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CSA N286.0.1:21 Commentary on N286-12, Management system requirements for nuclear facilities
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CSA N286.0.1:21
February 2021
Title: Commentary on N286-12, Management system requirements for nuclear facilities
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ISBN 978-1-4883-3194-7
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CSA N286.0.1:21
Commentary on N286-12, Management system requirements for
nuclear facilities
Technical Committee on Management Systems 3
CSA N286.0.1 Subcommittee 5
Drafting Task Force 6
Human Performance Task Force 7
Preface 8
0 Introduction 9
Purpose 9
Historic perspective of CSA N286 10
Context 12
Purpose of a management system 12
CSA N286 and its users 14
CSA N286 and its relation to other codes and standards 15
Reference publications 15
Key concepts 16
General 16
Using the principle approach 16
Stating the requirement once and avoiding incomplete lists 17
Reading and using the Standard as a whole 18
Directed at top management 18
Determining the requirements 18
Integration 19
Using terminology consistently 19
General 19
Worker 20
Top management 20
Business 21
Control 21
Harmonizing with current standards 21
Commentary on requirements of CSA N286 22
Applicability 22
General 22
Management system principles 23
Graded approach 23
Safety culture 24
Business planning 25
General 25
Monitoring and measuring 26
Organization 27
February 2021 © 2021 Canadian Standards Association 1
CSA N286.0.1:21
Commentary on N286-12, Management system requirements for
nuclear facilities
Resources 27
Communication 28
Information management 28
Documentation of the management system 29
Work management 29
Work planning/4.8.2 Work control 29
4.8.3 Independent verification of work 30
Problem identification and resolution 31
Change 31
Assessment 32
Self-assessment 32
Independent assessment 32
Use of experience 33
Continual improvement 34
General 34
Trend analysis 34
Assessing the effectiveness of the management system 34
Benchmarking 34
Commentary on specific requirements 35
General 35
Classification criteria [Clause 7.3.6 (c)] 35
Configuration management (Clause 7.5) 36
Verification of purchased services (Clause 7.6.7) 36
Construction (Clause 7.7) 37
Commissioning (Clause 7.8) 37
Research and development (Clause 7.11.3) 37
Counterfeit, fraudulent, and suspect items (CFSI) and other topics that arise through industry experience 38
Transportation of dangerous goods and other requirements 38
February 2021 © 2021 Canadian Standards Association 2
CSA N286.0.1:21
Commentary on N286-12, Management system requirements for
nuclear facilities
This is the third edition of CSA N286.0.1, Commentary on N286-12, Management system requirements for nuclear facilities. It supersedes the previous editions published in 2014 and 1992. This Commentary is directed only towards the requirements in the 2012 edition of CSA N286. The scope of this edition provides commentary on areas identified by users of CSA N286 which require additional clarity. This Commentary does not provide formal interpretations of CSA N286 and should be viewed only as an informative annotation of portions of CSA N286.
The purpose of this Commentary is to provide background information concerning certain clauses and requirements in CSA N286. This information can help the user clarify the context of the CSA N286 requirements.
This is a completely new edition of the Commentary and was prioritized during a condition assessment and industry scan for areas in need identified by users of CSA N286. It provides a more complete context and explanation on the structure and content of CSA N286, including both the principles and requirements, based on experience collected since the Standard was released.
This Commentary was prepared by the CSA N286.0.1 Subcommittee, with contributions from a Drafting Task Force and Human Performance Task Force, under the jurisdiction of the Technical Committee on Management Systems and the Strategic Steering Committee on Nuclear Standards, and has been formally approved by the Technical Committee.
Notes:
Use of the singular does not exclude the plural (and vice versa) when the sense allows.
Although the intended primary application of this Commentary is stated in its scope, it is important to note that it remains the responsibility of the users of the Commentary to judge its suitability for their particular purpose.
This Commentary was developed by consensus, which is defined by CSA Policy governing standardization — Code of good practice for standardization as “substantial agreement. Consensus implies much more than a simple majority, but not necessarily unanimity”. It is consistent with this definition that a member may be included in the Technical Committee list and yet not be in full agreement with all clauses of this Commentary.
This Commentary is subject to review within five years from the date of publication. Suggestions for its improvement will be referred to the appropriate committee. To submit a proposal for change, please send the following information to inquiries@csagroup.org and include “Proposal for change” in the subject line:
commentary designation (number);
relevant clause, table, and/or figure number;
wording of the proposed change; and
rationale for the change.
February 2021 © 2021 Canadian Standards Association 8
CSA N286.0.1:21
Commentary on N286-12, Management system requirements for
nuclear facilities
CSA N286.0.1:21
0 Introduction
0.1 Purpose
This Commentary was written as an aid for users that undertake implementation of a management system in keeping with the requirements of CSA N286. The Technical Subcommittee recognizes and accommodates the fact that there is a broad range of maturity of the CSA N286 user base ranging from nuclear power plants that have complied with CSA N286 Standards since the first editions of CSA N286 in 1978 to the 2012 edition, to nuclear facilities or nuclear suppliers who have partially complied through license conditions or contractual commitment but have more recently undertaken efforts to meet CSA N286, to new facilities and suppliers who are implementing a CSA N286 management system for the first time.
This Commentary is written to bridge changes in the user community that have occurred since the publication of the 2012 edition of CSA N286. Firstly, there has been a significant change in staffing at long-term existing nuclear facilities and suppliers that traditionally implemented CSA N286. This has resulted in a loss of knowledge (i.e., knowledge retention) as workers leave or retire and are replaced by new workers. Secondly, new and existing facilities and suppliers are currently going through the challenge of implementing a management system aligned with CSA N286.
This Commentary does not provide supplementary requirements or guidance (“shall” or “should”) for the implementation of CSA N286. Rather, it provides commentary on how CSA N286 evolved over time and why the 2012 edition of the Standard is structured the way it is and what it means. As such, the Commentary is not written in the style typical of a standard in that the Commentary is informative and avoids using language such as shall, should, and may that is used in standards to express provisions. The Commentary recognizes that CSA N286 is not a “one size fits all” standard like some other implementation standards. CSA N286 leaves the determination of requirements and implementation detail to the business that is using the Standard. A few points need to be considered when reading this Commentary. These are, but are not limited to, the following:
This Commentary is for a standard that was written from 2009 to 2011. The Commentary makes no attempt to update CSA N286 to reflect any new thinking or concepts that have arisen since its publication in 2012. Any updating, if required, would be the task of the committee charged with maintaining the Standard.
Throughout this Commentary, examples are used. These examples are not exhaustive, and for each example provided there are many other examples that could have equally been chosen.
This Commentary creates no new requirements or recommendations above those in CSA N286. This Commentary discusses the content of the Standard in an informative context using everyday language for added clarity.
This Commentary does not prescribe methods or techniques of implementation. It provides, in limited cases, examples of implementation to explain the Standard. These examples of implementation, if used, should not be taken as the only way that a requirement is to be met nor is it an endorsement of those particular methods and techniques of implementation.
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