Office for Nuclear Regulation

RRSL arrangements for the management of organisational change against its LC36 compliance arrangements

Executive summary

Purpose of Intervention

The purpose of this ONR intervention was to undertake a planned inspection at Rolls-Royce Submarines Ltd (RRSL), Core Design and Manufacture (CDM) Offices, Derby, in accordance with ONR’s Intervention Plan for the regulation of RRSL 2018/19.

Interventions Carried Out by ONR

ONR undertook an intervention to examine RRSL’s application of the Management of Change (MOC) process to organisational change, including a LC36 (Organisational Capability) compliance rating and Enhanced Implementation Monitoring and Control (EIM&C) of the CDM Phase 2 organisational change.

ONR utilised the following guidance during this intervention: ONR Nuclear Safety Technical Assessment Guide (TAG) 048, NS-TAST-GD-048 Rev. 5, ‘Organisational Capability’, ONR Nuclear Safety Technical Assessment Guide (TAG) 065, NS-TAST-GD-065 Rev. 3, ‘Function and Content of the Nuclear Baseline and Organisational Capability’, and ‘Nuclear Baseline and the Management of Organisational Change, A Nuclear Industry Good Practice Guide’, Safety Directors Forum, Issue 3, March 2017.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A – this was not a Safety System inspection.

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

Based on the evidence sampled during this inspection ONR judged that measured against ONR’s expectations for LC36 (Organisational Capability), for the management of  organisational change with respect to LC36 (2) and LC36 (5), the intervention rating is AMBER (seek improvement), with identification of three areas of good practice, five areas for improvement and one Regulatory Issue (Level 3).

The areas of good practice related to: (1) management of the Nuclear Baseline (justification and understanding of the fully capable organisation), (2) Nuclear Baseline vulnerability assessment and management, and (3) plans for organisational learning from the CDM Phase 2 organisational change.

The areas for improvement related to: (1) separation of roles and accountabilities for Change Managers and the organisational change Process Owner, (2) identifying the Design Authority (DA) component of the Nuclear Baseline, (3) addition of a hold-point for the CDM Phase 2 Management of Change (MoC) proposal to address benefits realisation and organisational change learning, (4)  reviewing the Operational Readiness Review (ORR) process for application to organisational change and LC36 compliance, and (5) enhancing the effectiveness of the CDM People Meeting for governance of organisational change.

The Level 3 Regulatory Issue related to: closure of the RRSL Internal Regulator LC36 Inspection (2017) findings (complete the update of documented organisational change arrangements to remove gaps and address shortfalls, deliver training to support SQEP change assessor capabilities and complete updates associated with the Organisational Baseline Statement - OBS).

The review of the CDM Phase 2 MoC implementation conducted by ONR during this intervention has demonstrated that the licensee has exercised adequate control over the management and implementation of the organisational change. Routine regulatory engagement during the remainder of the implementation period will be carried out by ONR.

Conclusion of Intervention

In the opinion of the ONR inspectors, the LC36 arrangements were judged as requiring improvement and further examination will take place as the identified improvements are implemented and reviewed. RRSL should address the gaps in their documented arrangements for management of organisational change, in harmony with ONR TAG 048 (Organisational Capability), to improve the robustness of their organisational change arrangements and deliver improved LC36 compliance.

ONR will undertake a follow-up regulatory engagement in September 2019, to inspect implementation of the CDM Phase 2 organisational change, review progress with closure of the Level 3 Regulatory Issue, engage with the wider RRSL LC36 compliance team (including newly appointed Change Managers) and review lessons learned from the Phase 2 learning exercise. RRSL Board responsibilities for safety and the associated arrangements within the wider company will be a topic for review at a future LC36 intervention.