The safety of nuclear installations in the UK is the responsibility of holders of nuclear site licences and is assured through a system of regulatory control. A nuclear site licence, which can only be granted to a corporate body, permits the use of a site for specified activities. Thus, for most sites, licensing applies throughout the lifetime of an installation from design and siting, through construction, commissioning, operation, and modification to eventual completion of decommissioning. AWE, however, had been operating for many years before being first licensed in July 1997 when its legal immunity from the Nuclear Installations Act 19651 was removed.
In 1997 the Nuclear Installations Inspectorate (NII) granted licences to Hunting BRAE Ltd to manage the operation of the Atomic Weapons Establishment (AWE) sites at Aldermaston and Burghfield. The Ministry of Defence (MoD) contract with Hunting BRAE Ltd expired on 31 March 2000, and the Ministry decided that AWE plc should run the sites in future. As nuclear site licences cannot be transferred from one party to another, the changeover in the management of the sites necessitated the revocation of the nuclear site licences formerly held by Hunting BRAE Ltd, and the granting of licences to the new operator, AWE plc, which came into effect on 1 April 2000. In May the NII published a report on the relicensing2.
The purpose of this report is to review the performance of AWE plc over the first three months under its new management contractors, AWE Management Ltd. This has been done to fulfil a commitment given by the Secretary of State for Defence in a House of Commons Written Answer on 29 March 20003. This report also provides a benchmark for a further review which is planned to take place after the first 12 months of the new licences. Although the Environment Agency (EA) will be providing a separate report, the Environment Agency site inspector worked with the HSE team to ensure that where HSE and the EA have joint interests, the opportunity was taken to explore and report on matters of mutual concern.
The review concluded that health and safety have been successfully managed during the change of contractor and licensee. The new licensee has made a good start under the new contract and maintained a good health and safety culture. A number of safety-related issues, many of which are long standing, were re-examined during the review and these will be used to establish a baseline for assessing future performance.
1. Hunting BRAE's 7-year contract to manage the AWE sites at Aldermaston and Burghfield expired on 31 March 2000. Following a tendering exercise during 1999, the MoD's Defence Procurement Agency appointed AWE Management Limited (AWE ML), a joint venture company comprising BNFL, Lockheed Martin and SERCO, as the new management contractor. It was decided that the new licences should be held by AWE plc, the employer of the labour force, so that any future change of the management contractor was unlikely to result in responsibility reverting to MoD or the need for relicensing. The sites are therefore being operated by AWE plc, which holds the new site licences. AWE ML now owns all the shares in AWE plc with the exception of one Special Share which is retained by the Secretary of State for Defence.
2. HSE recognised that the licensing of a new contractor to operate the Atomic Weapons Establishment sites would be of public interest. To provide reassurance, HSE therefore agreed to provide Ministers with reports on the safety performance of the new management contractors after 3 and after 12 months following licensing.
3. This assessment of the performance of AWE plc has been designed to provide an insight into the progress on a number of key topics of regulatory interest which were being addressed by Hunting-BRAE Ltd. Examination of each of these topics in this review provides a measure of how the new licensee has managed the changeover and maintained momentum in meeting work programmes agreed with HSE.
4. Over the last year, new regulatory requirements have been introduced: a new condition, on the management of organisational change, has been added to all nuclear site licences; the Control of Major Accident Hazards (COMAH) Regulations have also come into force. The approach by AWE plc in managing these requirements provides an indication of the company's ability to respond to new safety challenges in general.
5. The review also examined recent data concerning sickness, lost time accidents and average radiation exposure. Statistics on these topics have been gathered for some time at AWE: performance targets were set each year as part of a continuous safety improvement programme. Examination of trends in these parameters since AWE ML took over on 1 April acts as a useful barometer in measuring the success of the change under the new management regime.
6. The review has been carried out by a team of six HSE inspectors comprising five NII inspectors and one explosives inspector. They have closely monitored the change in site management to ensure no unforeseen problems arose as a result of the transition. This was achieved by maintaining the established planned inspection programme to evaluate AWE plc's compliance with the nuclear site licences. Meetings with all levels of AWE plc management were held to confirm that agreed safety improvement plans were being kept on schedule. A range of performance indicators was also selected against which to monitor the Company during the 3-month and 12-month review periods. These were chosen to ensure that a range of diverse safety requirements was examined to provide a reliable indication of the new licensee's ability and commitment to meet HSE's expectations.
7. At the end of the 3-month monitoring period the new licensee's management of safety was formally assessed, between 10 and 13 July 2000, by the same team of six inspectors. The assessment included a site inspection covering all the performance indicators and the team conducted interviews with a cross-section of the licensee's staff. The Environment Agency (EA) site inspector also joined the team to ensure that, where HSE and the EA have a joint interest, the opportunity was taken to explore areas where there might have been matters of mutual concern.
8. Following the award of the management contract to AWE ML, representatives of the AWE ML consortium established office accommodation in January next to the Aldermaston site where they set up arrangements for taking over management of the site. Whilst a major part of their activities was concerned with information gathering and verifying detailed aspects of the contract with MoD, known as due diligence, considerable effort was devoted to progressing the applications for gaining new licences and shadowing the activities of Hunting-BRAE management systems.
9. During this lead-in period, AWE plc directors were nominated by AWE ML to fill senior positions, some of which would be vacated by the Hunting-BRAE directors at the end of the contract, and draft strategic plans and objectives were prepared to meet the terms of the new contract. An organisational diagram for the AWE plc senior management is provided at Annex 1. This also shows the previous employer for each of the post holders.
10 All new directors had a programme of familiarisation visits to plants for which they were to become responsible, and briefings were given on the existing safety management systems and the Safety Management Prospectus that is a requirement for new site licences. The new directors also attended key management meetings to observe how normal day-to-day business was conducted. The proceedings of the Nuclear Safety Committee were also observed and the Chief Executive designate was invited by the Chief Executive of Hunting-BRAE Ltd to attend a Local Liaison Committee meeting and be introduced to members.
11. The lead-in process had been examined by the NII during a team inspection conducted between 7 and 9 February 2000. This provided confidence for the impending transfer of management responsibilities and showed that the new AWE plc management team was fully capable of taking up responsibilities on 1 April 2000.
12. Immediately following the change of management, NII inspectors carried out a sample inspection of key areas to ensure no major problems had arisen in the management of safety as a result of the transition. The inspection confirmed that a company safety policy statement had been provided and promulgated, and that plant safety cases and safety management systems were in place and operating properly. New company signs had been erected, there was no disruption of safety arrangements at plant level and it was very much a case of business as usual. Meetings were held with a range of plant staff including managers, staff and safety representatives which also provided reassurance that the change was evolutionary rather than revolutionary.
13. Fifteen key areas of safety were selected to assess the performance of AWE plc since 1 April 2000. All the topics have demanded close attention by the new licensee across a wide front of safety management interfaces since relicensing. They will also form a basis for a longer term view of the new licensee's performance for the 12-month review.
14. Responsibility for assessing the performance of AWE plc against the various indicators was allocated to different members of the team. Meetings of the team were convened during July to consider and discuss findings. This was done to identify any areas of concern which required closer scrutiny. Commentary on the team's findings is contained under each of the topic headings as follows:
15. HSE inspectors have maintained the programme of systematic inspections to ensure compliance with regulatory requirements. Inspections for compliance with licence conditions have been carried out at a range of different facilities at the Aldermaston and Burghfield sites and to date it is confirmed that managers are maintaining a consistent and positive approach to safety. Where deficiencies have been observed, the company has taken corrective action to rectify matters. During the 3-month period, 16 major facilities have been inspected by HSE inspectors: over the next year it will be possible to undertake a more extensive inspection coverage of the AWE sites which should provide a very clear indication of the safety performance of the new licensee. The 12-month report will contain the results of this planned inspection programme.
16. Licence Condition 11 requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and its effects.
17. It is NII practice to require the top tier of the arrangements - often called the Emergency Plan - to be submitted, and to be approved as a precondition of the licence coming into force. (This has the effect that the Emergency Plan may not be altered without further approval by NII). AWE plc has duly submitted the Emergency Plans for Aldermaston and Burghfield, and these have been approved. These plans are identical in all essentials to those approved under the previous licences.
18. During its first 3 months as licensee, AWE plc gave a satisfactory demonstration of these arrangements at Aldermaston at an emergency exercise held in 17 May 2000. NII witnessed the exercise, took part in the subsequent debriefing, and is following up the licensee's plans to make improvements to some aspects. This demonstration exercise showed an improvement in the performance of the teams at the plant as compared with previous exercises under the former licensee.
19. A further demonstration exercise is planned for September 2000, at Burghfield. This will form part of a further examination of the safety performance for the next review, at 12 months after licensing.
20. AWE plc is continuing with a comprehensive programme of improvements to the detailed emergency arrangements that was begun under the previous licensee, following regulatory action in 1999 by NII in the form of an Improvement Notice. The areas for improvement include: establishment of an emergency response policy; training of persons with emergency control functions; provision of emergency equipment; mustering on site; revising the off-site plans. Adequate progress is being made.
21. Licence Condition 7 requires that the licensee shall make and implement adequate arrangements for the notification, recording, investigation and reporting of incidents occurring on the site. The current arrangements are essentially those operated by Hunting-BRAE, the licensee prior to 1 April 2000.
22. AWE plc is reviewing these arrangements. This review has already led to proposals for change, and implementation has begun. Notable examples include: the introduction of a fast-track investigation procedure for more significant events, with a target of reporting on events within 24 hours; information on events will be shared with other licensees and with national and international databases (including that of USDoE); trend analysis of events has been introduced and important lessons promulgated throughout the company; and, the revision of the basis of categorisation of events: a Category 0 has been introduced for minor events that require no further investigation. It is anticipated that the review will be complete, and the improvements fully implemented, by November 2000.
23. NII judges the review to be thorough and the improvements which have already been introduced to be beneficial.
24. Much decommissioning is taking place on the sites, and this will increase as a number of facilities approach the end of their working lives. Some facilities are in a care and maintenance phase pending the commencement of dismantling. In April 2000, NII approved a site-wide 10-year Decommissioning Plan, as well as three facility-specific plans. These plans set out milestones and regulatory hold points beyond which AWE plc cannot proceed without NII agreement. Valuable experience is being gained by AWE plc on safe techniques for practical decommissioning.
25. The new management team has quickly come to terms with the magnitude of the task ahead and early indications are that programmes are being met. Progress has been good within an old large laboratory facility and an old production building. Preparations are on schedule in one of the old production facilities. Remedial work has also started ahead of schedule at a former research reactor. Two NII legal instruments clearing regulatory decommissioning hold points have been issued since relicensing on 1 April 2000. Safety submissions have been of acceptable quality and the management arrangements have ensured that thorough risk assessments are carried out.
26. The new management team has also recognised the need in future to move to more advanced and automated decommissioning techniques to further reduce the risk to workers. A reorganisation of the decommissioning teams is under way which should lead to a more effective delivery of the site programme. At this early stage, there is no evidence to suggest that the new contractor will not be able to meet the considerable decommissioning challenges ahead at Aldermaston.
27. Since relicensing, AWE plc has produced a site-wide radioactive waste management plan covering the next 10 years. There are currently seven formal regulatory Specifications in place, related to sludge tanks, future production arisings and legacy waste issues. These legal instruments were carried over from the old licence, and call for the design and installation of new plants to treat various streams of waste. The new management team is bound by these regulatory requirements as long as they remain in force and consequently needs to build new waste treatment plants, and any additional stores that may be necessary, in the next 5 years.
28. A new waste store is due for completion by the end of this year and wastes from cramped older stores will be transferred into this and other modern stores. A legal instrument was issued in May 2000 clearing the remaining regulatory hold point for transferring this waste. Early indications are that satisfactory progress is being made with these capital projects. A partnering alliance has been formed with a supplier to begin the sludge tank emptying and waste immobilisation project. Prior to 1 April 2000, the contract with the MoD did not provide strong incentives for minimising waste generation on site. The new contractual arrangements put in place by the MoD appear, on early inspection, to offer greater scope for waste minimisation and completion of the capital projects: this issue will be regularly pursued under the relevant licence condition with the new management team. The creation of a single Environmental Programmes Group has given added focus to dealing with radioactive waste issues.
29. AWE plc has given a commitment to cease discharging through the Pangbourne pipeline into the Thames by 2005 and is currently undertaking a Best Practicable Environmental Option (BPEO) study to consider options for the disposal of radioactive aqueous waste following the closure of the pipeline. This study will be completed for submission to the Environment Agency and NII by 1 October 2000.
30. Criticality accidents are prevented by controlling the configuration and quantity of fissile material, neutron reflectors and moderators at any work station. An area of concern identified over the past few years has been associated with the reporting of incidents related to criticality issues. These have been largely due to procedural weaknesses and not connected to any threat of a real criticality accident. However, ambiguities in procedures are not acceptable.
31. NII identified that the methodology for the analysis and generation of criticality certificates at AWE sites had introduced undue complexity. This complexity resulted in an increased work load on the criticality specialists, who were overstretched in handling constant requests for modifications to certificates, and an increased risk of human error. Under the new contract there has been a review of methods of working in this area, which in the case of the main production facility has resulted in a recent submission to NII of proposals to simplify the criticality calculation basis for a large part of the facility. This safety case requires more work to present the arguments to an acceptable standard, but if this is done it should result in lowering the risk of human error both during operations and in the programming of the material tracking systems, thus leading to improved safety.
32. The new management team has instigated workshops on criticality to clarify the position at the start of the new contract, identify solutions and priorities, and review resourcing. The workshop findings were presented to the new executive in June, resulting in agreement to pursue the recruiting of additional specialist staff and updating computer equipment. A strategy for handling certificate modifications and criticality re-certification across the sites is in preparation. AWE plc has identified a number of improvements that can be made to the criticality assessment arrangements. These should increase the effectiveness of the criticality service and improve consistency with other parts of the nuclear industry.
33. It is intended that the report covering the first year of the contract will include an examination of AWE plc's strategy for criticality control, with particular emphasis on reviewing the scope for reducing risk by engineered means as opposed to procedural controls.
34. Following the Strategic Defence Review published in 1998, the future demands on production at AWE sites were clarified, including the requirements for nuclear materials to satisfy the published programme. This allowed the previous contractor to start to identify a strategy for dealing with SNM (plutonium and enriched uranium), but very little progress was made before the new contract started.
35. The safe handling, storage, surveillance and use of SNM are important to safety at AWE. The new contractor has undertaken to produce a programme for managing SNM; this was a key issue for NII when granting the new licences.
36. To ensure that doses to workers are reduced and materials are properly controlled, NII has requested a strategy which ensures that SNM is in a stable form, is put into containers that are suitable for long-term storage (this avoids frequent handling and unpacking for surveillance checks) and that packages that are not yet in the newer purpose-designed stores are transferred into them. This should in turn release older facilities for decommissioning.
37. It was recognised that long-term and short-term programmes for SNM could not be established immediately nor put in place by the new contractor on the first day of the new licence. NII is satisfied that AWE plc recognises the problem and has therefore accepted a written commitment to produce a programme addressing the issues related to SNM by the end of September 2000. At the time of writing, the remaining documents were said to be on schedule for completion by September.
38. AWE plc has also introduced a new section called the Nuclear Material Management Programmes Office to oversee the strategy for dealing with SNM. This office should provide a central company focus for SNM matters.
39. Licence Condition 13 (LC13) requires the licensee to establish a nuclear safety committee to consider a number of safety-related matters and give advice to the licensee.
40. The HSE report2 published earlier this year records that a nuclear safety committee was formed in March 1996 by the previous licensee, and that NII was satisfied that it was strong and effective, and provided sound advice to the licensee.
41. AWE plc, the present licensee, established a new nuclear safety committee on foundations laid by the previous committee. Its terms of reference, which HSE has approved in accordance with LC13, are unchanged. Its working procedures are also largely inherited, though a review has been made of the scope and efficiency of the committee's business. Two worthwhile changes have already been made, in that the committee has made visits on the site to those facilities whose safety is under discussion, and intends to do so regularly, and that there has been renewed encouragement for safety representatives to attend as observers.
42. The committee now has 15 members, 11 of whom served on the previous committee. As required by LC13, the licensee has furnished to NII details of the qualifications and experience of the new members. NII has considered them and has not objected to any member.
43. A requirement of LC13 is that a nuclear safety committee must have an independent member or members. The AWE plc nuclear safety committee has three independent members, all of whom served on the previous committee. This has provided a strong basis for continuity of independent advice to the committee.
44. In its first 3 months, the nuclear safety committee has met four times. NII has received a full record of all matters discussed at those meetings and the advice given to the licensee.
45. The evidence from records is that an appropriate range of matters is being discussed and sound advice continues to be given. The committee has sometimes advised that papers presented to it should not be approved by the licensee, and it is apparent that the committee has an enquiring attitude when considering programmes and ALARP arguments, for instance in challenging the timescale proposed for the introduction of safer pallets in a drum store (the timescale was subsequently reduced).
46. The licensee has accepted all of the committee's advice during the period.
47. NII has a regulatory interest in all changes to a licensee's organisational structure and resources which may, (i) affect safety, whether beneficially or detrimentally, (ii) affect the licensee's ability to comply with the NII Act and licence conditions, (iii) or alter the basis on which the nuclear site licence was granted.
48. Licence Condition 36 requires each licensee to "make and implement adequate arrangements to control any change to its organisational structure and resources which may affect safety" on the site. 'Resources' has the broad meaning of the staffing, material assets and information needed to sustain the activities on the nuclear licensed site in a safe condition.
49. In line with all other licensees, AWE plc submitted its top-tier arrangement under LC36 on 1 April 2000. As part of the arrangements it later submitted a baseline analysis of staffing which is designed to provide a benchmark against which the licensee can assess the impact of any proposed organisational changes.
50. NII has assessed AWE's management-of-change arrangements, and judged these to be adequate as they incorporate all the essential details contained in the NII's published guidance. The current baseline document, however, requires further development before it can be considered to be fully effective. The work necessary has been identified, and a commitment has been made by AWE plc to progress it. This is being undertaken within a timescale similar to that of other major licensees. In the interim, AWE plc acknowledges that any proposal for a significant organisational change will need to include a baseline analysis for all plants and functions that will be affected by the proposed change.
51. During the transitional period the new management team identified the need for improvements to the assurance processes across the company, and produced a provisional plan for this. Assurance is the collective name given to safety, health, quality, environment and security functions, and the assurance processes include many of the means by which compliance with licence conditions is delivered. The production of safety cases and their independent review are examples. The assurance processes have been subjected to a fundamental analysis designed to provide the basis for structural, process and procedural improvements to the assurance functions. Comparisons have already been made between the current assurance structure and a number of alternative structures, and a new candidate structure has been identified. Work has gone on in parallel to establish and confirm assurance responsibilities and competencies of all staff, and to introduce positive cultural changes into the company.
52. Progress with the initial stages of the Assurance Improvement Plan is good and the related initiatives appear appropriate and worthwhile.
53. It has been confirmed that the efforts put into developing public relations and building trust with the local community by Hunting-BRAE Ltd have been continued by the new management: efforts are actively being made to enhance those relationships with the community wherever possible. Examples of the ways in which this has been done include: (i) the Local Liaison Committee (LLC) visited Sellafield on 21 and 22 June to observe how another LLC conducts its business; (ii) minutes of LLC meetings are now made available on the AWE web site; (iii) the AWE web site has been rebranded and extended; (iv) a special issue of the AWE newsletter "Community Link" which introduced the new management team was sent to local residents; (v) a selection of safety and environmental reports is being placed in local public libraries and (vi) a major external scientific conference was held on the site at Aldermaston for the first time on 27 June 2000. NII has received very positive feedback from some local residents on the special issue of "Community Link".
54. The Company has also stated its intention to extend the information provided on its website and to publish a Company brochure by the end of the year. A Working Group has been drawn from members of the LLC is to review the content of AWE plc's quarterly report on Environment, Safety and Health to determine if any changes should be made in the scope of the report.
55. The status of the Aldermaston and Burghfield sites with respect to COMAH was agreed between AWE plc and the previous site operator. The Aldermaston site was notified in February 1999 as a Lower Tier COMAH site, and it was confirmed by AWE plc that the Burghfield site would be operated with restricted inventories of dangerous substances, thereby reducing risks and avoiding being subject to COMAH.
56. In June 2000, inspectors from the Competent Authority made their first inspection under COMAH of representative areas of the Aldermaston site. The inspection team found an awareness of COMAH amongst facility staff and in general a good standard of operation, although there were some points where improvement was required. Just prior to that inspection, AWE plc had forwarded a draft "Major Accident Prevention Policy" document for the Aldermaston site to the Competent Authority and confirmed that, as planned, this would be finalised by August 2000. AWE plc also undertook to appoint a site manager for COMAH to take overall responsibility for COMAH compliance.
57. AWE plc also recognised that careful monitoring and control of inventories of COMAH dangerous substances present on the Aldermaston site are crucial for ensuring that these, aggregated where appropriate, remain below the top-tier threshold. To help with such monitoring and control, the existing databases for individual dangerous substances are being replaced by a single database for all COMAH dangerous substances held at Aldermaston.
58. AWE plc has kept the previous radiation dose objectives for annual maximum individual and collective doses. These are 5 mSv and 750 mSv respectively. The doses received in the first 3 months of the new contract appear to be well on target to meet the annual objectives. Additionally, annual dose objectives have been set for each of the major facilities. These will be monitored by the NII in the continuing review of AWE plc's performance. These doses are well below any statutory dose limits or constraints.
59. AWE plc has also developed and agreed with MoD an additional performance measure for individual doses that complements the current radiation dose objectives.
60. A target of 0.3 per 100,000 hours worked was set for the calendar year 2000 for the lost time accident frequency rate (LTAR) for employees (a lost time accident being one which results in an employee being absent from work, or unable to carry out normal duties, for over 3 days). From an LTAR of 0.7 in 1994 there has been a progressive reduction to 0.3 in 1999. In the first 6 months of 2000 there have been six lost time accidents, which represents an LTAR of 0.16, and AWE plc is confident that it is on course to achieve an LTAR of less than 0.3 at the year end. This figure is significantly lower than those for the years 1994 to 1999 for the manufacturing sector of industry.
61. All near misses and injuries at AWE sites (whether or not they involve AWE plc employees) are the subject of a Safety Related Incident Report (SRI) and are investigated by the Company. An analysis of trends in such reports involving employees for the year 1999 identified three priority areas for action: manual handling; stepping on or striking objects; falls of persons. A set of key performance indicators has been approved by the new executive, which will review progress quarterly and also review the targets.
62. There is a separate analysis for the work of Ministry of Defence Police (MDP) and contractors at AWE sites. AWE plc has recently noted that the LTAR for MDP is higher than that for the AWE workforce and is working with MDP to attempt to reduce it.
63. A sickness absence target for employees of 3.5% (days sickness divided by total available days) was set for the calendar year 2000. The actual rate in 1997 was 3.1%; in 1998, 2.71%; and in 1999, 2.83%. For the first 5 months of the calendar year 2000, sickness absence was 2.93% of total available days and the company is confident that the target for the year will be achieved. As a benchmark, AWE plc cites the norm of 3.7% for industry in general, quoted by the Confederation of British Industry.
64. AWE plc's strategy for reducing absence through sickness has two main thrusts. Firstly, it carries out trend analysis for sickness absence, using sickness absence report forms completed by employees and their line managers, coupled with the findings of health-related SRI investigations where relevant. Such analysis is used to prioritise collective preventive action such as improved working practices, working conditions, workplace precautions and targeted advice or information campaigns. Examples of such campaigns are: a recent healthy heart initiative; a planned one-day event for all AWE plc employees on ergonomics and back-injury prevention, to coincide with the European Week of Health and Safety later this year; an ongoing programme of Stress Awareness Workshops.
65. Secondly, intervention at the individual employee level for every sickness absence is designed to ensure that employees are fit to resume their normal duties or are given revised duties that make allowances for any consequent incapacity, with the aim of minimising future sickness absence.
66. Health and safety have been managed successfully during the change of contractor, operator, and licensee. AWE plc has made a sound start to safety management under the new contract: it has maintained the good safety culture it inherited and has begun to seek improvements to it.
67. During the lead-in process before the new contract, AWE plc identified the majority of the safety issues that require addressing: it has since shown enthusiasm in making and implementing plans to manage the consequent tasks. Some of the key safety issues relate to long-standing waste and decommissioning concerns that will not be resolved in the short term. It will therefore be necessary to monitor agreed long-term programmes carefully to ensure that no slippages occur.
68. In addition, AWE plc has continued several reviews that were begun under the previous licensee which are intended to improve safety performance.
69. Safety-related changes are to be expected under the new operator. As yet, the pace of change is slow. There is no evidence that safety has been adversely affected, and no reason to suppose that safety will not be properly taken into account in future proposals for change.
Added to HSE Web Site 31 July 2000