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Hartlepool - Conventional Health and Safety inspection

  • Site: Hartlepool
  • IR number: 19-058
  • Date: August 2019
  • LC numbers: N/A

Executive summary

Purpose of Intervention

To provide regulatory confidence in the management of conventional health and Safety (CHS) hazards present during the Hartlepool (HRA) statutory outage, with focus on the management the risk presented by Work at Height activities. This is in line with the inspection programme contained in ONR’s Operational Facilities Division intervention strategy 2019-20.

The ONR CHS strategy has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Work at Height Risk is a priority topic in the strategy. Due to a rise in Work at Height and Dropped Objects incidents across EDF Nuclear Generation Limited (NGL) Sites in 2018-19, the Conventional Health and Safety team committed to conducting a Work at Height Intervention at EDF NGL Sites in 2019-20. This intervention uses the principles within HSE publication ‘Managing for Health and Safety (HSG65)’ and health and safety audit techniques to assess how well NGL are managing the risks presented by Work at Height and Dropped Objects.

Interventions Carried Out by ONR

The key regulatory activities undertaken involved two CHS specialism inspectors during the two-part intervention, the aims of which were:

  • To provide regulatory confidence in the management of conventional health and safety hazards at Hartlepool, with a focus on Work at Height Issues.
  • To interview a range of staff and contractors conducting, arranging, managing and overseeing Work at Height.
  • To inspect the management of Work at Height activities during the statutory outage and test the perception of risk management gained from the staff interviews. 
  • Site familiarisation for Conventional Health & Safety Inspectors new to site.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

Key Findings, Inspector's Opinions and Reasons for Judgements Made

1st inspection 22nd-24th May 2019 – In the feedback session on this interview section of the intervention provided to the Site Director and the Industrial Safety Team, ONR Inspectors reported that they had found some issues with Workplace Transport and Guarding that would be followed up the on the next inspection. The interviews had provided ONR with the impression of a positive safety culture on site, particularly regarding the management of Work at Height risks and given inspectors some useful assumptions to test at the next visit to site.

2nd inspection 14th-16th August 2019 - Some of examples of good standards were seen during the visit, however there are a number of areas where significant issues were found and improvements are required. These were summarised during feedback provided at the conclusion of the visit to the Site Director and the Industrial Safety Team, as were the visit outcomes/actions required by NGL. The significant issues found are as follows:

  • ONR Inspectors observed several examples of workers working unsafely at height during the inspection, which in the inspector’s opinion, was in breach of Regulation 6(3) of the Work at Height Regulations 2005 – these issues were addressed by NGL Industrial Safety Engineers (ISE) at source. ONR asked EDF NGL to take action to improve the monitoring of Work at Height, especially during the busy outage period.
  • ONR Inspectors observed several areas of site where pedestrians and vehicles could not circulate in a safe manner, which in the inspector’s opinion, was in breach of the Workplace (Health, Safety and Welfare) Regulations 1992, Regulation 17. This was especially apparent the busy corner next to the fire station where both pedestrians and vehicles (including large trucks) were filtered into one single lane of road - these issues were addressed by NGL ISEs at source. This risk is more apparent given the increased number of workers and vehicles during the outage period and ONR requested that EDF NGL take action to identify current and forthcoming danger areas on site put controls in place to ensure segregation between pedestrians and vehicles.
  • ONR Inspectors found several examples where guarding of rotating parts of fixed machinery was inadequate, which in the inspector’s opinion was, in breach of the Provision and Use of Work Equipment Regulations 1998, Regulation 11. The most concerning examples were observed in the CW Pump House, where there are large gaps in the guarding on the pumps. ONR r confirmed the following day that EDF NGL had taken temporary measures (signage and temporary covers)  to improve the guarding on the plant identified until engineering solutions could be implemented. ONR also requested that NGL survey remaining similar plant on site and then make permanent fixes to guarding where required to prevent access.

Conclusion of Intervention

1st inspection 22nd-24th May 2019 (Onsite interviews) - An inspection rating of ‘Green – acceptable’ should be applied the first part of this intervention.

2nd inspection 14th-16th August 2019 (Outage inspection) - the issues found mean that an inspection rating of ‘Amber – below standard’ should be applied to the second part of this intervention, on the basis that specific legal requirements were not met, but without prejudice to overall nuclear safety or security objectives.

One Level 3 Regulatory Issue (related to machinery guarding breaches) and two Level 4 Regulatory Issues (related to Work at Height and Workplace Transport breaches) will be added to the ONR Regulatory database in order to monitor the required improvements. These will be subject to ONR’s governance processes. An email has been sent to the ISEs and Technical & Safety Support Manager at Hartlepool confirming the actions required and establishing whether timescales are reasonable to complete the actions.