Office for Nuclear Regulation

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Barrow - Ionising Radiations Regulations 2017 and LMFS intervention

Executive summary

Purpose of Intervention

This intervention was conducted at the BAE Systems Marine site at Barrow-in-Furness and covered both the licensed and authorised sites within the Devonshire Dock Complex. It was undertaken as part of the 2019/20 intervention plan and propulsion sub-division strategy.

This was a joint inspection with inspectors of the Defence Nuclear Safety Regulator who are responsible for the through life safety of the nuclear plant. DNSR’s findings are reported separately.  ONR and DNSR invited BAESM Independent Nuclear Assurance Inspectors to join the inspection to support continued development of this important function.

Interventions Carried Out by ONR

This Intervention combined:

The team targeted arrangements for:

During the inspection we held discussions with personnel from senior management through to operational levels. We sampled relevant documentation and inspected areas primarily around the Devonshire Dock Complex and Devonshire Dock Hall, to see how the arrangements are applied at the point of work. We assessed compliance against:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

There were a number of areas of relevant good practice observed including:

A number of opportunities for improvement were identified during the inspection and have been recorded as regulatory observations and shared with the licensee. The main observation was:

In response to this observation a single Level 4 Regulatory Issue is raised for the licensee:  

A number of minor shortfalls were identified e.g. the control of information in relation to ‘plan of the day’ meetings and occupational health and hygiene assessments, and opportunities being missed for learning post job.

The shortfalls observed during ‘plan of the day’ meetings included a lack of transparency related to amendment/removal/addition of planned tasks; making de-confliction of tasks difficult and reducing the duty holders’ ability to trace back if required. We did observe good examples of challenge during the meetings, but this was not consistent.  

Current occupational health assessments take a ‘broad-brush’ approach, which is not necessarily tailored to the individual’s role or exposure profile. Radiation workers are subject to hand arm vibration (HAV) questions, although there are no HAV exposures in this population. BAESM is currently reviewing their occupational health assessment processes with their contract occupational health service, and this is an area where resource could be more focused.

There was little or no evidence of any reflection analysis post job to capture learning. This was particularly apparent with respect to lifts and lifting operations. BAESM should apply the principles of review, learn and improve to obtain learning at the end of work packages/tasks.

ONR maintains oversight of improvements through the site improvement plan. ONR Regulatory Issues will be updated to reflect the findings from this inspection, and a new level 4 issue will be created as described earlier. 

Conclusion of Intervention

Based on the sampling undertaken during the intervention I am satisfied that in general the licensee has in place adequate arrangements under Licence Condition 26 Control and Supervision of Operations, The Health & Safety at Work etc., Act 1974 and Relevant Statutory Provisions including IRR17. I therefore assign a rating of Green (no formal action) to this intervention.