Office for Nuclear Regulation

Control of Substances Hazardous to Health Regulation 2002 (COSHH) Inspection Compliance

Executive summary

Purpose of Intervention

This was a reactive inspection conducted at the BAE Systems Marine Limited Licensed Site in Barrow in Furness on the 22 January 2020.  The purpose was to inspect compliance with Control of Substances Hazardous to Health Regulations 2002 and the Confined Spaces Regulations 1997, in response to reported airborne chemical by-products generated during testing.

Reactive inspections support the wider intervention strategies of both the ‘Nuclear Internal Hazards and Site Safety’ specialism, and the Propulsion Stes sub-division of the Operating Facilities division.

Interventions Carried Out by ONR

An assessment of the BAESML’s arrangements to ensure compliance with the aforementioned legislation was conducted, by reviewing historical and current risk assessments and the systems of work planned for future build, testing and commissioning.  

Explanation of Judgement if Safety System Not Judged to be Adequate


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

BAESML was able to demonstrate that significant work had taken place to identify the source of the chemicals generated during testing.  I reviewed the plans for extraction and air circulation within various compartments, and was satisfied that the measures proposed were appropriate to control personal exposures to substances hazardous to health to well below any relevant Workplace Exposure Levels (WELs), and reduced the risks to as low as reasonable practicable. 

The fixed and personal detection equipment was suitable for foreseeable chemical exposures, and BAESML was able to demonstrate adequate provision, testing and training in the use of control measures, including respiratory protective equipment (RPE). 

The additional controls identified, particularly regarding extraction and air movement within compartments, had the added advantage of reducing the risks arising from thermal stress.  Nevertheless there are opportunities for BAESML to demonstrate a greater level of monitoring for this hazard, particularly in ‘closed boat’ conditions.

Conclusion of Intervention

Overall I was satisfied by the steps taken to control and mitigate risks from chemical exposure and to limit the risks from thermal stress arising from current operations. No further regulatory action is proposed.