This intervention was to sample the effectiveness of the Independent Nuclear Assurance (INA) function at BAE Systems Marine Limited (BAESML), Barrow-in-Furness Site, which was undertaken in accordance with ONR's developing regulatory strategy for the Barrow site.
The intervention considered BAESML organisational capability and capacity within the INA function; its independence to be able to raise issues of concern with senior level staff; the adequacy of advice given and timely response to findings; and to broadly assess the cultural acceptance of challenge within the organisation and the remit/mandate of the function.
Inspections are carried out against ONR's published guidance requirements, as described in the technical inspection guides, which can be found at Office for Nuclear Regulation (ONR) Compliance inspection - Technical inspection guides. This inspection was primarily conducted using the following guide: Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the Provision of Nuclear Safety Advice, NS-TAST-GD-080 - Rev 2, Further information on Integrated Intervention Strategy (IIS) ratings, is available at http://www.onr.org.uk/intervention-records/onr-inspection-rating-guide.pdf
This intervention was carried out through a series of structured discussions with key personnel from the Nuclear Safety and Security Directorate and the Business Integration Directorate, which included relevant Directors, Senior Operations, Chairs of key Authorisation Groups, Front-line Delivery and the INA functional line. The intervention also included a sample observation of an on going INA inspection and review of the Terms of Reference for a series of Safety Committees / Authorisation Groups in BAESML.
This was not a Safety System Inspection.
I found the capability of the INA function had notably improved since the last inspection, appropriately 18 months ago. There is new Senior Engineering Manager leading the INA team who has the appropriate level of understanding of an effective INA function. The team capability has been strengthened and the inspection arrangements revisited, with the introduction of a more targeted multi-year inspection plan, surveillance plans, competency assessment framework and enhanced reporting.
Although the INA function has a good range of planned inspections, I observed a general lack of awareness of the full scope of the INA function within the various levels across the organisation. The general view appeared to be the INA function were there to help maintain BAESMLs legal obligations, rather than the broader role of independent assurance, challenge, advice and contributing to a continuous improvement culture.
I also found a notable number of agreed actions from INA inspections were overdue. I acknowledge this situation is exacerbated by the current IT limitations. However, I am concerned with the ownership of actions in response to INA inspection findings, their timely closure and the confirmation that the actions are having the required impact.
I consider the effectiveness of the Independent Nuclear Assurance function in providing assurance and advice to the BAESML Board as Amber. There is a lack of a clear mandate for the Independent Nuclear Assurance (INA) function from the Executive Team, which has led to a limited understanding of the full role of the function across the organisation which in turn limits the efficiency and effectiveness of INA interventions therefore the potential safety benefit. This may also be a contributing factor to the number of overdue actions in response to INA findings. I have raised a level 3 Regulatory Issue which will be monitored over the coming year, with a follow up inspection in 12 months.