- Site: Barrow
- IR number: 21-019
- Date: May 2021
- LC numbers: 25
Executive summary
Purpose of Intervention
Undertake a compliance inspection of BAE Systems Marine Limited (BAESML) Licence Condition (LC) 25 (Operational Records), which forms part of the 2021/22 intervention plan and propulsion sub-division strategy.
Interventions Carried Out by ONR
Licence Condition 25 (LC 25) requires the licensee to ensure that adequate records are made of the operation, inspection and maintenance of any plant which may affect safety.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
This inspection, which comprised of discussions with BAESML staff and examination of plant documentation, focussed on the following areas:
- BAESML arrangements associated with LC25.
- BAESML view on compliance with LC25.
- Sampling implementation of the arrangements and documentation associated with the following on the licensed site:
- Devonshire Dock Hall (DDH) - Including operational documentation related to records relevant to radioactive material; records that show the status of EMIT.
- Wet Dock Quay (WDQ) - Configuration of the plant; DAP Operational Logs; Operating Rule Compliance Check Sheets.
- SQEP Records for those with responsibilities for the production, review, storage and retrieval of Operational Records
Explanation of Judgement if Safety System Not Judged to be Adequate
Not Applicable – this was not a System Based Inspection (SBI).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
From review of the arrangements and sampling of operational records, I consider that the licensee does effectively implement their arrangements for LC25 – Operational Records and meets relevant good practice as identified in the LC25 Technical Inspection Guide (TIG).
From the LC25 arrangements documents BAESML were able to adequately demonstrate persons responsible for operational records, that the definition covered all aspects of operations that may affect safety, and a list of what records should be kept and their retention period.
I considered that licensee’s compliance matrices provided a good account of responsibilities and this was useful in identification of business and functional compliance arrangements. I gained further confidence in the site’s compliance with LC25 by the LC25 owner and LC25 leads commitment to date and attitude to continuous improvement.
In relation to the sample chosen BAESML demonstrated that adequate records are made of the operation, inspection and maintenance of any plant which may affect safety. I was further assured by those I interacted with on site in relation to their management, oversight and attitude to operational records.
No matters were identified as requiring immediate regulatory attention during the conduct of this compliance inspection and no Regulatory Issues have been raised.
Conclusion of Intervention
I judge that BAESML has adequately demonstrated compliance against LC25 – Operational Records, meeting relevant good practices. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of GREEN (no formal action required) is merited for the licence condition inspected.