- Site: Barrow
- IR number: 19-162
- Date: February 2020
- LC numbers: 26
Executive summary
Purpose of Intervention
This intervention was conducted at the BAE Systems Marine site at Barrow-in-Furness and covered both the licensed and authorised sites within the Devonshire Dock Complex. It was undertaken as part of the 2019/20 intervention plan and propulsion sub-division strategy.
This was a joint inspection with inspectors of the Defence Nuclear Safety Regulator who are responsible for the through life safety of the nuclear plant. DNSR’s findings are reported separately. ONR and DNSR invited BAESM Independent Nuclear Assurance Inspectors to join the inspection to support continued development of this important function.
Interventions Carried Out by ONR
This Intervention combined:
- Licence Condition 26 Control and Supervision of Operations.
- Health & Safety at Work etc. Act 1974 (HASAW) and relevant statutory provisions which included:
- Ionising Radiation Regulations 2017 (IRR17).
- Management of Health and Safety at Work Regulations 1999 (MHSWR).
- Lifting Operations and Lifting Equipment Regulations 1998(LOLER).
- Control of Substances Hazardous to Health Regulations 2002 (CoSHH).
- Leadership and Management for Safety (Not Rated).
The team targeted arrangements for:
- Permitting of high hazard activities e.g. confined space, hot work and lifting operations.
- Radiographic operations including a source recovery exercise.
- Setting to work and work planning and de-confliction meetings.
During the inspection we held discussions with personnel from senior management through to operational levels. We sampled relevant documentation and inspected areas primarily around the Devonshire Dock Complex and Devonshire Dock Hall, to see how the arrangements are applied at the point of work. We assessed compliance against:
- LC26 - Control and Supervision of Operations – ONR’s Technical Inspection Guides (TIG) - NS-INSP-GD-026 - Revision 5.
- IRR17 compliance - ONR’s Technical Inspection Guides (TIG) - NS-INSP-GD-054 - Revision 6.
- ‘Work with Ionising Radiation’ - Approved Code of Practice and Guidance L121.
- ‘Safe use of lifting equipment’ – Approved Code of Practice and Guidance L113 (2nd Edition).
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
There were a number of areas of relevant good practice observed including:
- Implementation of a revised structured training programme for team leaders (‘The Submarines Way’).
- The development of source recovery tools and techniques by the radiography teams; standardising contingency arrangements and minimising the time of response and therefore ensuring exposures are ALARP.
- A culture of challenge and active decision-making, and strong command and control.
A number of opportunities for improvement were identified during the inspection and have been recorded as regulatory observations and shared with the licensee. The main observation was:
- We noted that the nuclear baseline (and supporting competence-recording system for operational staff) identified a wider community of staff controlling and supervising work that may affect safety. For example the team leaders in Health Physics and Chemistry, Safety Cases etc. The expectation is for the duty holder to review the nuclear baseline and include the supervision competencies of ‘the submarines way’ training programme.
In response to this observation a single Level 4 Regulatory Issue is raised for the licensee:
- BAESM to review the totality of the supervisory community (i.e. those in and supporting the nuclear baseline) and identify, explicitly, the expectations and requirements placed on these supervisors (e.g. expectation to complete the ‘submarines way’ training programme; supervision competences). I set a review date for this issue at 1 May 20 and closure at 1 August 20, as I judge this issue should be managed concurrently with 7849. This will ensure the management and supervisory community have been trained in the duty holder’s expectations for management and supervision.
A number of minor shortfalls were identified e.g. the control of information in relation to ‘plan of the day’ meetings and occupational health and hygiene assessments, and opportunities being missed for learning post job.
The shortfalls observed during ‘plan of the day’ meetings included a lack of transparency related to amendment/removal/addition of planned tasks; making de-confliction of tasks difficult and reducing the duty holders’ ability to trace back if required. We did observe good examples of challenge during the meetings, but this was not consistent.
Current occupational health assessments take a ‘broad-brush’ approach, which is not necessarily tailored to the individual’s role or exposure profile. Radiation workers are subject to hand arm vibration (HAV) questions, although there are no HAV exposures in this population. BAESM is currently reviewing their occupational health assessment processes with their contract occupational health service, and this is an area where resource could be more focused.
There was little or no evidence of any reflection analysis post job to capture learning. This was particularly apparent with respect to lifts and lifting operations. BAESM should apply the principles of review, learn and improve to obtain learning at the end of work packages/tasks.
ONR maintains oversight of improvements through the site improvement plan. ONR Regulatory Issues will be updated to reflect the findings from this inspection, and a new level 4 issue will be created as described earlier.
Conclusion of Intervention
Based on the sampling undertaken during the intervention I am satisfied that in general the licensee has in place adequate arrangements under Licence Condition 26 Control and Supervision of Operations, The Health & Safety at Work etc., Act 1974 and Relevant Statutory Provisions including IRR17. I therefore assign a rating of Green (no formal action) to this intervention.