Office for Nuclear Regulation

New ONR Enforcement Management Model

25 April, 2018

A new enforcement management model (EMM) that aims to ensure consistent, proportionate and transparent decision-making by nuclear inspectors has been introduced by ONR.

The new model follows an extensive internal review by ONR along with engagement with licensees and dutyholders. It is designed to help inspectors to make decisions regarding the degree of enforcement required where dutyholder non-compliance and deficiencies are identified.

Chief Nuclear Inspector Mark Foy explained:

“The new model updates and replaces the previous EMM ensuring it is fit for purpose and reflects the nature of the nuclear industry. Since vesting as a statutory corporation on 1 April 2014, we have continued to apply the same EMM that we inherited from the Health and Safety Executive (HSE), our pre-vesting parent organisation.

“However, use of HSE’s EMM highlighted inadequacies when ONR sought to apply it in a nuclear or radiological context, as it fails to account for the full scope of ONR’s regulatory vires and the risks associated with the hazards of the nuclear industry.

“ONR’s new EMM and supporting guidance provides a clear, logical process for inspectors to make enforcement decisions in accordance with ONR’s Enforcement Policy Statement (EPS).  It will ensure that our enforcement decision making is properly aligned to the industry we regulate, and the model can be applied consistently across each one of ONR’s regulatory purposes, as defined by The Energy Act (2013).”

The new EMM will:

  • Ensure consistency and simplify the enforcement decision making process.
  • Provide a framework for making enforcement decisions that is more transparent, and ensure that those who make decisions are accountable for them.
  • Improve proportionality and targeting by considering the risk based criteria against which decisions are made.
  • Better equip inspectors to make decisions in complex cases, and allow peer review of enforcement action.
  • Ensure that there is a consistent and proportionate approach to when and how we record enforcement decisions.
  • Enable ONR to more easily coordinate enforcement management information.