Office for Nuclear Regulation

Planned compliance inspection - work at height, workplace transport and CDM arrangements

Executive summary

Purpose of Intervention

This inspection was one of a series of planned compliance inspection in line with the Conventional Health and Safety (CHS) operational delivery plan for 2018/19.  The purpose of this inspection was to evaluate the effectiveness of DSRL’s management of two key conventional health and safety hazards:  workplace transport and work at height. We also discussed DRSL’s arrangements for compliance with the Construction (Design and Management) Regulations 2015 (CDM).

Interventions Carried Out by ONR

The key regulatory activities undertaken during the two day inspection were based around:

Regulatory judgement was based on determining compliance with sections 2 & 3 of the Health & Safety at Work etc Act 1974 and relevant statutory provisions made under the Act, namely:  The Workplace (Health, Safety and Welfare) Regulations 1992, The Work at Height Regulations 2005 and the Construction (Design and Management) Regulations 2015 (CDM).

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

Work at Height:

ONR examined DSRL’s written procedures for work at height and explored the implementation through discussions with appointed persons for work at height and site walk-downs.  Examples of good practice were identified in relation to the planning and execution of work at height activities however, ONR questioned DSRL’s approach to the identification of fragile roofs/surfaces.  In response, DSRL have reviewed their risk assessment process and, from now on, will be treating all roof as fragile until a competent person has confirmed that they are non-fragile (in line with HSE guidance: Health and safety in roof-work).  Further work will be carried out to update their company standard for work at height and DSRL agreed to complete this work by October 30th.  They also agreed to include a fragile roof check in their work at height sub-permit. 

Workplace Transport:

ONR examined DSRL’s risk assessments for aspects of site transport and undertook site walk-downs to evaluate the effectiveness of control measures.  Examples of legal compliance were noted in respect of risk assessments, driver training, vehicle maintenance and visibility aids.  In addition, the site was organised so that vehicle and pedestrians could circulate in a safe manner, with the provision of pavements, crossing points and site speed limits, as required by the Workplace (Health, Safety and Welfare) Regulations 1992, Regulation 17 and associated approved code of practice and guidance.  However, DSRL need to take action on the lighting upgrades identified as necessary by an independent assessor and improve their site management arrangements to ensure the safety of contractor vehicles brought onto their site.  DRSL agreed a timescale for action in respect of these matters.

 Construction (Design and Management) Regulations 2015:

The main objective of this part of the intervention was to gain an initial insight into DSRL’s  arrangements for complying with CDM.  DRSL is client, PD and PC for a number of small projects of their site and have standard procedures in place, setting out the arrangements for compliance.  A number of construction projects on site were sampled and the CDM arrangements appeared effective.  There was effective flow of information and good liaison between parties however, some of the documentation for the ‘ponds’ project, did not read across to CDM and there appears to be some inconsistencies in approach to CDM between the two projects observed on site.  DRSL has recently appointed a Construction Director and are in the early stages of reviewing their CDM arrangements, moves welcomed by ONR.

Conclusion of Intervention

Feedback was provided at a close out meeting attended by senior managers and those involved in the inspection.  The overall impression left by the inspection was positive.  Where observations were made by ONR during the intervention, these were accepted by DSRL and timely action taken where required.  Overall we deemed that relevant good practice was being met, but some areas for improvement were identified in respect of work at height and workplace transport.  In these cases DSRL committed to taking action and these will be monitored through future routine interactions with ONR.