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Training and qualification requirements

5. ESTABLISHMENT AND ADMINISTRATION OF FOREIGN MATERIAL

5.5. Establishing and describing administrative controls

5.5.8. Training and qualification requirements

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undergoing formal qualification (certification) and authorisation for task performance and responsibilities, including those for FMM (for example, for maintenance staff);

— An evaluation of FMM training effectiveness, that is governed by the evaluation process within the training programme, needs to be performed. The evaluation is done against the approved FMM training needs and FMM training programme and process descriptions, as well as the formal QA requirements of SAT based training procedures.

As aforementioned in Section 4.7, the development of the training to support the FMMP needs to be in line with SAT methodology, but to simplify, the basics of the training can be covered by looking at the ‘5Ws’ of training: why, who, what, where and when, which indicate purpose, audience, content, delivery method and time and frequency, respectively, as discussed in the following Sections.

5.5.8.1. Purpose of training

The ‘why’ of delivering FMM training is relatively easy. For a project/plant FMMP to be fully effective, the personnel intuitively and continuously recognise the appearance of FM, its interpretation, e.g. its potential to intrude during task performance, and the prevention techniques needed to eliminate or minimise the hazard and risk. Communicating clear expectations to workers and including the purpose of the programme via the training programme provides the base knowledge to support the proactive approach of preventing FMI events.

It needs to be clear that training conveys information and provide knowledge to individuals and results in that qualification/certification which is a management system action that grants permission to individuals to perform certain roles or tasks per requirements and expectations described in the FMMP procedures. The FMM training is followed by a test or objective evaluation of the person’s skills and abilities so that management has a basis for granting authorisation to individuals to fulfil the role or perform the task in accordance with the skill, competency, experience and knowledge requirements and expectations of FMMP.

5.5.8.2. Training audience

The ‘who’ of training is a little more complicated. Dependant on specific worker responsibilities, the definition and identification of training audience may differ from one owner/operating organisation to another. Moreover, depending on the type, specialty, significance, complexity, routineness or frequency of activities, the audience will be different among the disciplines and organisations of the same site. However, common programme requirements include:

— A basic or introductory level of FMM training needs to be provided to all personnel who have unescorted plant access;

— Everybody at site need to have training to reach the same levels of FM awareness, understanding the purpose of the FMM and FMMP;

— Everybody on site needs to learn and understand their specific (required and/or expected) roles and responsibilities for FMM and for support the implementation and improvement of the programme;

— Both regular site staff and the contract/supplemental personnel understand the importance of a successful and effective FMMP and are familiar with FMM concepts and the FMMP requirements and expectations;

— Everybody at site has to have a basic understanding of the consequences of a loss or failure of cleanliness and housekeeping and/or control and management of FM.

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Beyond these basic FMM training audience, the training is no longer ‘one fits all’. Therefore plant’s/project’s FMMP defines the applicable FMM qualifications and the necessary training for these qualifications, which are to be geared and targeted to the different levels of FMMP involvement that exist amongst the work groups or levels within the organisation. Particularly, these work group include, as a minimum: maintenance, work management, operations and fuel handling, engineering, chemistry, radiation protection, QA/QC inspectors, supply/procurement and warehouse and security. It is necessary that both front line workers and contractor of these disciplines, as well as their management (i.e. frontline team leader/supervisors and departmental and divisional managers) attend these targeted trainings.

Also, among the particular roles that require specific training, the FMMP administrators (FMM Coordinators) and experts (FMM Conscience) are unique audience owing to their additional roles and responsibilities and required expertise, experience and knowledge in FMM and FMMP.

5.5.8.3. Content of training

All FMM training need reflect the basic FMM concepts and any specific FMMP requirements.

Reinforcing FMCs are needed to anticipate, prevent, protect the SSCs from FM hazard, risk and impact, and to eliminate, minimise or mitigate a FMI incidents, as well as the importance recognising, identifying and immediately reporting of any potential FM hazard and risk to SSCs and FMCs are the basics of the ‘what’ of FMM training.

Again, the objectives, levels or degrees of training and extent or details of the courses are dependent on the assigned responsibilities of the training audience; however, the development of the training for the specific qualifications needs to align with the SAT methodology.

Training material are to be prepared based on a set of determined and defined objectives, which may vary dependent on the target audience and the type, significance, specialty, complexity, routineness or frequency of activities.

Personnel who perform hands on work with plant SSCs ought to receive a higher level of training material and concepts. To be more effective, the plant/project worker training, that is geared to the tasks that particular individual or work group performs, may focus on, as applicable:

— FMM culture (topics related to the traits discussed in Section 5.3);

— FMRL assessments;

— Application of FMM requirements and expectations in task planning;

— Setting, maintaining and modifying FMCAs and FMCA buffer zones;

— FMM briefing and communication requirements;

— Control of personal items;

— Application, use, restrictions and exceptions on FMC devices, such as bungs, tethers, plugs, etc.;

— Material storage requirements;

— Activity generated FM control;

— Liquid and gas FM and their control;

— Conduct of FMM inspections and verifications;

— Reporting criteria, methods and tools for FM events, near misses, close call, identified issues;

— Conduct of FMM observations;

— FM recovery activities, tool and techniques;

— FMI recovery and evaluation requirements;

— Housekeeping and cleanliness requirements and behaviours.

All these focused training contents also include relevant OPEX to demonstrate and reinforce the consequences that poor FMC practices can have, and have had, on nuclear safety and performance across the industry, as well as other high risk/high consequence industries, such as aviation, food, medicine, pharmaceuticals, etc. Using OPEX to demonstrate how significant poor (or effective) FMM practices can be, is very helpful to connect the requirements and expectations to actual and real consequences.

Due to the important oversight, programme management and administrative functions that they perform, it is recommended by the industry experts that FMM Coordinators and FMM Conscience have additional information and knowledge over and above plant management and worker trainings. Similarly, owing to the significance of their responsibilities, independent inspectors and area monitors need to hold special qualification and receive training over and above other plant worker trainings. This special training and qualification need to reinforce the importance of their role and contain instructions for their roles, as defined/specified in the FMMP governing document, including:

— Accurate tool and material logging and reconciliation;

— Inspecting and controlling FMCAs and buffer zones;

— Loss of FMCA integrity identification and reporting;

— Conduct of tool integrity checks;

— Training qualification verification;

— Closeout inspection verification.

5.5.8.4. Training delivery methods

Design, development and delivery of training that meets the specified requirements of FMMP can include a e-modules, classroom, laboratory or simulator (i.e. mock-up and hands on) training. This can be referred to as the ‘where’ element of the training and, again depends on the nature of particular role, responsibility and activity. For example, hands on or mock-up trainings can be highly effective and strongly complement computer based or classroom trainings. These types of training may involve a dynamic learning activity (DLA) and needs reflect, as closely as possible, the conditions that would be expected in the field. FMM aspects need to be incorporated into all mock-up and hand on trainings for activities in which FM controls be required, needed and used.

The delivery method can also include audio-video material, e.g. books and notes for self-reading, OPEX videos for self-viewing, as well as daily office or field-based mentor and protégé approaches to transfer tacit knowledge.

Training methods for particular activities, as applicable and required, may be specified in the FMMP administrative procedure (or they may be referred to the administrative or task specific procedures and processes of other programmes, such as the training programme, for descriptive instructions. The FMMP administrative procedure still contains the criteria, requirements and responsibilities for designation and interface) in such cases and the FMMP owner and coordinator ensure that instructions regarding the FMM training are correctly maintained in those processes and procedures.

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5.5.8.5. Timing and frequency of training

All plant/project personnel need to receive an introduction to the FMM and FMMP, immediately upon initial access to site, typically in conjunction with general employee training (GET). This course would provide the purpose and importance of FMM and FMMP and the general employee’s responsibilities relating to FM awareness and management as discussed in Section 5.5.8.2.

More in-depth, higher level, specialised training may contain one or multiple times of delivery:

— Initial task training needs to be provided to workers and managers relating to their specific areas, disciplines and assigned tasks for being qualified or permitted to perform independent work;

— Just-in-time training may be used prior to a performing a specific task or supporting a project or program, for example, FMM monitor role, outage work, component replacement or modification. This type of training could involve communication of project requirements, DLAs or practice on mock-ups;

— Continuing training is an excellent opportunity to enhance and expand workers’ FMM knowledge and awareness, particularly based on new information and knowledge, including the OPEX. The frequency of the continued training is typically set by the SAT methodology.

The following topics need to be considered for delivery during these sessions:

— Management expectation reinforcement;

— FMM programme, process or procedures changes, such as:

 Restrictions and use of particular FMC devices, e.g. internal FMC devices, lanyard/tether applications and use;

 Restriction and use of particular tools, e.g. wire wheels and brushes;

 Internal FMC devices use;

 Specialised FMC tool availability and use;

— Use of own and others’ OPEX to improve performance:

 FMM trend results and finding by CAP cause investigations;

 Lessons learned relating to encountered FM related events, close calls and near misses during an outage;

 Observation programme results;

 Industry event or trends.