- Site: AWE Aldermaston
- IR number: 21-144
- Date: January 2022
- 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 2021/2022 Integrated Intervention Strategy (IIS) for the Atomic Weapons Establishment (AWE).
AWE is currently subject to Enhanced Regulatory Attention from ONR. One of the three safety performance attributes that determines regulatory attention is ‘Control of Hazards and Risks’, part of which is the ‘Maturity of Conventional Health and Safety (CHS) prioritisation and risk profiling. The ONR Nuclear Internal Hazards and Site Safety Team is conducting an intervention to assess the adequacy of AWE’s approach to CHS Risk Prioritisation with much work already completed to understand how this works across the company. The purpose of this intervention was for ONR to examine how CHS risks are prioritised and managed at a local level, within the PTC Facility
Interventions Carried Out by ONR
This intervention consisted of two stages. Firstly, a remote meeting a week before the intervention with the PTC Principal Environment, Safety and Health (ESH) Managers and the local ESH team to understand risk priorities at PTC and the evidence used to establish these, and secondly, a 1 ½ day site-based inspection consisting of meetings with relevant PTC site staff to understand what risk control measures are put in place for the priority risks, as well as a site walk-downs to observe risk control measures at the work face.
I prepared an agenda for the intervention and shared this with AWE prior to the intervention. 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 AWE. It was established at the remote meeting that the risk priority areas for PTC are confined spaces, work equipment safety, work at height, control of hazardous chemicals, explosive atmospheres and lifting. These were the areas of focus for the site inspection.
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 Management of Health and Safety at Work Regulations 1999, as well as the following provisions:
- Provision and Use of Work Equipment Regulations 1998
- Control of Substances Hazardous to Health Regulations 2002
- Dangerous Substance and Explosive Atmospheres Regulations 2002
- Confined Spaces Regulations 1997
- Work at Height Regulations 2005
- Lifting Operations and Lifting Equipment Regulations 1998
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I identified the following areas of good practice:
- I judge that AWE and PTC have focussed their efforts in the correct areas and on balance, most of these priority risks have received requisite attention and control measures.
- I spoke to several work parties on the site walk-downs in MPF and they were all able to identify the key risks involved in their work and clearly articulate the ways in which these risks are controlled.
I also identified that AWE require improvements in the management of the risks presented while working in confined spaces in MPF. AWE have identified that due to the ingress of nitrogen in the ground floor that the whole area is classified as a confined space with an asphyxiation risk (until a permanent solution can be identified). However, there are elements of how AWE are currently managing the confined spaces that constitute a breach of the Confined Spaces Regulations 1997 and the associated Approved Code of Practice (ACOP), specifically with the prevention and control of access into the confined space area. AWE agreed to address these issues.
Conclusion of Intervention
From the evidence I sampled during this intervention, in the main, I was satisfied how AWE decides on which CHS risks to give priority to and to understand how these risks are managed and controlled in PTC. For the risks associated with work equipment safety, work at height, control of hazardous chemicals, explosive atmospheres and lifting, AWE were complying with the associated relevant statutory provisions. As a result, I judged these elements of this intervention merited a ‘Green’ (No Formal Action) rating. However, I found significant shortfalls in compliance with Confined Spaces Regulations 1997. As a result, I judged this element of the intervention merited an ‘Amber’ (Improvement Required) rating and I will apply ONR’s Enforcement Management Model to this issue to determine if formal enforcement is required and the level of any associated Regulatory Issue.