- Site: Rosyth
- IR number: 21-030
- Date: June 2021
- LC numbers: 10, 12
Executive summary
Purpose of Intervention
This inspection focussed on the implementation of Rosyth Royal Dockyard Ltd. (RRDL) arrangements for compliance with Licence Condition (LC) 10 (Training) and LC12 (Duly authorised and other suitably qualified and experienced persons (SQEP)). This inspection formed part of ONR’s Integrated Intervention Strategy for 2021/22.
The inspection purpose was to establish whether RRDL has adequate arrangements for LC10 and 12 and that their application enabled RRDL to demonstrate that individuals performing safety important roles are SQEP.
In addition to the inspection, the Annual Review of Safety was undertaken during the visit.
Interventions Carried Out by ONR
During the inspection, we gained evidence of how RRDL manage and track the training and competence of individuals whose role is necessary for nuclear safety. In doing this, we considered how the increased risk and complexity associated with the SDP phase 2 may impact the LC10 and 12 arrangements. Specifically, we:
- Explored the adequacy of the written arrangements for LC10 and 12 in meeting regulatory expectations
- Inspected a sample of role profiles and training and competency records for individuals on the nuclear baseline at different levels of the organisation
- Discussed the arrangements for competency management and how they are used in practice with a sample of role holders on the nuclear baseline.
- Explored how changes to the nuclear baseline are managed and tracked using the recent creation and appointment of a senior role.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable as this was not a system based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the inspection we identified several positive aspects. We found that a competency management system was in use and was being kept up to date. We found that individuals who hold roles on the nuclear baseline were able to clearly explain their role and provide confidence that they held suitable competence. We also found that individuals were open in discussing the current position with respect to LC 10 and 12 and spoke about improvements that were planned or underway.
However, we also identified several shortfalls, which I consider significant. With respect to the arrangements, we found gaps in how roles with nuclear safety importance are identified and reviewed. We also found gaps in the requirement to identify all competencies (knowledge, skills and attitudes) required for role delivery. Further, we found that the arrangements were not clear on whether they applied to contractors taking up nuclear safety important roles. Finally, we identified that the arrangements for the appointment of Duly Authorised Persons (DAPs), did not include clear criteria as to when a role would require a DAP.
With respect to the application of the arrangements, we found several significant gaps and errors in the records sampled. We found that RRDL were unable to provide records of the qualifications held by individuals for roles on the nuclear baseline and found errors in the records held regarding individual competency. It is noted that RRDL were open about the gaps and have been proactive in addressing them. In relation to the errors, we found that in each case, they were associated with the accuracy of the data held, rather than the competence of the role holder.
Finally, during the inspection we identified that RRDL have several systems that hold competence information, in addition to the nuclear baseline records. However, we found that these systems are not integrated and there is limited visibility of the information to end users and those planning work. Again, I consider this gap, particularly with respect to visibility, to be significant.
Conclusion of Intervention
From the inspection, we gained confidence that those individuals spoken to were competent for the roles they undertake. I therefore consider the gaps and issues identified to be associated with RRDL’s ability to demonstrate competency. However, having adequate arrangements to identify all competencies required for nuclear safety important roles, and being able to demonstrate that role holders possess these competencies, is an essential requirement of LC10 and 12. I also note that as the organisation moves into SDP phase two operations, the reliance on the arrangements will increase.
As such, given the size of the gaps and their importance to current and future operations, I have rated the inspection amber against LC10 and 12.
In seeking improvement, I am cognisant of the current low level of risk posed by site activities. I therefore consider that a level 4 issue, requiring RRDL to define a set of arrangements to deliver the current and future scope of operation is appropriate.