Executive summary
Date(s) of inspection: April 2023
Aim of inspection
This intervention reviewed and examined work planning and control of contractors arrangements for the D58 work area at Barrow; in order to provide regulatory confidence in the management of control measures and systems to aid in incident prevention by suitable planning, information provision and instruction. It formed part of the planned inspection activities at the BAE Systems Marine Limited nuclear licensed site, informed in part by ONR regulatory intelligence of a rising number of conventional safety incidents at the site.
Subject(s) of inspection
- Control of Work (PTW) - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The methods and procedures for project planning (focusing on contractor selection) were presented and discussed, with relevant arrangements reviewed and practical examples provided. Contractor procurement, capability assessment and suitability for projects at a tier one level was found to be adequate. However, we found that tier two and lower sub-contractors were not assessed to the same standards and BAE Systems Marine Limited (BAESML) relied on the tier one contractors to undertake necessary due diligence.
Methods and procedures for the control of contractors on site were reviewed; evidence of regular daily and weekly meetings with tier one contractors were identified. The role of the 'Responsible Person' (RP) has authority for oversight and control of the work of a contractor activity. The RP is selected for the role using a newly introduced skills matrix, an example of which was seen. Standards and Expectations for RPs are set, however understanding of the loading of RPs was not fully understood, which may result in a gap in the oversight of sub-contractors by RPs due to overloading.
A site walkdown demonstrated evidence of control of tier one contractors, including detail and knowledge of Responsible Persons on the site. However, risk assessment and method statements of sub-contractors (tier two and below) were reviewed afterwards and found to be lacking in detail. BAESML committed to follow up with relevant parties involved as a learning exercise.
Overall, with respect to the planning of projects, we judged that the selection and control of tier one contractors is suitable for the work undertaken on site. We consider that BAESML should undertake higher levels of control and monitoring of the performance of tier two (and below) sub-contractors.
Conclusion
Based on the sample inspected, I rate the intervention as green - 'No Formal Action'. This rating is in line with the established ONR guidance.
- “Relevant good practice generally met, or minor shortfalls identified, when compared with appropriate benchmarks.”
- “No significant shortfalls identified in the delivery of safety, safeguards or security functions.”
Opportunities for improvement do exist. However, these will not be tracked by ONR at this time, as I judge that it would be a disproportionate use of resource, and further interventions focusing on conventional health and safety (CH&S) are planned at BAE Systems Marine Limited (BAESML) as part of a continued focus on CH&S performance at BAESML.