5. ESTABLISHMENT AND ADMINISTRATION OF FOREIGN MATERIAL
5.4. Assembling programme governance and administration
5.4.3. Documenting administrative framework
departmental FMM programme coordinator(s) or departmental, internal and external subject matter experts and consultants.
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communicated in order to be referenced and followed by everyone in the organisation in every task.
Therefore, a high tier programmatic governing document, such as a descriptive FMMP administrative procedure, that contains the objective, scope, roles and responsibilities, requirements and expectations of the FMMP is developed to effectively establish, implement, maintain, oversee and improve the programme. This descriptive administrative procedure would also include common definitions, elements, methods, goals and assessments needed to implement and improve the programme and establish the basic reference for the low tier, prescriptive implementing procedures.
Here, it should be noted that, depending on the corporate strategy and practice for procedures, manuals or instructions, the FMMP administrative procedure may also include some prescriptive instructions instead of creating another set of low tiers, discipline/work area/task specific implementation procedures, although it may be advantageous to have a ‘one stop’
procedure. However, it should be kept in mind, a single procedure that contains both overall administration of the FMMP and the specific work implementation instructions may quickly become a large and complex. When the administrative procedure contains too many prescriptive and task specific instructions, a check sheet approach may be considered to help the administration of specific FMM requirements associated with the conduct of common tasks.
Regardless of the procedural structure and style, the governing procedure needs to document the established framework for standard application of FMMP in every discipline/work area/task (see Ref. [45], paragraphs 2.522.62).
The governing documents for FMMP are typically controlled and managed by the most concerned division with FMM under the ownership and accountability of programme authority, i.e. FMM Programme Owner/Manager, as described in Section 5.4.1.2. Contents and instructions of the FMMP governing administrative procedure are agreed by all relevant organisation, including cross-organisational/cross-functional entities, e.g. FMM panels, boards, committees (see Section 5.6.2), as reviewed and approved by their leaders and is endorsed by the highest level of management on a nuclear site, i.e. the overall decision authority, described in Section 5.4.1.1.
This FMMP governing procedure typically documents standard methods and tools for task review, preparation and implementation, such as those for the determination of preventive, protective and mitigative controls based on FM hazards and FMI risk levels (determination of which are also prescribed in the governing procedure with clear definition and boundaries of probability and consequences). These methods and tools are applied in the planning of the activities and to be reflected and used in work processes and in the implementing (task specific) procedures and work orders. It is also important that the administrative procedure needs to establish criteria and prescription for exemptions and deviations from the standard methods.
As such, content of a FMMP administrative procedure would typically be consisting of the following information:
— Corporate policy and/or executive management expectations and goals;
— FMM regulations, requirements, industry standards and codes that compel the establishment, implementation and maintenance of FMMP;
— FMMP objective and scope (and exemptions from scope with reasons/justifications);
— Glossary defining and describing key terms used in the programme, e.g. FM, FMM, FMI, FMC, to set standard terminology and concepts for the plant/project;
— Organisational and individual roles and responsibilities for FMMP administration and implementation;
— Common control and conduct of FMM standards and practices in work activities, such as:
FMM prevention, protection, exclusion, mitigation, evaluation definition and scope;
FMRL definition, criteria, methods, tools (e.g. checklists, flow charts) and guidance for assessment, determination and designation of FMRLs;
Definitions, determination and requirements of FMCAs, including setting up permanent and temporary FMCAs to support/facilitate work, preparing and inspecting equipment, work area, tool, material and parts and activities/tasks, managing and controlling personnel and equipment entry/exit, etc.;
FMM planning requirements and expectations, including the job area and task preparation methods, tools;
Training and qualification requirements;
Methods and conduct of change management, i.e. changes in plans, management and control due to changing plant conditions and activity environment and personnel;
Human performance requirements, tools and foreseen/recommended conditions of application;
Identification and references/links to standard forms or tools to utilise in programme implementation, including the guidance on their designation and applicability determination;
— Requirements, criteria and methods for, and conduct of, exemptions/deviations from standard FMM programme, processes, procedures and practices;
— Interface and communication requirements and methods for activities with relevant organisations and personnel;
— Training level and scope requirements, objectives and designation/determination methods to apply FMM training, including graded approach based on functions and skills of individuals and organisations, as well as criteria for task properties, e.g. for complexity, rarity, specialty;
— Incident identification, reporting and resolution requirements, including clear definition and description of organisational and individual roles and responsibilities and applicable programmes and processes:
Criteria and methods for classification and designation of FMM issues, particularly events, near misses and close calls, for reporting;
Selection of reporting processes and references to the applicable programmes/procedures;
Issue resolution request requirements, methods and references to the applicable programmes/procedures;
— Programme health review and assessment requirements, which include:
Identification of data to be collected and analysed and data collection and analysis methods;
Definition, description and interpretation of key performance indicators/metrics;
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Requirements for periodic (and special or as requested) programme assessment, audit and continuous improvement action plans, including the conditions for special review and assessment of the programme;
Definition and description of review and assessment instructions, methods and roles and responsibilities in initiating, conducting, assessing and closing such assessments;
Requirements and processes for continuous improvement and timely update of the programme;
— Requirements, processes and instructions for mitigation and recovery from FMI events, including clear definition of criteria for mitigation entry and exit conditions, description of organisational and individual roles and responsibilities and applicable programmes and processes;
— Requirements, processes, methods, tools (or reference to those) and organisational and individual roles and responsibilities of tracking of unrecovered foreign material in the design and facility records.
The controls and guidance provided in the governing procedure may also specifically target an activity, an environment and/or the personnel performing activities and, in some cases, may define how the activity overall can be carried out controlled and attentive manner with as low as reasonably achievable risk, as to:
— Special training, qualification and authorisation;
— Special activity plan with exclusive FMC measures;
— Modified activity steps;
— Special tools;
— Increased hold and review points;
— Protections against foreseen events that would adversely affect risk and ramification;
— Heightened area entry/exit protocol;
— Exceptional and expanded storage, transport and use of material conditions;
— Rescheduling of nearby activities;
— Identification of steps to be taken in the event of an FMI to minimise consequences, etc.
Section 5.5 discusses the key administrative controls, and their descriptions, that are developed in the administrative framework and documented in the governing procedure.