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ARPANSA schedules inspections well in advance, based on risk. Reviewed regularly, the inspection scheduled for a facility takes into account the inherent risk. It also considers the quality of safety controls in place and past performance. If inspectors identify consistent good performance, the frequency of inspections may decrease.
ARPANSA assigns a lead inspector for each licence. The lead inspector is the primary point of contact and maintains a high level of familiarity with the licence holder’s activities.
Typically the lead inspector will assemble a team of two or more people for each inspection. The team may include special expertise depending on the scope of the inspection and may include external subject matter experts. The team will determine key elements of the inspection, refine the scope and develop an inspection plan.
The lead inspector will liaise with the licence holder to agree on a suitable date and provide email notification at least two weeks before the inspection. ARPANSA will often request copies of relevant documentation before the inspection such as latest procedures, radiation surveys, and dose records.
An initial meeting is scheduled to allow introductions, define the roles of the inspectors and to confirm the inspection’s purpose, scope, and timetable. This is also an opportunity for the inspectors to ensure that they are familiar with any workplace hazards that may be present and relevant site safety and emergency procedures.
An inspection typically takes one or two days but may take up to five days for a complex site or facility. Inspections focus on features, controls and behaviours that contribute to the safety of the source or facility. Inspectors may gather information by talking to workers and managers, inspecting documents, observing procedures, taking photos or videos, taking measurements or samples. For more information see What inspectors look for.
Typically held on the last day of the inspection, the exit meeting is a time for agreeing the facts. There should be no surprises; discussions with appropriate staff about any significant issues should have occurred beforehand. The exit meeting affords the licence holder the opportunity to clarify and explain any identified issues.
Following an inspection, and before the final report is issued, the licence holder is given an opportunity to comment on the findings.
Issues are characterised as a ‘non-compliance’ or ‘area for improvement’ and evaluated for significance. Licence holders are required to investigate and correct any non-compliance. Areas for improvement are expected to be addressed voluntarily by the licence holder, consistent with a desire for continuous improvement. Routine monitoring by ARPANSA will determine the effectiveness of any action taken.
Where there is non-compliance, ARPANSA will evaluate the degree of risk posed by that non-compliance to determine what level of action is required. See Regulatory Guide: Graded response to non-compliance for more information.
Following each inspection, the licence holder is asked to complete an anonymous online survey on the inspection process. The information received informs the annual review of the inspection program and assists continuous improvement. See Inspection outcomes for more information.
ARPANSA annually reviews its regulatory activities, including the inspection program, to ensure they continue to be efficient and effective. This review takes into account feedback from licence holders, the Australian Government’s Regulator Performance Framework, as well as all good practices, areas for improvement and non-compliances identified during inspections.
While non-compliance and areas for improvement usually identify a specific issue, there can often be a number of underlying factors, so it is important that licence holders look beyond the specific issues.
Licence holders should assess both direct and contributing causes and implement controls to address both. Licence holders should also consider whether there are lessons to be learned from the inspection that are relevant for other parts of their organisation. This process should form part of the organisation’s holistic safety approach.
For more detailed information on the inspection process see the Inspection Manual - May 2021