LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT are systematically taken into account in all decisions concerning the facility. The IMS specifies the steps taken with regard to all types of organisation and resources, in particular those adopted to manage important activities. ASNR thus asks the licensee to set up an IMS able to maintain and continuously improve safety, notably through the development of a safety culture. 3.2.7 – Taking complexity into account Implementing the safety principles described above is not in itself a sufficient condition for achieving the desired level of safety. In particular, licensees and those Responsible for Nuclear Activities (RNAs) report that their activities are becoming increasingly complex, which in certain situations can have adverse effects on safety by causing them to lose sight of requirements and increasing the risk of errors. While there are many reasons for this complexity, primarily internal to the licensees, some of them can be attributed directly or indirectly to the methods of control exercised by ASNR. Therefore, licensees and ASNR must work together to remedy the situation. The Steering Committee for Social, Organisational and Human Factors (Cofsoh) held two days of discussion on this subject in 2024, enabling participants to define a common vocabulary, analyse the different forms and dynamics of complexity and ways of dealing with it, and then illustrate these concepts through case studies in nuclear installations. A summary of these sessions was published in 2025 and Cofsoh plans to return in 2026 to the work undertaken since then on this subject. ASNR is also currently funding work, the results of which are expected in 2026, on the parameters and dynamics of complexity in the governance of reactor safety in France. ASNR is currently pursuing its ideas to help reduce complexity. On the one hand, it is reviewing its own work to avoid generating further complexity. It also intends to develop inspections designed to analyse, as close as possible to operational activities, the situations in which complexity could be reduced. In addition, ASNR is overseeing initiatives launched by licensees and activity managers, such as EDF’s work on a complete overhaul of the general operating rules for its reactors, in order to simplify them and make them easier to read and use by operators (see chapter 8, Highlight No. 4). Lastly, in 2026 ASNR will contribute to the strategic analysis entitled “Managing the simplification project” in the “FONCSI 4” programme (2023-2027). This programme aims to re-examine the relationship between safety management and its proceduralisation (formal rules, documentation, registration, reports, certification, audits, etc.). The first meeting will be devoted in particular to defining an initial line of work based on the following questions: How can we distinguish between useful formalisation and excessive bureaucratisation, which generates additional costs, irrelevant tasks and unnecessary or even harmful constraints? How can simplification be justified to external stakeholders? What impact will this simplification have on the role of safety managers? Is simplification the only way to deal with the increasing complexity of organisations? 3.2.8 – Application of safety principles in France In France, management of nuclear safety and radiation protection has been entrusted since 1 January 2025 to the Authority for Nuclear Safety and Radiation Protection (ASNR), formed from the merger of ASN (Nuclear Safety Authority) and IRSN (Institute for Radiation Protection and Nuclear Safety). This new Authority and the other regulatory bodies are presented in chapter 2 of this report. Its regulatory activities are detailed in chapter 3, and the management of radiological emergencies and post-accident situations in chapter 4. 3.3 Access to licensee information Transparency of information is a key element of safety. The main nuclear activity licensees implement a proactive public information policy. They are also subject to a number of legal obligations, either general, such as the environmental report required by the Commercial Code for joint stock companies, or specific to the nuclear sector as detailed below. The annual public information report drawn up by the BNI licensees All BNI licensees must establish an annual report concerning more specifically their situation and the steps they take with regard to the prevention of risks for public health and the environment, in accordance with Article L. 125‑15 of the Environment Code. These reports are made public and forwarded to the Local Information Committee (CLI) for the installation concerned and to the High Committee for Transparency and Information on Nuclear Safety (HCTISN – Article L. 125‑16). Access to information in the possession of the licensees The nuclear sector has a system that fosters public access to information. In application of Article L. 125-10 of the Environment Code, licensees must communicate to any person who so requests, the information they hold on the risks their activity presents for public health and the environment and on the measures taken to prevent or reduce these risks. This right to information on the risks also concerns those responsible for the transport of radioactive substances when the quantities involved exceed the thresholds set by law. The Commission for Access to Administrative Documents If a licensee refuses to communicate a document, the requesting party can refer the issue to the Commission for Access to Administrative Documents (CADA), an independent administrative Authority. CADA issues an opinion on this refusal. If this opinion is not followed, the dispute may be taken before the administrative jurisdiction which will rule on whether or not the information in question can be communicated. Communication of the requested information must in particular not jeopardise national defence secrecy, State security, public safety, research and prevention of violations of any sort by the competent services, or business secrecy, which includes the secrecy of processes, economic and financial information and commercial or industrial strategies. ASNR is particularly attentive to the application of this right to information, in compliance with the protection of interests provided for in law. ASNR Report on the state of nuclear safety and radiation protection in France in 2025 119 01 05 09 02 06 10 03 07 11 13 04 08 12 A / Z
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