The obscure definition of Control in UK Cabinet Office parlance

My understanding of the history of emergency planning in the UK nuclear industry was that we adopted the management tool we call “Command and Control” after the Piper Alpha accident. In that disaster a fatal fire on a North Sea rig was prolonged while the responders sought somebody with authority to stop pumps feeding the fire with gas from neighbouring fields.

Following this lesson we ensured that our emergency arrangements unambiguously identified one role on site who would have unquestioned authority over all resources and actions on site after an emergency had been declared and another who would have similar unquestioned authority over the rest of the Company in support of the emergency response. We then gave people in these roles suitable training and a letter of authorisation promising them the full retrospective support of the Management Board for any actions they initiate when in post in response to an emergency.

An important set of components of the emergency scheme ensured that the person in this role was as fully aware of the changing situation as could be achieved and provided with the full range of technical advice that might be needed (situational awareness) and that their instructions (in terms of strategic foci) were converted to actions (orders) and every effort was made to complete the actions and report back in the time allotted. In this way the crisis is managed.

For many years I’ve worked with the Cabinet Office definitions of Command and Control.

I’ve just been reading the output of a New Zealand ministerial review Better Responses to Natural Disasters and Other Emergencies in New Zealand and I was struck by the completeness and clarity of their definitions of command and control:

  • Command (authority within an agency) is executed vertically, and includes the internal ownership, administrative responsibility, and detailed supervision of an agency’s personnel, tasks, and resources. Command cannot normally be exercised outside an agency.
  • Control (authority across agencies) is executed horizontally, and is the authority to direct tasks to another agency, and to coordinate that agency’s actions so they are integrated with the wider response. Control authority is established in legislation or in an emergency plan. This is control to task a certain agency towards a certain outcome (achieve a managed evacuation for example). It is not control over the actual resource – personnel and vehicles.
  • Coordination: bringing together agencies and resources to ensure unified, consistent, and effective response. 

    Command and control assists with coordination by defining authority between and within agencies.

These definitions can be compared to the UK Cabinet Office definitions as given in Cabinet Office Glossary

  • Command and control – The exercise of vested authority through means of communications and the management of available assets and capabilities, in order to achieve defined objectives.

Note: Command and Control are not synonymous terms – see the separate glossary entries.

  • Command – The exercise of vested authority that is associated with a role or rank within an organisation, to give direction in order to achieve defined objectives.
  • Control – The application of authority, combined with the capability to manage resources, in order to achieve defined objectives.

Further research quickly yielded the US and UK Department of Defence definitions

US Department of Defence, Dictionary of Military and Associated Terms

  • Command and control — The exercise of authority and direction by a properly designated commander over assigned and attached forces in the accomplishment of the mission.
  • Command — The authority that a commander in the armed forces lawfully exercises over subordinates by virtue of rank or assignment.
  • Control — Authority that may be less than full command exercised by a commander over part of the activities of subordinate or other organizations.

MoD, Joint Concept Note 2/17 Future of Command and Control

  • Command – The authority vested in an individual of the armed forces for the direction, coordination, and control of military forces.
  • Control – The authority exercised by a commander over part of the activities of subordinate organisations, or other organisations not normally under his command, that encompasses the responsibility for implementing orders or directives.

UK doctrine for civilian multi-agency working is based on co-operation of the Emergency Services rather than the control of all relevant resources by a Commander from a selected service (see Emergency Response and Recovery Non statutory guidance accompanying the Civil Contingencies Act 2004). This is consistent through the JESIP programme and the development of the Joint Decision Model.

I get the impression that historically our definitions of Command and Control may have been fudged so that it could be claimed that the concept is at the heart of multiagency response when, in fact, it clearly isn’t. We exercise Command and Control (or at least Command) within our own company or service structures and coordination between companies and services. Generally it seems to work in emergencies. If that is accepted then we don’t need to mangle the definition of control and “The application of authority, combined with the capability to manage resources, in order to achieve defined objectives” can be replaced with something clearer. If we feel that command and control across all the responders is more likely to achieve success than coordination (I’m certainly not in a position to judge this) then we should move in that direction. Either way better definitions of these key terms would be helpful.

IAEA Publication: Knowledge Loss Risk Management in Nuclear Organisations

 

BEIS has issued a Ministerial Statement to both houses of Parliament (Commons and Lords) with regard to policy in the light of leaving euratom. It proposes a twofold approach of (1) “negotiations with the European Commission to seek a close association with Euratom and to include Euratom in any implementation period negotiated as part of our wider exit discussions”; and (2) “to put in place all the necessary measures to ensure that the UK could operate as an independent and responsible nuclear state from day one.

IAEA Risk cover

It might do well to read a recent publication from IAEA Knowledge Loss Risk Management in Nuclear Organisations. This sees challenges resulting from an aging workforce, an industry that runs plant for several decades with different skill sets being required for design, build, operate and decommission stages leading to changing workforce and management. The long duration of nuclear projects also results in issues of technology obsolescence and the need for the introduction of new skills such as cyber security. In the UK we can add the risks posed by the free market “policy” that is resulting in a series of very different prototypes being built or proposed.

This is an issue that should concern BEIS because, of course, the average tenure of a civil servant in a particular influential post is very short compared to the nuclear project duration. They need to ensure that they maintain the knowledge, skills and systems to understand what the NDA, operators, ONR, the environment agencies have been tasked to do and how well or badly they are doing it.

The IAEA document seeks to increase awareness among nuclear organisation managers of the need for a strategic approach and actions plans to identify and manage the risks of individual and organisational knowledge loss.

The IAEA projections show the number of nuclear reactors operating in the world rising, with most of the growth in countries that already have a nuclear industry. Within this picture reactors are retiring and will take experienced resource to decommission them. An even greater cause of need for new recruits is expected to be the loss of skilled and experienced workers to retirement, internal transfer or promotion, or resignation. One scenario for the USA shows 19,000 new positions and 63,000 new hires by 2030.

The IAEA propose a Strategic Workforce Planning system that is composed of a cycle of Workforce Analytics, Workforce development, Execution and Metrics and Business Unit Planning.

They call for a “Coherent intervention by governments, industry, universities and R&D organisations” to provide a feed line of skilled and competent workers.

In the UK the NDA fund R&D in the area of nuclear decommissioning to meet its obligations under the Energy Act “to promote and, where necessary, carry out research in relation to its primary function of decommissioning” and “to ensure that there is a skilled workforce available to undertake the work of decommissioning” (NDA University and Research Strategy). Various universities offer nuclear power material to undergraduates and postgraduates (For example: Manchester, Bristol, Leeds, and Cambridge). These have different levels of direct links to the industry and it is not entirely clear that the situation can be called a “strategy” or described as “coherent” but it does (presumably) provide a feed of skilled (but not experienced) youngsters for the industry.

IAEA_Process

Figure 1 Knowledge devlopment from IAEA NG-T-6.11

Figure 1 shows the IAEA view of the relationship between workforce planning and knowledge management. Those new to the industry are likely to spend some working, learning and training before becoming independent competent workers and then some further time before achieving recognition as an expert in their field. The art of knowledge transfer management is to ensure that, where an expert leaves for any reason while their skills are still needed, a suitable replacement is ready to take the post.

On the industry side, workforce planning is required Site Licence Conditions 12 and 36 (below). This leads to systems which identify key skills, suitably qualified and experienced personnel and succession management.

 

Licence Condition 12:

Duly authorised and other suitably qualified and experienced persons

1 The licensee shall make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.

2 The aforesaid arrangements shall also provide for the appointment, in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety.

3 The licensee shall submit to ONR for approval such part or parts of the aforesaid arrangements as ONR may specify.

4 The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless ONR has approved such alteration or amendment.

5 The licensee shall ensure that no person continues to act as a duly authorised person if, in the opinion of ONR, he is unfit to act in that capacity and ONR has notified the licensee to that effect.

 

 

Licence Condition 36:

Organisational capability

1 The licensee shall provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site.

2 Without prejudice to the requirements of paragraph 1, the licensee shall make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety.

3 The licensee shall submit to ONR for approval such part or parts of the aforesaid arrangements as ONR may specify.

4 The licensee shall ensure that once approved no alteration or amendment is made to the approved arrangements unless ONR has approved such alteration or amendment.

5 The aforesaid arrangements shall provide for the classification of changes to the organisational structure or resources according to their safety significance. The arrangements shall include a requirement for the provision of adequate documentation to justify the safety of any proposed change and shall where appropriate provide for the submission of such documentation to ONR.

6 The licensee shall if so directed by ONR halt the change to its organisational structure or resources and the licensee shall not recommence such change without the consent of ONR.

The IAEA recommend a knowledge management team and define a list of participating roles and stakeholders for a typical nuclear power plant and the team’s main functions. It then outlines an Organisational Competence Loss Risk Assessment methodology. Among other tools this suggest a risk matrix which lists the skills requirements in each area and maps who, within the organisation, has those skills. This leads to the identification of those areas at risk of knowledge loss and the development of an Action Plan to restore the situation.

Another tool assesses the skills and knowledge of any employee nearing retirement, promotion or otherwise likely to leave their current post and initiates an Action Plan if appropriate.

The remainder of the document provides tools, forms, guidance and case studies.

 

REPPIR 2018 delayed?

The SRP tell me that “BEIS has advised that it is its intention to publish the Government response to the REPPIR consultation and the draft REPPIR regulations in late Spring 2018 with a view to laying the regulations before Parliament in Autumn 2018”.

I thought that the new regulations had to be in place in February of this year but didn’t think they were anywhere near enough to completion.

I can’t yet find a BEIS press release on the subject.