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 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.
• As with the Standard, this Commentary will be misinterpreted if it is not read as a whole. The information that a reader is looking for (including valuable context) might not be in the specific section related to the topic of their interest but elsewhere.
CSA N286 is an overarching standard that prescribes a management system framework based on principles that can be used in a broad range of applications from the most basic nuclear activity to the risks and complexities of nuclear power generation. As such, the Standard identifies requirements for processes and practices that need to be in place for nuclear businesses to succeed, but avoids prescribing in detail the process and practice methodology recognizing that one size does not fit all. Rather it leaves it up to the top management of the business to determine what their business objectives, requirements, and risk profile is, and to design their management system to achieve their desired outputs within their risk profile.
A prerequisite to reading and using this Commentary is that the user read CSA N286 from cover to cover to understand it in its entirety prior to using this Commentary. This Commentary is not the Standard and cannot be used in place of the Standard. It is important to reiterate that this Commentary also reflects the reality that CSA N286 was written ten years prior to the issue of this Commentary. As such, the scope of this Commentary is bound by the scope of CSA N286 and refrains from introducing new concepts and industry developments that have evolved since the publication of CSA N286.
This Commentary sets out commentary and guidance on the following:
• describes why CSA N286 is written the way it is and provides background on its historic development, and the evolution from quality assurance to quality management to integrated management;
• establishes the context of CSA N286 within nuclear standards and other requirements-generating documents and how CSA N286 provides the overarching controls and cohesiveness;
• describes some of the key concepts that the Standard is built on and how they apply throughout its application;
• provides commentary on particular clauses and discusses the use of specific terminology such as control, top management, workers, assessment, etc.;
• provides commentary on how the Standard can be used to address or supplement activities in other requirements; and
• references other publications that provide guidance on implementation.