The purpose of this inspection was to provide regulatory confidence in the management of Conventional Health and Safety (CHS) hazards present during the Sizewell B (SZB) statutory/refuelling outage, including monitoring of work at height activities and management of risks associated with the Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR). This is in line with the inspection programme contained in ONR’s Operational Facilities Division intervention strategy 2019-20.
ONR has identified a number of priority conventional health and safety topics/activities to be covered during inspection activities. Work at height risk is a priority topic in the strategy. This was one of the key topics of focus during the intervention, along with examination of Sizewell B’s compliance with DSEAR, following the discovery of issues with compliance with these regulations on other NGL sites.
As a specialist inspector in conventional safety, accompanied by a colleague of the same specialism, I undertook a three day inspection. This included discussions with key staff, including management and safety representatives, observations of work at height, and examinations of arrangements for compliance with DSEAR, following issues found at other NGL sites. A further purpose was site familiarisation for Conventional Health & Safety Inspectors new to SZB.
Overall it was a positive exercise and much of the work at height examined was well controlled. I looked in detail at examples of rope access work and scaffolding work. I also observed whether workers were abiding by rules with regards to dropped objects and found no discrepancies. However there was some Work at Height issues:
I met with station DSEAR co-ordinators to discuss progress with the new NGL DSEAR risk assessment process that had been introduced fleet wide. They were able to show the new document to the Inspector and how they had arrived at their conclusions. They also explained the current status of the programme for removal of equipment that does not have the correct protection rating (and are therefore potential sources of ignition) from within zones designated to have the potential for an explosive atmosphere. They were able to give me a satisfactory breakdown of their priorities, what was being removed in this outage, what would remain and how this was to be monitored.
TU representatives were positive about their engagement with management over safety, but they did share some issues. They felt that there was an overreliance on some work teams to almost rewrite risks assessments in their ‘Time Off for Personal Safety’ assessment (TOPS assessment). Related to this, we discussed whether jobs were walked down during the planning risk/assessment stage and Inspectors were told that this was not always the case. Finally, they told us that some workers do not have the confidence to challenge supervisors or managers when they perceive a safety issue. We shared these concerns with the Technical & Safety Support Manager.
Many of examples of good standards were seen during the visit in addition to the areas for improvement. NGL Sizewell B industrial safety personnel have clearly put a significant amount of effort into managing CHS hazards present during the outage.
These conclusions were summarised during feedback I provided at the conclusion of the visit, and we agreed improvement actions for the station, particularly in relation to management of work at heights. A regulatory issue (7923) has been added to the ONR Regulatory database, related to the improved planning and risk assessment of the work at height. This will be subject to follow-up and ONR’s governance processes.
These issues aside, health and safety management standards were good in general. Therefore, an inspection rating of ‘Green – no formal action’ was applied to this intervention.