Nuclear supply chain fraud
Nuclear supply chain fraud: The elephant in the room Lloyd’s Register 19 June 18, Our head of nuclear inspection discusses the fact topic few people want to acknowledge about CFSI in the nuclear industry.Simon Emeny
Our voice on nuclear regulatory and supply chain assurance
The subject of counterfeit, fraudulent and suspect items (CFSI from here on in) is a big topic in the nuclear industry in light of some high profile incidents in the past few years. Civil nuclear plant owners and operators mostly focus on detection to fight this; enhanced levels of inspection, supply chain audits, and repeat inspections are among their weapons.
These additional measures are implemented to prevent CFSI from happening again, and deep investigations and analyses are undertaken to find root causes.
A recent review at a long-time manufacturer of high integrity forgings found, among other items:
The ISO 9001 and ASME management systems may detract from a comprehensive management system, through focussing on compliance issues rather than a system for the management of regulatory and other aspects related to the production application.
There is a risk that the cumulative effect of a series of “minor” changes are considered acceptable without requalification, since revisions to qualification documents were not reviewed against original specifications and qualifications.
The metallurgical aspects of the process are well understood, but it is not clear if they are documented in a way that can be applied by those operating the processes and carrying out tests…………
An old management adage goes, “Culture eats strategy for breakfast.” In the world of nuclear supply chains, you could say, “Culture eats fraud detection systems for dinner.”
This could mean there is a culture of deliberate falsification. A culture of not caring. A culture of concentrating on cost or delivery without considering the wider, unintended consequences. A culture of assumption, or unconscious incompetence.
Bold statements? Yes, and certainly they don’t apply broadly across the industry. However, they should provoke thought and reflection, especially as the risk of CFSI increases as nuclear supply chains lengthen, become more diverse, and we move toward using standard items in facilities………https://www.lr.org/en/insights/articles/nuclear-supply-chain-fraud-the-elephant-in-the-room/
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