- Site: Winfrith
- IR number: 21-070
- Date: July 2021
- LC numbers: 10, 26
Executive summary
Purpose of Intervention
This was a planned intervention that forms part of ONR’s 2021-22 Conventional Health and Safety operational delivery plan and ONR’s 2021-22 Intervention Plan for Magnox Ltd (ML) Southern Sites The purpose of this inspection was to evaluate Magnox Limited’s (ML’s) compliance with the Construction (Design and Management) Regulations 2015 (CDM 2015), within the SGHWR project at Winfrith. Also, Winfrith’s compliance with Licence Condition 10 (Training) and Licence Condition 26 (Control and supervision of operations) were inspected.
Interventions Carried Out by ONR
Prior to the inspection, ML provided the documents setting down its CDM 2015 arrangements for the SGHWR project, and ML Winfrith’s arrangements for compliance with LC10 and LC26. The key regulatory activities were:
- Discussions with the Client and Principal Designer regarding the implementation of their duties for the project.
- Discussions with the Principal Contractor regarding the implementation of their duties under CDM 2015 for the project.
- Inspection of the SGHWR construction site.
- Inspection of the licensee’s arrangements for compliance with LC10 regarding the adequate provision of training for those with responsibilities for safety at the Magnox Winfrith site.
- Confirming that the licensee has adequate arrangements under LC 26 to ensure that all operations affecting safety are conducted under the control and supervision of suitably qualified and experienced persons.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A
Key Findings, Inspector's Opinions and Reasons for Judgements Made
CDM
ML is both the Client and Principal Designer for the current works for the SGHWR project at Winfrith. ML’s arrangements for managing the project, include a detailed organisational structure governing the roles, responsibilities, and accountabilities for the safe working together of ML and their Principal Contractor (PC), James Fisher Nuclear Ltd (JFN), who employ sub-contractors to do some of the work. ONR judged that these arrangements were adequate for effective control and supervision by the licensee of the Principal Contractor (JFN).
LC 26
However, these arrangements were not fully reflected in an inspection of the workface where a shortfall in the implementation of control and supervision of a sub-contractor (Pneutrol) was observed. Employees of Pneutrol had signed the daily risk assessment sheet, and this included written confirmation/signing that the portable appliance testing (PAT) was in date for the hand operated power tools and ancillary equipment. It was over 3 months out of date at the time of the inspection. This had not been picked up by the JFN supervisor on the daily walk round or the ML supervisor on the weekly walk round for the 3 weeks Pneutrol had been working on site. The shortfall was brought to the attention of ML
LC10
The licensee demonstrated adequate compliance with Licence Condition 10. Accurate training records of all staff on-site were produced at ONR’s request and confirmed there were no shortfalls evident in the duty-holder’s procedures. ONR observed a discussion with a scaffolder concerning his training, that provided evidence that the training arrangements were being implemented.
Conclusion of Intervention
ONR provided feedback to ML regarding their compliance with CDM 2015 and License conditions 10 and 26.
There was a shortfall in the implementation of control and supervision by the licensee over the principal contractor and its sub-contractor regarding the checking of the test date for portable appliances. ML were informed that a Level 4 Regulatory Issue was to be raised. ONR informed ML that it would confirm that the issue had been resolved in a future inspection.
ONR was satisfied with the licensee’s arrangements for complying with LC10.