The purpose of this intervention was to provide regulatory confidence in the management of conventional health and safety (CHS) hazards present at Atomic Weapon Establishment’s (AWE) Aldermaston and Burghfield sites (A and B sites). This is in line with the inspection programme contained in ONR’s Operational Facilities Division (OFD) intervention strategy 2018-19.
The ONR CHS strategy has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Management of the risk posed by Asbestos (Enforced under the Control of Asbestos Regulations 2012) is a priority topic within the ONR CHS strategy.
The agenda for the site visit was agreed with AWE in advance of the visit and can be found in TRIM at 2018/0380407. Also, prior to the site based intervention, AWE provided ONR with a range of documentation associated with the Company’s asbestos management arrangements. The documentation is saved in TRIM Folder 4.3.567. Further documentation gained during and after the visit will be scanned and also saved to the TRIM folder.
The key regulatory activities undertaken during the three day inspection were based around:
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: the Management of Health and Safety at Work Regulations 1999, the Control of Asbestos Regulations 2012 and associated the Approved Code of Practice.
AWE gave ONR Inspectors a summary of how they managed the risks from asbestos on site. ONR then examined the overall system that AWE employed to manage risks posed by remaining ACMs on site, how these ACMs are risk assessed and how information on asbestos is shared with workers. ONR visited three site locations to observe ACMs in situ and spoke to the Facilities Managers on the how they managed and monitored their sites and kept records. ONR Inspectors also examined recent Abnormal Events involving asbestos issues.
ONR Inspectors judged that AWE are managing asbestos risks adequately, however there are areas the AWE can improve on and bring this in line with the approved code of practice. Changes to the Asbestos management plan are required to identify how AWE make sure that that the asbestos register is checked and understood before any work starts that has the potential to disturb ACMs. This should include the provision of visual information for maintenance workers and notification of change of use of buildings that contain asbestos. AWE should also improve aspects of the monitoring of the Licensed Removal Contractors that they engage.
In looking at the recent Abnormal Events, ONR focused on a particular event where uncontrolled disturbance of ACMs in A**. Workers drilled into Asbestos Insulating Board without prior knowledge. Exposure was fortunately mitigated by techniques and control measures adopted for the potential for radioactive material; however the incident appears to have highlighted failings in work control and CDM pre-construction information. ONR informed AWE that they are very concerned that this incident occurred and that, depending on the results and the actions that the investigation generates, ONR may also take further action to require improvements in the system.
ONR Inspectors had a meeting with the site Trade Union safety reps to discuss the management of CHS on site. What came from the previous meeting was a concern that some CHS Abnormal Events were not being investigated fully and TU reps were consulted as much as they should be – these were still concerns. ONR told union reps that that new investigation system should solve many of their concerns; but ONR CHS inspectors would monitor this and retain a line of communications with TU reps on this issue.
Feedback was provided at a closeout meeting with the ESH Delivery Lead present and the Site Safety and Security Head (at the close of the meeting), as well those AWE staff involved in the intervention. ONR Inspectors shared the opinion that they judged that AWE are managing the risks from asbestos adequately, but also gave a summary of the areas for improvement specified by ONR during the inspection that could improve the risk management system further, as well as raising concern at the recent exposure incident, where further actions may be required. ONR will return to site early in 2019 to inspect licensed asbestos removal and review AWE’s monitoring this work. Feedback was also provided on the on-going concerns shared by the TU safety reps on the way in which investigations of CHS Abnormal Events were being carried out.
These concerns aside, health and safety management standards on the subjects examined were adequate in general. Therefore, an inspection rating of ‘green – acceptable’ should be applied to all parts of the intervention, but Level 4 issue will be raised to track the asbestos management improvements that ONR have asked AWE undertake. ONR’s comments were accepted by the site management team and no objections were raised.