Office for Nuclear Regulation

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Barrow - Planned compliance inspection - LC 10, 12 and 36

Executive summary

Purpose of Intervention

This inspection focussed on the implementation of BAE’s arrangements for compliance with Licence Condition 10 (Training), Licence Condition 12 (Suitably Qualified and Experienced Personnel) and Licence Condition 36 (Control of Organisational Change).  This inspection formed part of ONR’s Integrated Intervention Strategy for 2019/20.

The purpose of this intervention was to take a strategic view on the adequacy of how the arrangements for these three, people-related licence conditions work together, and to gain assurance that BAE are identifying, managing and tracking the roles, competences, skills and behaviours required for nuclear safety, and are keeping these up to date through the recent organisation restructuring.

Interventions Carried Out by ONR

As previous interventions have focussed on specific nuclear competences to carry out specific activities and judged them to be adequate, this intervention focused on the wider range of competences, skills and leadership behaviours important to safety, and how these are being identified, assessed, tracked and vulnerabilities assessed, as the organisation moves towards new facility construction and new classes of submarines.

During the intervention I gained evidence of the implementation of training and competence requirements, and how the organisation tracks the roles necessary for nuclear safety and that the personnel filling those roles are fully able to do so. I also gained evidence of the tracking and assessment of vulnerabilities arising from BAE’s assessment.

Explanation of Judgement if Safety System Not Judged to be Adequate

NOT APPLICABLE THIS WAS NOT A SYSTEM BASED INSPECTION

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

I judged that the new approach to managing and tracking nuclear safety roles was adequate, was being maintained live, and management information was being provided on vulnerabilities and opportunities to inform strategic workforce planning for the future.  This was evident in that BAE staff were readily able to demonstrate how recent, significant changes to staff reporting chains and team structures had been tracked and implemented effectively.

In the areas of training and competence identification and tracking, I noted that separate systems are in use to track nuclear safety competences, and key competence for nuclear (the latter being the wider BAE system and approach owned by the HR Department).  Whilst I noted that having a two system approach is an acceptable route to compliance, during the inspection I judged that this had presented BAE with challenges in demonstrating the totality of the picture, and in particular being able to highlight any specific expectations (such as in product quality or supervision) for those staff working in nuclear specific roles.

I noted that a change of software system, planned for Summer 2020, provides BAE with an opportunity to verify the current data, validate the requirements and improve their ability to demonstrate the wider competence and training requirements, and generate improved management information to inform future resource planning.

Conclusion of Intervention

I concluded that BAE’s agreement to deliver a programme of actions (linked to the associated regulatory issue) during the transition to the new software system, will improve the demonstration of competence and meet our regulatory expectations.  I agreed with the duty holder that we would hold discussions and maintain oversight of the change to the new system, and seek to re-inspect the implementation of their arrangements for LC 10 and 12 in Autumn 2020.  

I judged that whilst there are improvements required in the demonstration of competence, there was no specific risk relating to the nuclear safety of operations underway or planned, and I noted that other interventions have provided assurance of alternative verification of specific competences for specific operations (known as operational readiness reviews).

I rated the implementation of the arrangements for compliance with the licence conditions as follows: