Executive summary
Date(s) of inspection: February 2024
Aim of inspection
The purpose of this vendor inspection was to gain confidence in Bilfinger’s arrangements for Supply Chain Management (SCM) and procurement activities for nuclear safety related items or services.
Subject(s) of inspection
- Health & Safety at Work Act, Section 6 (General duties of manufacturers) - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
ONR carried out a Vendor Inspection of Bilfinger during March 2024, utilising specialists from the Supply Chain and Quality Management disciplines.
The purpose of the vendor inspection was to gain confidence in Bilfinger’s arrangements for supply chain management (SCM) and procurement activities, for the provision of items to GB nuclear facilities. Therefore, the inspection focused on both the adequacy of Bilfinger’s documented arrangements and the implementation of those arrangements in relation to a sample project, which was part of Bilfinger's’ contract with NNB GenCo (HPC).
The inspection was comprised of discussions with Bilfinger staff, a review of records and the sampling of information contained within the management system and related electronic tools
Conclusion
Whilst there were areas of good practice identified during the inspection, it was concluded that there is an overall lack of clarity and integration of the Bilfinger management systems, in addition to gaps in the quality management arrangements of the various Bilfinger entities. A series of detailed findings were identified against these areas, which include, but are not limited to:
- Clarity and Integration
- An absence of overarching organisational strategies/policies e.g. Counterfeit Fraudulent and Suspect Items (CFSI).
- A lack of integration between the Bilfinger Engineering & Technolgies (BET) and Bilfinger UK Limited (BUK) Management systems.
- Inconsistency in the content of the various Bilfinger management systems.
- Gaps and Shortfalls
- Errors and oversights in the Inspection & Tests Plans of Bilfinger and their sub-suppliers.
- Inadequate control and application of electronic signatures for the records sampled.
- Shortfalls in the use and dissemination of learning and OPEX for the areas observed.
Based on these findings, the gaps and shortfalls identified represent a departure from Relevant Good Practice (RGP), including the requirements contained in IAEA General Safety Requirements (GSR) Part 2
Consequently, an amber rating was assigned to the inspection, and one level 3 Regulatory Issue has been raised to address the above shortfalls against RGP.