- Site: Devonport
- IR number: 19-189
- Date: February 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
The purpose of this ONR intervention was to undertake a planned inspection at Devonport Royal Dockyard Ltd (DRDL) Offices, Plymouth, in accordance with ONR’s Intervention Plan for the regulation of DRDL 2019/20.
Interventions Carried Out by ONR
The objective of the intervention was to observe the DRDL Board, examine DRDL’s Board arrangements, conduct structured interviews with selected Executive and Non-Executive Directors and assess the application of relevant good practice.
ONR utilised the following guidance and Relevant Good Practice (RGP) during this inspection: Licensing Nuclear Installations, ONR, 4th Edition, Jan. 2015; Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the provision of Nuclear Safety Advice, NS-TAST-GD-080 Rev 3; Safety Assessment Principles (SAPs) for Nuclear Facilities, ONR, 2014, Rev 0, Leadership and Management for Safety, MS.1 (Leadership); Function and Content of a Safety Management Prospectus, NS-TAST-GD-072 Rev 3; and UK Corporate Governance Code, July 2018 (UK CGC).
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A – this was not a Safety System inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Based on the evidence sampled during this inspection ONR judged that measured against ONR’s expectations for licensee Boards, the intervention rating is GREEN (no formal action), with identification of three areas of good practice, five regulatory observations (areas for improvement) and no Regulatory Issues.
The areas of good practice related to:
- Safety oversight and governance of the DRDL Board, including improved safety reporting to the Board and priority given to safety matters.
- Challenge culture – significant safety challenge at the DRDL Board, with appropriate behaviours, and recent appointment of an experienced Non-Executive Director.
- Visibility of independent advice to the Board and effective action tracking.
The regulatory observations (areas for improvement) related to:
- Continued development of the quality of safety information and briefing to the DRDL Board, including clarity of expectations for acceptable safety performance.
- Enhanced safety oversight across all business units with the potential to affect safety on the licensed site.
- Complete the Organisation, Accountabilities and Responsibilities Programme and embed the new arrangements.
- Continued Board development - appointment of an additional Non-Executive Director, with appropriate experience and behaviours for safety challenge, and continued coaching for Executive reporting to the Board.
- Planned Change of Board Chair by DRDL - review the effectiveness of the change after a suitable period of time (6 to 12 months), to provide assurance of independence, continued development of the challenge culture and effectiveness of Board arrangements.
Conclusion of Intervention
On the basis of the areas sampled during the intervention, the inspectors judged that DRDL had established adequate arrangements for the DRDL Board and Executive. There was evidence that the licensee has made significant improvements in the arrangements, challenge culture and behaviours of the DRDL Board over the last 12 months. This work has also included appropriate separation of Board and Executive functions, as described in relevant good practice.
ONR understands that there are further improvements to be delivered by the licensee, and embedment of the revised arrangements and behaviours is vital – these aspects are part of DRDL’s continued improvement programme. No major shortfalls with respect to relevant good practice for licensee Boards were identified during the intervention.
ONR will undertake a follow-up regulatory engagement in late 2020, to review progress and embedment of the revised Board and Executive arrangements and improvement programme.