Executive summary
Date(s) of inspection: July 2024
Aim of inspection
The inspection sampled safety leadership on site to get an indication of the safety culture and provide ONR with confidence in NNB GenCo (HPC) Ltd’s (HPC's) implementation of its safety leadership arrangements. The inspection focussed on safety leadership through the Licensee (Client & Principal Contractor) into the major Tier 1s contractors including front line supervision and their management of a sample of recent incidents on site involving electricity and work at height.
Subject(s) of inspection
- CDM 15 - Rating: Green
- Leadership & Management for Safety - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection team found a clear flow in the setting of standards required, from the Client’s own standards through to the Principal Contractor’s set of standards, which are then formally cascaded to contractors. Compliance with these standards is monitored through a number of audits undertaken by the Client, Principal Contractor and Contractors (although the audit outputs were not reviewed and, therefore, the inspection did not assess the effectiveness of the audits in testing the implementation of standards).
The inspection team reviewed a sample of contractor’s arrangements which clearly demonstrated how the Principal Contractor’s standards and expectations are being adopted with some variances between contractors. Their implementation on site is monitored through inspections, audits, and direct leadership engagement in the field.
The inspection team had a number of discussions with a range of front line supervisors, who generally demonstrated their competency, awareness of risks, positive behaviours and engagement with their teams.
The management of a sample of recent incidents were reviewed through the reports themselves and discussions with some of those involved. This helped demonstrate the roles of leaders in undertaking and managing these investigation but also provided some insights into, for example, the system to support the process and track actions, which should be followed up as part of the planned organisational learning inspection later in 2024.
Overall the inspection, and the review of documentation sent post the inspection, provided insights into the safety culture. Further insights would need to be gathered to provide an indication of any trends and inform any regulatory judgement on culture.
Conclusion
We concluded that based on the evidence provided, safety leadership through the Licensee (Client & Principal Contractor) into the major Tier 1s contractors and supervisors is being adequately implemented by NNB GenCo (HPC) Ltd.
On this basis, a GREEN rating was assigned to this inspection against regulatory good practice set out in the scope.
A number of observations were provided, and these will be followed up by ONR during routine interactions and the organisational learning elements will be part of the planned inspection later in the year.
There are some areas where further insights would need to be gathered to provide an indication of any trends and inform any regulatory judgement on culture e.g. consistency in the competency across front line supervisor levels, and whether some low level issues on site are being adequately recognised or challenged.