Is it acceptable to audit to the Nuclear Principles?

[Mnts2C]

Hello everyone,

I'm part of an auditing division at a naval shipyard. Quality is roughly split into nuclear efforts and nonnuclear efforts (I'm in the nonnuc arena). I'm trying to improve quality for the whole shipyard, ~12,000 people.

At a high level, the nonnucs are doing adequately with compliance auditing while beginning to use process auditing. The nuc oversight team has been struggling for <insert reasons>. With that aside, it appears the nucs are trying to reinvigorate their program by auditing to nuclear principles (listed below).

The nucs may document several NCs in an area but want to raise the report severity level by pointing to the one of principles.

I'm curious as to what you Covers might have experienced in a similar situation where oversight leaves the area of compliance and process, and tries to perform oversight to principles.

Nuclear Principles
1. Responsibility is a unique concept
2. Conservatism in design and operation
3. Strong central technical control
4. Verbatim compliance with approved technical procedures
5. Not “living with” deficiencies
6. Formal documentation and communication
7. Selection, training, and qualification of the best people, dedicated to excellence
8. Thorough involvement and review by senior personnel
9. No management system can substitute for hard work
10. Frequent, thorough, and detailed inspections and audits
11. Enforcement of standards
12. The devil is in the details
13. Face facts brutally
14. If you can’t write it down, you can’t understand it
15. Completed staff work

Thanks in advance !!

 

[AndyN]

Re: Auditing to Principles ...

Good luck with that! "Principles" like this are full of "interpretation" and not solid requirements. Trying to audit to a bunch of esoteric criteria is going to end in a fist fight with someone. If you're serious about improving things, don't touch this...:mg:

 

[dsanabria]

Re: Auditing to Principles ...

@Mnts2C

In your statement it appears that you are auditing to your process and make a oversight leaves the area of compliance and process, and tries to perform oversight to principles.

Can you provide an example of you thoughts so that we could follow it clearly?

 

[Mnts2C]

Re: Is it acceptable to audit to the Nuclear Principles ?

Dsanabria,

As a nonnuc, I perform compliance and process auditing. Nonconformances are given a severity level that the organization is accustomed to. Occasionally multiple NCs might be upgraded to a higher severity level if there are systemic NCs, the process is not being managed, or safety is at risk. So, my NCs are based on approved requirements not being met.

The other auditing group (nucs) are attempting to redirect their efforts from compliance auditing to principle-based auditing. To me, this appears to be subjective. If the nuc auditor notes some NCs for ‘i’s not dotted or ‘t’s not crossed, they will write another finding, justifying a higher severity level because it doesn’t meet one of the ‘principles’.
Ex: shoe laced untied, shoe lace untied, and here is your NC with a low severity level. And here is your NC with a higher severity level for violating principle #5 (living with deficiencies).

Hope this helps.

 

[dsanabria]

Re: Is it acceptable to audit to the Nuclear Principles ?

Got the picture - thanks!

If this is going on, time for upper management to identify what would be the best way to go... but if you are at the lowest pevel, unless you have another opportunity to transfer, there is a hard and tought chance for you to change the culture.

If you choose to stay and fight it, we could give you opinion as to how to go about it but...

 

[Mnts2C]

Re: Is it acceptable to audit to the Nuclear Principles ?

I agree with you Andy. Now the challenge becomes how to educate and redirect their focus while attempting to create alignment between the two camps.

Appreciate the feedback.

Mnts2C

 

[AndyN]

There's no reason why these principles couldn't be mapped to a management system requirement, in the same way as the 8 QM principles in ISO 9004 were. Maybe doing that and then auditing the QMS would bring a greater understanding of requirements, a systematic approach to effectiveness and less subjectivity?

 

[John Broomfield]

Mnts2C,

As auditors you use criteria (requirements) as necessary to fulfill the objectives of the audit.

These criteria are approved by the audit client and seen as legitimate by the auditee. They are not established or imposed by the auditor.

If you want to use these criteria then recommend them for the approval of the entity that is paying for your audit.

And make sure these criteria are not a complete surprise to the auditee's management.

Then you are good to go with including these principles in your audit planning, investigation, evaluation and reporting.

John

 

[Steve Prevette]

The nuclear principles stated do come from the nuclear industry, which is trying to tackle cultural issues. See also http://www.nrc.gov/about-nrc/regulatory/enforcement/INPO_PrinciplesSafetyCulture.pdf

Also well worth going back and reviewing Admiral Rickover's principles.

So, yes these are a bit squishy, but do have some reasonable thought behind them. Having been ships force for two shipyard overhauls, and having watched a main hull isolation valve repeatedly fail its shipyard tests (in fairness - the manufacturer had gone out of business years ago and the shipyard was trying to repair the seat of the valve) I would prefer to see nuclear standards through out. Or at least sub-safe.

Do you have to follow NQA-1 in the yards?

I do currently work at a DOE nuclear site in a Fluor / Newport News Shipbuilding / Honeywell consortium, so I may be able to offer some insight.

 

[Mnts2C]

I had a lengthy reply written to all but somehow messed it up.

So here's an attempted short rewrite:

AndyN: 9004 Annex B was helpful, thanks.

JohnB: Understand all provided the principles are communicated early.

SteveP: Local docs do not reference NQA-1. Familiar with Rickover.


While I do understand the merits of principles and they do have their place in the manager's toolbox, I feel their subjectivity is not well suited to support a nonconformance audit finding. How can the auditee satisfactorily address a subjective issue? Hence AndyN's initial reply.

Currently what I could support is several NCs that share a relationship to a principle or two. The NCs are audit findings and must follow the CAPA process. The offending principle would be part of the audit report summary that 'needs improvement'. This allows auditee management to improve their principle mojo and can allow the audit body to follow-up as desired.

Thanks to all for your feedback with this issue.

R/ Mnts2C