- Site: Sellafield
- IR number: 21-084
- Date: September 2021
- LC numbers: 35
Executive summary
Purpose of Intervention
This was a planned intervention to provide regulatory confidence in the management of conventional health and safety (CHS) hazards associated with control of substances hazardous to health (COSHH) at Sellafield’s Analytical Services (AS).
The intervention was carried out in-line with the planned inspection programme for Analytical Services.
Interventions Carried Out by ONR
This intervention was carried out by two ONR Nuclear Internal Hazards and Site Safety specialist inspectors and the ONR site inspector on 14 and 15 September 2021. An agenda was prepared for the intervention and shared with Sellafield before the intervention.
The intervention comprised:
- discussions with Sellafield staff;
- site walk-down accompanied by Sellafield staff;
- sampling of documents and records; and
- further email correspondence after the site visit with Sellafield seeking clarification on documents and 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 ie Control of Substances Hazardous to Health Regulations 2002. I also consulted the relevant good practice such as:
- Approved Code of Practice and guidance L5 for COSHH
- EH40/2005 Workplace Exposure Limits
- COSHH Essentials
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Whilst on site, ONR Inspectors noted areas of good practice, which were that AS had significantly reduced its chemical inventory and had streamlined its chemical purchasing policies and procedures, resulting in improved controls in relation to the quantities of chemicals retained on site. Good practices were also observed in relation to the labelling of chemical containers. AS were also able to show good practice as regards fume cupboard extraction such as 6 monthly thorough examinations and weekly testing with anemometers and tracking of the results. It was also noted that COSHH assessments had been performed for large numbers of chemicals in use and emergency grab sheets were provided in the corridors outside laboratories.
AS were unable to provide clear evidence that hazardous substances with a Workplace Exposure Limit (WEL), carcinogens, mutagens, teratogens, respiratory sensitisers, or skin sensitisers were being adequately controlled. COSHH assessments provided did not fully consider the nature (dustiness, volatility etc.) of substances in use. COSHH assessments did not consider the need for exposure monitoring or health surveillance. AS were unable to show that where the circumstances of work involved exposure to more than one substance, that the risk presented by exposure to such substances in combination had been considered.
Exposure monitoring is required for COSHH assessment, where there is a serious risk to health from inhalation of the substance; to check that exposure limits are not exceeded; to check that exposure controls work well enough, or if improvements are required; to help choose the right level of respiratory protection; and to show any need for health surveillance. It was noted that exposure monitoring and health surveillance is being conducted for radiological hazards associated with laboratory work.
Conclusion of Intervention
Based on the samples observed and examined, Sellafield’s arrangements in managing COSHH did not meet ONR’s regulatory expectations, there were deficient arrangements for compliance with the legal requirements of COSHH in relation to Regulation 6 assessment of the risk to health created by work involving hazardous substances to health and Regulation 10 Monitoring of exposure. As a result, an intervention rating of Amber (Seek Improvement) was allocated. A Level 3 Regulatory Issue (8993) has been raised to track Sellafield’s progress in addressing the shortfalls against COSHH requirements. ONR will follow this up as part of routine engagements with Sellafield.