- Site: Clyde
- IR number: 21-107
- Date: October 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) is the enforcing authority for Health and Safety on HMNB Clyde - Faslane authorised site.
This report relates to a reactive inspection carried out at the base following on from a report of an incident in conjunction with The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013.
The purpose of this inspection was to evaluate the immediate measures put in place by the base to prevent reoccurrence of the incident which related to submarine battery replacement activities and specifically to live electrical working.
Interventions Carried Out by ONR
This inspection was to determine if Babcock International Group and the submarine flotilla has put in place battery replacement health and safety arrangements which address the immediate risks of live electrical working and to sample the implementation of these arrangements with those with responsibilities in discharging them.
This inspection was measured against the requirements of the Management of Health and Safety at Work Regulations 1999 and the Electricity at Work Regulations 1989 (which are both relevant statutory provisions of the Health and Safety at Work Act 1974).
We referred to guidance published by the HSE relevant to live electrical working and relevant to work with batteries to enable ONR to form a judgement on the adequacy of the immediate actions put in place to deal with the risks identified by the incident.
This inspection was rated based on the ONR inspection rating system guidance as explained ONR-INSP-GD-064-ONR ‘Compliance Inspection Guide’. This is available on the ONR external website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
ONR Inspectors reviewed the battery replacement health and safety arrangements, which included the updated risk assessment, introduced since the incident, we judged that this was suitable and sufficient for the activity and appropriately detailed the hazard of live electrical working and the mitigations.
As part of the battery replacement health and safety arrangements, inspectors reviewed the updated work instruction, we judged that this covered the hazards of live electrical working and well-articulated the enhanced roles and responsibilities that have been put in place.
ONR Inspectors reviewed the arrangements introduced by the submarine flotilla to provide enhanced oversight of hazardous activities such as battery replacement on boats and judged that this provides additional controls for this activity.
In making our judgement, ONR Inspectors sampled the key roles and responsibilities identifed in the battery replacement arrangements and spoke to individuals regarding these responsibilities. Those sampled expressed how they had been involved with development of the updated health and safety arrangements which we considered to be good practice.
We judged, from the sample of roles, that individuals were clear on their responsibilities and the necessary cooperation between contractor and ships staff to carry out this activity.
We did identify that the arrangements refer throughout to ensuring the use of competent personnel, however the visibility of competency records to those managing this activity was not readily available, which we judged prevents positive compliance of this aspect of the arrangements.
We noted that these arrangements for battery replacement have only recently been introduced and encouraged the further evolution of these based on feedback from this inspection and practical use of them on the base.
Conclusion of Intervention
This was a targeted inspection with the focus on determining that the dutyholders had dealt with the immediate risks associated with this incident.
I consider that the updated arrangements for battery replacement activities do adequately consider the hazards of live electrical working and a suitable and sufficient risk assessment has been developed.
These arrangements deal with the immediate risks identified following the incident. I recognise that the Babcock International Group and the submarine flotilla internal investigations into this incident are yet to be finalised and further corrective actions will likely be implemented.
I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of GREEN (no formal action required) is merited, and no regulatory issues were identified.