The management of counterfeit, fraudulent, and suspect items (CFSI) in the nuclear industry is a requirement of license holder and supplier quality management systems in most jurisdictions. These requirements can be found in standards like ISO 19443:2018 and the CSA N299 series, national regulation in some countries includes provisions related to CFSI management and avoidance.
The dangers of CFSI in the nuclear energy industry are significant and can have severe consequences for the safety and reliability of nuclear power plants. CFSI may not meet the required specifications and standards for use in nuclear power plants. This can result in equipment failures, malfunctions, or other safety-related incidents that can cause damage to the plant or harm to personnel.
CFSI may not have undergone the required testing and inspection procedures to verify their quality and authenticity. This can lead to equipment and materials being installed in the plant that are defective or substandard, and may not be able to perform their intended functions, which can again result in equipment failures and malfunctions. The use of CFSI can have legal and financial implications for nuclear power plants and suppliers, as well as impact public trust and confidence in the industry. In the event of a safety-related incident, the use of CFSI can result in costly legal and financial penalties, damage to the reputation of the plant and the industry, and loss of public trust and confidence.
Nuclear power plants and suppliers to the nuclear industry manage the threat of CFSI by implementing various measures to ensure the safety and reliability of their operations. The combating of CFSI in the nuclear power industry requires a comprehensive defense-in-depth approach. This approach involves multiple layers of protection to minimize the risk of CFSI entering into the nuclear power plant.
At the outer layer, procurement managers play a critical role in screening all procurement's for risks. This involves verifying the authenticity and traceability of the items and ensuring that they come from reputable and trusted suppliers. Procurement managers should also conduct due diligence on suppliers and perform risk assessments to identify any potential risks related to the supply chain.
The next layer in the defense-in-depth approach is the quality assurance team, which is responsible for inspecting and verifying the quality of the items before they are installed in the plant. This includes checking for any signs of counterfeiting or fraudulent activities and ensuring that the items meet the required specifications and standards.
The receiving inspection at the warehouse is another critical layer in the defense-in-depth approach to combating CFSI in the nuclear power industry. This layer involves inspecting the items upon their arrival at the warehouse from the supplier and verifying that they are genuine and meet the required specifications and standards.
During the receiving inspection, the items are visually inspected for signs of damage, defects, or any inconsistencies with the purchase order. Any discrepancies are reported to the procurement team. In addition, the items may be subjected to various tests and inspections to verify their authenticity and quality.
The final layer is the maintenance personnel who work with installed structures, systems, and components (SSCs) in the plant. They play a critical role in detecting any issues related to CFSI and reporting them to the appropriate authorities. Maintenance personnel should be trained to recognize the signs of CFSI and be equipped with the necessary tools and procedures to deal with them.
Overall, the defense-in-depth approach to combating CFSI in the nuclear power industry involves a combination of measures at different layers to minimize the risk of CFSI entering into the plant. This includes implementing strict procurement processes, conducting thorough inspections and quality checks, and ensuring that maintenance personnel are well-trained and equipped to detect and report any suspicious activities.
Nuclear regulatory bodies play an important role in combating counterfeit, fraudulent, and suspect items (CFSI) in the nuclear industry. These bodies are responsible for ensuring that nuclear facilities and their components are safe and reliable, and that they meet the necessary regulatory requirements.
To combat CFSI, nuclear regulatory bodies implement strict regulations and standards for the procurement, manufacture, and installation of nuclear components. They also require that nuclear facility operators establish robust quality assurance programs that include measures to prevent the introduction of CFSI into their supply chain.
The OECD Nuclear Energy Agency Vendor Inspection Cooperation Working Group (VICWG) has published a Common Position on the Risks of Counterfeit, Fradulent, and Suspect Items. The position paper can be downloaded here. The position paper notes that:
The international nuclear community has identified examples of documentation falsification and misrepresentation of materials in nuclear power plants, found not only within vendors’ but also the licensees’ organizations. This type of systemic, quality issue affects a broad spectrum of users and suppliers in the nuclear field, particularly when the falsification has been ongoing and undetected for many years. Evidence of these recent events prompts a review of regulatory oversight and quality assurance practices of our international community.
In addition to these regulatory measures, nuclear regulatory bodies also work closely with industry stakeholders, such as equipment manufacturers, suppliers, and contractors, to raise awareness of the risks associated with CFSI and to promote best practices for mitigating these risks. This may include conducting training and outreach programs to educate stakeholders on how to identify and report CFSI, as well as collaborating with law enforcement agencies to investigate and prosecute cases of CFSI.
Apollo+ supports owner/operators and suppliers to understand the requirements related to CFSI management and helps organizations to implement best practices in this area. Contact us at info@apolloplus.com
