technology. There is already commitment from the Office for Nuclear Regulation (ONR) and the Environment Agency (EA) to streamlining processes, taking into account assessments done in the USA. In our view Government needs to define proportionality in relation to ALARP and Best Practical Means (BPM) bearing in mind that ALARP is a cross-cutting principle that could have implications for other sectors.
It is correct to highlight under-resourcing and failure to pay market rates as constraints on the regulatory process. There is a shortage of skills and capacity. Like ONR, the Defence Safety Nuclear Regulator (DSNR) is under-resourced. Ninety-five posts have been unfilled for two years, with staff moving from the private defence sector promised a £12,000 NSQEP allowance that has yet to materialise. Whilst international collaboration has benefits, it can result in loss of specialist talent overseas in an environment of constrained UK training capacity.
Prospect would have no objection to closer working between regulators. However, any merger of regulators would have wider and significant impacts and would be likely to delay implementation, for example of the UK/USA nuclear partnership commitments announced by the Prime Minister in September. Regulators work across nuclear fission and fusion, and many are already concerned and uncertain about the impact of other proposed changes, such as those in the Cunliffe review and those taking place across the NDA Estate. This broader context is important and must be taken into account by decision-makers.
Revolutionary change may have superficial attraction, but it is not a sensible approach to delivering quickly. Any programme of change will be best delivered in consultation with the frontline experts charged with delivery and with their trade union. Regulatory barriers, real or perceived, are not the greatest challenge to the UK’s nuclear future. Priority must be given to ensuring a stable and secure investment climate and as well to commitment and funding for a long-term construction, training, and supply chain programme.
