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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 the past performance of the site. If inspectors identify consistent good performance, the frequency of inspections may decrease. Inspectors may conduct extra (or augmented) inspections if ARPANSA believes safety performance needs to improve to reflect international best practice.
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 build a team of two or more people for each inspection. This team will include a range of specialist expertise to cover 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. They will provide email notification at least two weeks before the inspection. ARPANSA may also request copies of relevant documentation before the inspection (e.g. latest procedures).
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 lasts one to five days. Inspections focus on features, controls and behaviours that contribute to safety of the source or facility. The inspectors may gather information by talking to workers and managers, inspecting documents, taking photos or videos, taking measurements, or taking 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 identified during the inspection. 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. Agreement can be reached about any potential non-compliance and/or areas for improvement.
Following an inspection, and before the final report is issued, the licence holder is given opportunity to comment on the findings.
Issues are characterised as ‘potential 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 requested to complete an anonymised online survey to provide feedback 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, and all good practices, areas for improvement and non-compliances identified during inspections.
Inspections may identify non-compliances to legislative requirements, areas for improvement to meet best practice. While both non-compliance and areas for improvement identify a specific issue, the issue can have a number of underlying causes which have contributed to the problem which was observed. Licence holders should review the specific issue identified, assess the direct causes and contributing causes, and implement controls to address the underlying causes. 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 2019