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BAESML Barrow: CDM inspection of 58 and DDQ sites

  • Site: Barrow
  • IR number: 21-089
  • Date: September 2021
  • LC numbers: N/A

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation (ONR) Strategy, each year ONR performs a series of planned interventions at nuclear licensed sites. This intervention forms part of ONR’s 2020/2021 Integrated Intervention Strategy (IIS) for BAE Systems Marine Ltd (BAESML) at Barrow.

The purpose of this intervention was for ONR to examine the adequacy of the arrangements that BAESML has in place to manage its construction activities on its licensed site and the authorised site, and to judge the compliance with the Construction (Design and Management) Regulations 2015.

Interventions Carried Out by ONR

This one and a half day intervention on 28th and 29th September 2021 focussed on the construction site at D58 and the construction at Devonshire Dock Quay (DDQ), on the Authorised Site. This intervention was led by an ONR Nuclear Internal Hazards and Site Safety (NIHSS) specialist inspector, supported by an ONR Civil Engineering Inspector and the Nuclear Principal Inspector responsible for ONR’s oversight of the Dreadnaught Programme. We were accompanied by one of the site Defence Nuclear Safety Regulator (DNSR) inspectors. I prepared an agenda for the intervention and shared with BAESML prior to the intervention and requested key documents related to CDM compliance. During the intervention, I strictly adhered with control measures outlined within ONR-GEN-GD-022 (Visit to licensee and other duty-holder premises and other relevant locations during the COVID-19 pandemic) and the local COVID-secure control measures at Barrow.

The intervention comprised of discussions with BAESML staff and the Principal Contractors (PCs) responsible for the D58 and DDQ sites, as well as site walk-down of both site location accompanied by BAESML and the PCs’ representatives and sampling of associated records.

Regulatory advice and judgement were based on determining compliance with Sections 2 and 3 of the Health and Safety at Work etc Act 1974 and the relevant statutory provisions made under the Act, particularly the Construction (Design and Management) Regulations 2015 and the Management of Health and Safety at Work Regulations 1999.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not Applicable to this intervention.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I identified the following areas of good practice:

  • BAESML’s level of oversight and scrutiny of both projects was good. They were able to demonstrate that they had applied their systems to function as both CDM compliant Intelligent Clients and Principal Designers. The SRP SHE function were able to provide evidence of regular risk-based checks, inspections and audits that focussed in the correct areas and provided reassurance that the Principal Contractors on both sites were controlling the risks.
  • The evidence sampled during the inspections demonstrated that the control of the key risks was well managed by the Principal Contractors on both D58 and the DDQ sites.

I also provided regulatory advice in the following areas:

  • D58 – A Mobile Elevated Working Platform (MEWP) with deep cuts in the solid tyres was taken out of service when this defect was raised by ONR. I also asked BAESML and the Principal Contractor to review the other MEWPs on site to ensure that the controls are sufficient to prevent accidental operation.
  • DDQ – I asked the Principal Contractor to augment their Risk Assessment/Method Statement by including reference to the parameters that allow the MEWP to work safely below the dock line are included along with controls that alert or prevent these parameters from being exceeded are maintained and tested.
  • DDQ – Further information is required on the controls employed by the Principal Contractor to ensure that workers’ hearing is not being affected by the piling operations.

Conclusion of Intervention

From the evidence I sampled during this intervention, I was satisfied that the risks for the D59 and DDQ projects were being adequately controlled. I found no significant shortfalls in compliance with CDM 2015 and other relevant statutory provisions. As a result, I judged that this intervention merited a ‘Green’ (No Formal Action) rating.