Executive summary
Date(s) of inspection: March 2024
Aim of inspection
The aim of the inspection was to sample NNB Generation Company (HPC) Ltd (NNB GenCo) and Tier 1 contractor arrangements for planning, managing, monitoring and coordination activities resulting in plant vehicle pedestrian interfaces (PVPI) at the Hinkley Point C (HPC) site. A further aim was to enhance regulator confidence that appropriate risk control measures have been effectively implemented to reduce the likelihood of a recurrence of the incident and that these control measures are being sustained by dutyholders. The inspection included inspection of both adequacy of the arrangements and a significant focus on effectiveness of implementation in site working areas. The site inspection activities included both an announced and unannounced element.
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The inspection highlighted the significant effort that has been put into developing the PVPI standard and confirmed through on-site inspection that this has driven real and significant improvement. The inspection focused both on adequacy of the arrangements and adequacy of controls implemented on site, in particular how NNB GenCo ensures (using the Plan Do Check Act management model plus the Construction (Design and Management) Regulations 2015 (CDM15) principles) the expectations within the standard are:
- communicated and coordinated by competent personnel (both informing the revised standard and ‘business as usual’ communication structures);
- targeted to where the PVPI risks are (or will be) most significant;
- implemented into risk-based controls on site;
- reflective of relevant UK legal requirements and good practice;
- received and understood by those affected by the risks; and
- proportionate to the nature and size of the undertaking at site, i.e. NNB GenCo’s management arrangements need to reflect they control Europe’s largest construction site and a uniquely complex and dynamic working environment.
The inspection identified both areas that were consistent with relevant good practice as well as raising a number of observations and findings. The revised PVPI standard has been simplified bringing increased clarity that enables both improved compliance and also facilitates auditing and assurance. The inspection found that assurance activities are risk informed and targeted with evidence presented of feedback loops, including effective implementation of a Community of Practice. In relation to the observations and advice provided, the key finding was in relation to inconsistent application of the standards for managing risks to workers, as evidenced through the decision to voluntarily stop operations in one particular area (W30).
In relation to the area where work had been voluntarily stopped, the re-visit to the area as part of the unannounced phase of the inspection found that significant improvements had been made including:
- a separate walkway was installed for the lifting operatives;
- designated areas and segregated areas for the different activities had been re-established;
- the access route into the area which was not on the traffic management plan had been physically barriered off using scaffolding;
- the roller shutter door which was being used as an unauthorised entry route into the building had been closed removing the potential short cut; and
- the cage used to store liquefied petroleum gas (LPG) bottles had been locked.
Conclusion
The inspection identified a number of areas of good practice and significant improvements in implementation of effective controls for PVPI. However, some areas for improvement were identified, in particular the inconsistent application of standards as evidenced through the decision to voluntarily stop operations, which resulted in a provisional amber rating and an associated level 3 regulatory issue will be raised in relation to ensuring the standard further strengthens clarity of responsibility and that this is effectively implemented.