Note of clarification regarding ONR's vires in defence
Updated 4 October 2024
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1. This note is to provide further explanation of the ONR’s vires in defence, with reference to relevant paragraphs/footnotes from the PIR reports.
2. Full Report (33) and Summary Report (7) – To note that the Reports state that ONR’s regulatory work “has been directed towards maintaining the existing fleet of operating nuclear reactors, fuel cycle facilities, decommissioning, and the safe handling and storage of hazardous waste materials at licensed civil and authorised defence sites”. However, this is only true of licensed civil sites. As referenced in Full Report Footnote 3, on authorised defence sites, ONR regulate the Health and Safety at Work Act 1974, including Radiation (Emergency Preparedness and Public Information) Regulations 2019 and Ionising Radiation Regulations 2017. References throughout to ONR’s work at authorised defence sites should be interpreted with this in mind.
3. Full Report (36) – To note that the Report states that ONR has “five sets of purposes”. It should be clarified that these are their purposes for the civil sector. ONR do not regulate nuclear security, nuclear safeguards or the transport of radioactive materials for defence purposes. These are covered instead by defence regulators. ONR also do not regulate nuclear safety at authorised defence sites; this is regulated by the Defence Nuclear Safety Regulator. References throughout to ONR’s five purposes should be interpreted with this in mind.
4. Full Report (41) – To note that the Report states that “ONR’s safeguards purposes were expanded, with ONR becoming the UK’s nuclear safeguards regulator”. As above, this statement only applies to civil nuclear sites and not defence sites. References throughout to ONR’s safeguards purposes should be interpreted with this in mind.
5. Full Report (Footnote 99) - To note that the Report referenced ONR minutes of the Board from 2019 to provide “details of what the vires review included.” It should be clarified that the joint review was undertaken sometime later in 2020 - 2021, with the scope having been developed and refined during the intervening period.