To undertake a three day ONR/HSE intervention examining the arrangements Babcock Marine and Technology (Babcock) has in place at its Devonport Royal Dockyard Ltd site to manage working at height activities across said site, both within and outside the Licensed Site Boundary (regulated respectively between ONR and HSE).
One of ONR’s key strategic themes is influencing improvements in nuclear safety and security. The Cross ONR Programme strategic direction for 2015-2020 delivers its contribution to this theme by providing coherent support and advice to other ONR regulatory programmes in conventional safety. In addition, the ONR Conventional Health & Safety (CHS) team sub-programme strategy has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. ‘Working at Height’ is one such activity.
DRDL has reported a number of working at height accidents in recent years, two such events in 2014 and 2015 respectively, both of which resulted in serious injury, ONR investigations and enforcement action by way of letter. Furthermore, HSE served an Improvement Notice on DRDL for inadequate working at height arrangements on a cooling tower in 2014. As such, this intervention further supports ONR’s focus on work at height activities at this site.
Due to the nature of the work undertaken at DRDL on ships, vessels and across the yard facilities and infrastructure, it is estimated that hundreds of people, including employees and those not in the employments of DRDL or Babcock, regularly undertake work at (or access to) height - further supporting the importance of this planned intervention.
The key regulatory activities undertaken during the three day intervention were based around:
Walkdowns of a number of DRDL locations were undertaken throughout the intervention during which ONR and HSE focussed on the key performance indicators (KPIs) identified at the intervention-planning stage. As working at height interfaces with a variety of other hazards, the visit inspections also took into account a number of other conventional health and safety topics such as noise-induced hearing loss, factors influencing human performance, control & supervision of work; and management of contractors. Consequently, the intervention enabled insight into a number of elements of working at height management rather than being a detailed drill-down inspection of one particular element. The inspection also provided an opportunity to verify action taken (and continuing to be taken) by DRDL following two falls from ladders on V and T class vessels resulting in major injury.
Regulatory judgement was based on determining compliance with sections 2 & 3 of the Health & Safety at Work etc Act 1974 and relevant statutory provisions made under the Act. A number of key relevant statutory provisions were referred to during the visit, including:
Work at Height Regulations 2005 (as amended), Management of Health & Safety at Work Regulations 1999, Construction (Design & Management) Regulations 2015; Lifting Operations and Lifting Equipment Regulations (LOLER) 1998 and the Provision and Use of Work Equipment Regulations (PUWER) 1998.
A number of areas of good or best practice were seen during the visit in addition to areas for improvement. These were summarised during feedback provided at the conclusion of the visit, as were the visit outcomes/actions required by DRDL.
Areas of good or best practice seen during the visit included:
The formation of a Working at Height Strategic Group and a Working at Height Working Group – the latter of which was interviewed and shows good direction and clear commitment with engaged TU representation.
Numerous examples of facility-driven improvements such as DDF loading bay area edge protection, the J-clamp system for flat-bed trailers, the re-organised and improved FRC stores areas.
The GOTCHA and other rescue arrangements in place, including the arrangements for storing and issuing the equipment; and training of users.
The MEWP working group and the ’21 Operating standards’ now in place following a fatal accident at a nearby refuse facility; and the improved MEWP guarding standards in place following a MEWP fatal incident on site.
DRDL’s ongoing stakeholder engagement with MoD in respect of MoD-owned Portable Specialist Site Equipment [PSSE] used by DRDL at Devonport.
Fixed ladder risk profiling methodology and work undertaken by the Cross Site Services team.
Areas requiring improvement included (in order of priority):
The overall impression gained from the inspection was a variable one.
DRDL now appear to have a better understanding of the risks presented by work at (and access to) height activities across their site – an understanding that has been accelerated by events involving working at height in previous years and subsequent enforcement action taken by both HSE (Improvement Notice) and ONR (letter) between 2014-2015. As a result DRDL have invested, and continue to invest, a substantial amount of effort and resource into developing, improving and implementing management arrangements and risk-control arrangements for staff and contractors working at height. Particularly impressive was that many of the improvements are being driven bottom-up from individual facilities, for which front-line teams are to be commended. There is also excellent TU engagement in ongoing improvements.
However, progress in this area has been slower than expected; and ONR and HSE agree with DRDL that there is still a long way to go until arrangements meet good practice across all areas of work at height. A number of priority actions were identified during the inspection, such that control was not always being achieved and in a number of cases compliance with legislative requirements was not currently being met. In such cases, the site committed to take action to rectify the deficiencies identified.
ONR and HSE will continue to work with DRDL regarding the priority actions, with progress against the remaining areas for improvement being monitored via discussion/follow up visits with the site. As such, and in agreement with all inspectors present during the inspection, a post-visit CHS rating of ‘amber – below standard’ is regarded as appropriate. The final report and letter to DRDL will also summarise the primary observations made against the KPIs and conventional H&S topics covered during the intervention. Issues will then be added to the ONR Regulatory Issues database for tracking purposes.