Office for Nuclear Regulation

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Effectiveness of the Independent Nuclear Assurance (INA) Function at RRDL

Executive summary

Purpose of Intervention

This intervention was to sample the effectiveness of the Independent Nuclear Assurance (INA) function at Rosyth Royal Dockyard Limited (RRDL), which was undertaken in accordance with ONR's regulatory strategy for the Propulsion sites.

The intervention considered RRDL's 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.

Interventions Carried Out by ONR

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

This intervention was carried out through a series of structured discussions with key personnel from the Nuclear Assurance, Operational and Programme Delivery functions, which included relevant senior staff and the Chair of the Procedure Authorisation Group (PAG).

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a Safety System Inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

We observed a positive safety culture within RRDL with visible leadership who appeared to promote a culture where areas of concern can be raised; with the clear expectation the concerns will be addressed in a timely manner.

However, we found only limited evidence of an Independent Nuclear Assurance (INA) capability within RRDL.

We also found no evidence of the mechanism of assurance, such as a forward assurance plan, surveillance plans, graded approach to categorising findings, ability to capture and actively track findings, the provision of compelling advice and the ability to confirm that the desired outcomes have been achieved.

RRDL need to clearly define the appropriate assurance arrangements that are proportionate to the risk / hazard of the work undertaken by RRDL; both now and in the future. This should be informed by relevant guidance and an understanding of how other duty holders approach assurance with similar challenges.

Once an appropriate assurance model has been defined for RRDL, then this needs to be supported by an implementation plan to establish robust INA arrangements, which are adequate for the risk / hazard of the nuclear work at RRDL.

Conclusion of Intervention

We consider the effectiveness of the Independent Nuclear Assurance function in providing assurance and advice to the RRDL management board as Amber. There are only limited arrangements in place currently and a lack of clearly defined accountability for assurance activities. We will raise a level 3 Regulatory Issue which will be monitored over the coming year, with a follow up inspection in 12 months.