Guidance

Management and leadership for the environment: generic developed principles

Updated 2 May 2024

Applies to England

We consider that management systems and the leadership shown by senior management have key roles in ensuring business and other users use radioactive substances in a way which fully protects people and the environment.

In this document we describe how we expect an operator to manage its business and provide that leadership to ensure that the business minimises its impact on people and the environment from the use of radioactive substances.

This document covers matters such as the structure of an organisation and how:

• it trains and manages staff
• the senior management provide leadership and direction
• they assess the environmental performance of the business

These management and leadership developed principles (MLDPs) are based largely on national and international guidance on management and leadership for the safety of nuclear facilities.

Although the principles apply to all the organisations that we regulate as radioactive substances activities, the extent to which the detailed considerations apply depends very much on the scale of their use of radioactive substances and the management of radioactive wastes (or both) and the associated risks.

All the considerations are likely to be relevant at large organisations where the management of radioactive substances and radioactive wastes is a major part of their activities.

At organisations where only a few people are involved in the management of radioactive substances and radioactive wastes a much simpler approach will often suffice, providing it achieves compliance with the principles.

MLDP1 – establishing and sustaining management and leadership

All organisations whose activities might adversely affect people or the environment should establish and sustain effective leadership and management for the environment to ensure that people and the environment are properly protected from adverse effects.

Considerations

Prime responsibility for environment protection always falls to the organisation or person responsible f or the activities that could give rise to adverse effects. Others (organisations or people) who contribute to or might affect an organisation’s environment protection performance should be made aware of their responsibilities.

Effective management for the environment includes:

• leadership
• capability
• decision making
• learning

MLDP 2 – high standards of environment protection

Directors, managers and leaders at all levels should focus the organisation on achieving and sustaining high standards of protection of people and the environment.

Considerations

Focusing the organisation includes:

• establishing strategies, policies, plans, systems, goals and standards for protection of people and the environment
• ensuring that these are delivered throughout the organisation
• providing direction and oversight that encourages a strong environment protection culture to underpin operation
• visibly demonstrating commitment to environment protection through their activities
• recognising and resolving conflict between environment protection and other goals
• ensuring that any reward systems promote environment protection
• endorsing behaviour that protects people and the environment
• challenging behaviour that threatens people or the environment
• reinforcing the value of environment protection in interactions with staff, contractors, suppliers, stakeholders and the public
• engaging staff at all levels through proper consultation and involvement to secure collective responsibility, personal accountability, shared values and improvement of environment protection
• providing training in environment protection goals and methods
• supporting oversight of environment protection, led by the management board
• securing an effective, preferably integrated, management system throughout the organisation

In general, formal accreditation of management systems should be achieved. An appropriately certified environmental management system will be most effective if it is a component of an integrated management system.

MLDP3 – capability

Organisations should have the capability to secure and maintain proper protection of people and the environment.

Considerations

Capability includes:

• having sufficient human resources with regard to numbers, skills, competencies and knowledge at all times
• having effective processes for assessing, monitoring and maintaining the sufficiency of human resources
• having effective processes for assessing all organisational changes, planned and unplanned, that might affect environment protection
• having effective processes to secure and maintain the technical, behavioural, managerial, and leadership competencies of all individuals whose performance might affect environment protection
• ensuring that all of the individuals who have responsibilities for environment protection have sufficient personal authority, including access to resources, to deliver those responsibilities effectively
• having an organisational structure and management system (preferably integrated) that secures effective co-ordination and collaboration by all those directly and indirectly involved in the organisation’s activities that might affect environment protection
• taking account of factors that affect the reliable performance of organisations when designing organisational structures, jobs, processes and procedures that might affect environment protection
• having clear roles, responsibilities, accountabilities, objectives, expectations and performance standards for environmental protection
• having effective supervision and oversight of all activities and individuals that might affect the environment
• having effective processes for capturing, assessing, interpreting, understanding and communicating plant, system, equipment and process performance and environmental information so that faults, problems and issues that might have adverse effects on the environment are identified early
• these processes include having expertise and knowledge of expected and unexpected performance and consequences and arrangements for ensuring that this capability is maintained throughout all stages of facility lifecycle
• having effective processes for knowledge management such that sufficient relevant information is available to those who make decisions that might affect environment protection – including matters relating to how information is structured and communicated as well as its content
• having effective processes for managing (including identifying, updating, validating, approving, preserving and making available) records and documents that are relevant to environment protection

Capability also includes securing and maintaining within the organisation sufficient knowledge and competence about matters relating to environment protection such that:

• it understands what proper protection of people and the environment requires and it remains in control of achieving this
• its ability to do so is not compromised when it uses contractors or others to carry out work or other related activities on its behalf because it maintains itself as an ‘intelligent customer’

MLDP4 – decision making

Decisions at all levels that might affect environment protection should be rational, objective, timely, transparent and prudent.

Considerations

Effective decision making processes should be used for all decisions that might affect the environment. This includes:

• ensuring a high priority is given to environment protection and is evident in all decisions that might affect the environment
• ensuring that an integrated approach is taken, all relevant matters are taken into account and priorities properly assigned, in decisions where there is conflict or potential conflict between environment protection and any other goals of the organisation (for example, relating to health, safety, security, quality, economic and commercial matters)
• ensuring that relevant information, including data and opinion, is sought, considered and used to inform decisions that might affect the environment
• evaluating the quality of data and opinions
• questioning assumptions
• exploring all relevant scenarios of expected and unexpected behaviours and consequences that might affect the environment
• considering short and long term implications of decisions
• allowing for error, uncertainty and the unexpected and demonstrating a prudent approach
• inviting effective active challenge and review of decisions, made at all levels of the organisation, that might affect environment protection

MLDP5 – learning from experience

Organisations should learn from their own and others’ experience so as to continually improve their ability to protect the environment.

Considerations:

The organisation’s ability to protect the environment includes leadership, capability and decision making.

Organisations should establish effective processes for learning should be established and sustained by organisations whose activities might adversely affect people and the environment.

Effective processes include active arrangements for gaining, assessing and acting upon information from all relevant sources. Sources of information include:

• staff at all levels (for example, from observations, near misses, suggestions, deviation and non-conformance reports) and trade unions
• monitoring, review and audit activities relating to strategies, plans, goals, standards, processes, procedures, plant and systems, testing and validation procedures, environmental monitoring, inspections and investigations, non-conformances, incidents and events, and self and external assessments
• reviews by external organisations of such matters, including publication of new standards
• performance benchmarking with other relevant organisations is available to those who make decisions that might affect environment protection
• these processes include matters relating to how information is structured and communicated as well as its content and,
• tracking corrective actions arising from learning to ensure that these are implemented and assessing their effectiveness