Executive summary
Date(s) of inspection:
- December 2023
Aim of inspection
Undertake a compliance inspection against any duty imposed by articles 8 to 22 or by regulations made under article 24 of the Regulatory Reform (Fire Safety) Order 2005.
Seek assurance that the Licensee’s arrangements associated with all applicable articles are suitable and adequate, and that the licensee is working to those arrangements.
Follow-up on Regulatory Issue 11145 related to the maintenance and the functionality of fire doors in building D34.
Subject(s) of inspection
- Confined Spaces – Rating: Green
- Construction Fire Safety – Rating: Green
- Fire (Life Safety) Compliance Inspection – Rating: Green
- Fire Risk Assessments – Rating: Green
- Fire Safety Strategies – Rating: Green
- Regulatory Enforcement – Life Fire Safety – Rating: Amber
- Regulatory Reform (Fire Safety) Order 2005 – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This inspection assessed BAE Systems Marine Ltd’s (BAESML) arrangements to support Life Fire Safety (LFS) and sampled the implementation of those measures on site. Compliance was assessed using relevant Office for Nuclear Regulation (ONR) inspection guidance, specifically Technical Inspection Guide (TIG) NS-INSP-GD-073 Issue 2 – The Regulation of Life Fire Safety Provision on GB Nuclear Sites. The inspection consisted of examination of the licensee’s arrangements regarding LFS covering the Devonshire Dock Hall (DDH) complex (including boats currently in build), meetings to assess the implementation and management of LFS at a site level and walkdowns of the DDH and construction areas. This intervention was undertaken by two inspectors from the Office for Nuclear Regulation’s (ONR) Nuclear Internal Hazards & Site Safety (NIHSS) specialism and the Nominated Site Inspector.
It was noted that the Fire Risk Assessments (FRA) sampled as part of the inspection were of an adequate quality and level of rigor with a clear focus on driving improvements. The hot works permitting process and associated controls were inspected and found to be adequate. A Vessel Fire Safety Officer (VFSO) was questioned on the hot works process and their responsibilities. The VFSO was able to answer all questions and confirmed the implementation of controls discussed with fire safety managers.
An existing Regulatory Issue (RI) – 11145 was in place for the DDH on adequate installation, inspection, maintenance and testing of fire doors. Fire doors were tested during a walkdown of DDH and found to be incorrectly installed such that they would not fully close in all configurations. RI-11145 has therefore been kept open and the RAG status of the issue changed to amber (from green). It was noted during the inspection that the tenant organisation on site has ultimate responsibility for building wide assets such as fire doors. An additional action has therefore been attached to RI-11145 to understand any potential blockers to closing out the programme of improvements to the fire doors.
During the walkdown of DDH several accumulations of combustibles were noted as well as the consolidation of laydown spaces to form a large area of combustible loading. Additionally, it was noted that plastic brick guards were present throughout the facility despite a recommendation being raised within the building FRA to either remove them or justify their use. A Level 4 (lowest level) Regulatory Issue has therefore been raised on the control of combustibles within DDH.
Conclusion
Based on the evidence provided by BAESML and observed on the day of the inspection, I consider that generally BAESML have an adequate process in place for the control and management of fire safety with respect to life safety. I judge that the FRAs received are of an adequate quality and level of rigour and demonstrate a desire to drive continuous improvement through the raising of recommendations. Additionally, the hot works permitting process and use of VFSOs appears to provide an adequate means of controlling the specific fire risks associated with hot working. It is my judgement that BAESML has a potential weakness in ensuring recommendations are suitably closed out once raised, and this may be hampered by the landlord-tenant arrangement particularly with respect to building wide issues (such as fire doors). RI-11145 will be kept open to gain further evidence that fire doors are suitably installed, tested and maintained with the RAG rating moved to Amber. The issue will remain at Level 4 however, an additional action will be added to track any potential blockers which may arise with respect to the landlord organisation.
Based on the evidence seen, I judge that there is a lack of suitable controls on the control of combustibles. A Level 4 regulatory issue will therefore be raised on the control of combustibles within DDH.
Despite some minor contraventions and areas where further evidence has been requested, I consider that overall BAESML has demonstrated adequate arrangements with respect to fire safety. An ONR inspection rating of Green “No Formal Action” is therefore appropriate.