Learnings From Inspections: Plans need to work together with Standard Operating Procedures
Plans and arrangements for managing safety (Plans), typically including a radiation management plan, are submitted to ARPANSA during the initial licensing process. They must be maintained (Planned Exposure Code) and updated at least every 3 years (section 61 of the Regulations). Plans are reviewed by ARPANSA during inspections and assessments. It has been found that when standard operating procedures (SOPs) are changed the changes are not always reflected in higher level plans (e.g. not listing or linking new equipment types to the Plans).
The Plans need to be used, be useful for the organisation, be effective and followed by those who refer to them.
Why SOPS are being updated while Plans are not
In general, SOPs are likely to be updated more frequently as they need to be used more often by staff than the Plans. Reasons why Plans are not updated with SOPs can be human, technological and/or organisational. For example:
- A human factor observed is when the person responsible for updating or monitoring Plans changes, the responsibility is not reassigned or known during handover.
- A potential technological factor could be difficulties experienced with change and document control management systems, e.g. There is no indicator or reminder to update the Plan.
- An organisational factor could be how the organisation perceives and approaches the purpose of the Plans. When an organisation writes a document for the regulator instead of preparing it as an operational document, this can create gaps between what is proposed, what is done in the workplace, and observed by regulatory officers.
How you can improve the currency of your Plans with SOPs
To prevent the Plans becoming out of sync with the SOPs, the review task needs to be part of routine operation – with sufficient resources for the staff involved in updating the information. This can include:
- Developing prompts for relevant staff so they can efficiently make changes to key parts of the plan as changes occur
- Ensuring changeover tasks are communicated and guidance available, especially for those who are new or covering a role
- Organising sufficient time/resources for ensuring updates can be completed within workloads
- Looking at ways to streamline the process, including how obstacles can be overcome at an organisational level
- A change management system which is proactive in identifying necessary changes and making them in a timely manner
- Understanding how the Plans reflect safety in a holistic manner (see Holistic Safety Guide and Sample Questions)
- Knowing when changes need to be reported to ARPANSA (see Additional Tips here)
While ownership of the high-level Plan often is with senior management, having operational staff involved helps keep them aware of changes and is a way to facilitate proactive safety management. Regular reviews with staff who need to enact the Plan is critical to ensuring that it reflects how work is conducted, the latest SOPs and radiation safety challenges that need to be addressed in a continually changing industry landscape.