Executive summary
Date(s) of inspection: December 2024
Aim of inspection
This inspection was targeted at understanding how the licensee was manging risks associated with lifting operations and use of lifting equipment (including accessories) at Heysham 2. LOLER Approved Code of Practice (ACOP) L113, Provision and Use of Work Equipment Regulations (PUWER) ACOP L22, and Rider-operated lift trucks ACOP L117 was used as the main benchmark relevant good practices to determine how risks associated with lifting operations and use of lifting equipment (including accessories) were manged to as low as reasonably practicable (ALARP). The inspection also included testing the implementation of the licensee's revised arrangements in control of lifting operations and lifting equipment (BEG/SPEC/SHE/COP/030), in particular on intermediate lifts.
Subject(s) of inspection
- Lifting / LOLER - Rating: Green
- Provision and Use of Work Equipment Regulations 1998 (PUWER) - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
This inspection focused on the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and how site were ensuring their compliance with the regulations. Particular focus was on the change EDF Nuclear Generation Limited (NGL) had made to their company specification in relation to the categorisation of lifting operations. Rather than having basic and complex lifts, they have also introduced the category of an intermediate lift. This change brought the company specification in line with the British Standard (BS7121-1).
The inspection involved a day on site which consisted of an office based discussion and a site walk-down. There were no lifting operations taking place on the day of the inspection. As such the site tour focussed on the storage of their lifting equipment and how they ensured suitable equipment could be used by employees.
EDF NGL's lifting equipment store was in good order and through sampling the process of 'checking out' equipment it was clear robust measures were in place to ensure only adequate lifting equipment could be used by competent individuals.
A similar sampling exercise took place at one of EDF NGL's contract partners (Altrad Babcock) lifting equipment store. This store was not secure and it was not clear what equipment could or could not be used. Two slings from the store were picked out to establish whether they had been subject to a thorough examination. Although Altrad Babcock were unable to provide a record of the examination at the time of the inspection it was provided the following day. This allowed me to confirm that they were in compliance with LOLER regulation 9(3)(a).
Conclusion
EDF NGL were able to demonstrate they understood what met the requirement for an intermediate lift, how they are identified, and what was required for those lifts that are identified as intermediate. Through sampling lifting equipment on site the team were able to demonstrate that they had appropriate procedures in place to ensure that only equipment that had been subject to thorough examination could be used. These processes also only allowed competent people access to the lifting stores. EDF NGL have a competent LOLER advisor on site who was able to demonstrate the procedures that are in place and answer any questions confidently in relation to the processes.
Although there were inadequacies with the contract partners lifting store. Namely that I could not identify what equipment within the stores was appropriate to be used in lifting operations. The Altrad staff present were unable to demonstrate that the equipment within the stores had been subject to a thorough examination on the day of the inspection. EDF NGL reacted quickly and put in place measures to ensure they could not proceed with lifting operations on site. These operations were embargoed until 3 January 2025. EDF NGL did not remove the embargo until they were satisfied a positive improvement had been made. This involved:
- Highlighting the issues to the Altrad regional manager, and tracking them to completion; and
- a number of follow up observations of the store carried out by senior EDF NGL staff to ensure that the changes had been implemented.
There was a lack of clarity on the day in relation to whether the lifting equipment in the store was fit for purpose. However by providing in date thorough examination certificates the morning following the inspection I was reassured that LOLER had been complied with. Even if it could not be demonstrated on the day.
Based on my sample a green inspection rating is appropriate.