Office for Nuclear Regulation

Remote compliance inspection of site licence conditions 10 Training and 12 SQEP and DAP

Executive summary

Purpose of Intervention

This inspection focussed on the implementation of BAE Systems Marine Ltd. (BAESML) arrangements for compliance with Licence Condition 10 (Training), Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons). This inspection formed part of ONR’s Integrated Intervention Strategy for 2020/21.

BAESML have been improving their arrangements for Licence condition 10 and 12 in response to previous ONR findings (with Regulatory Issues (RI) 7849 and 8398 tracking progress).  Through 2020, the programme of improvements has been delayed and BAESML have been reliant on temporary arrangements for a period beyond that originally expected.  The purpose of this inspection was to gain confidence that that at the current time, the expectations of LC 10 and 12 are being met and to confirm that BAESML have a clear understanding of the arrangements they are making and a clear plan for their implementation.

Interventions Carried Out by ONR

During the inspection, we gained evidence of how BAESML manage the training and competence of individuals whose role is necessary for nuclear safety.  We gained evidence as to how changes to roles are managed and tracked, to enable BAESML to demonstrate the competence of those on the nuclear baseline.  We also gained evidence as to the improvements that BAESML are making to their LC 10 and 12 arrangements and the programme for the delivery of these improvements. 

We inspected role profiles for individuals within the test and commissioning capability.

We inspected the nuclear baseline records for the primary build team and for the test and commissioning team.

We explored how changes to the nuclear baseline are managed and tracked and using examples (a senior manager in the primary build team and a commissioning engineer from within the test and commissioning team).

We explored how the processes to develop and manage the corporate role profiles (managed by the HR team) and the processes to develop and manage the nuclear baseline competencies (managed by the Nuclear Discipline Skills & Capability (NDSC)) combine to ensure that the totality of roles required to control and deliver nuclear safety requirements are identified.

We inspected the functionality that will be provided by the new SuccessFactors software package.

We explored progress against the programmes for RI 7849 and RI 8398, to ensure that a clear picture exists for how the changes will improve compliance against licence condition 10 and 12.

Explanation of Judgement if Safety System Not Judged to be Adequate

NOT APPLICABLE THIS WAS NOT A SYSTEM BASED INSPECTION

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

We found that BAESML hold adequate information and records to demonstrate that individuals, whose role has nuclear safety importance, are competent.  We gained confidence that BAESML can make and track changes to the nuclear baseline using forms and spreadsheets and gained confidence that individuals and functions are involved in maintaining their competence through review.  We judged that BAESML have adequate information relating to competence to inform operational readiness reviews, prior to commencing a new build stage.

With respect to the stability of the competence management system, we judged that there is an over reliance on the use of spreadsheets and key individuals to maintain them.  We also found that the way that the HR function manages the corporate aspects of the role profile and the NDSC team the nuclear baseline aspects introduces complexity.  Whilst not a barrier to compliance, we considered that this complexity increases the potential for important competencies (e.g. supervisory or leadership) to be omitted from role profiles or assigned at incorrect competence levels. We judged that the current competency management arrangements are likely to be vulnerable to human error or key individuals leaving their role.

In relation to visibility, we identified that there is a disconnect between the written arrangements and those described to be in place.  We also found that that individuals and line managers are unable to understand the totality or status of the competency requirements of their roles, or that of their teams, without contacting the NDSC team.  We judged that it is currently difficult for the wider business to understand the competency management arrangements.

We also gained evidence that the current arrangements for appointing DAPs do not adequately test knowledge prior to appointment.  We judged that this increases the probability that DAPs are appointed without adequate knowledge of the safety case for which they are responsible. 

BAESML are making improvements in this area (with RI 7849 and RI 8398 tracking progress).  During the inspection, we gained confidence that positive work has been undertaken to address the identified gaps identified in the LC 10 and 12 arrangements.  We also gained confidence that the implementation of a new competency management software system (SuccessFactors), will reduce the reliance on spreadsheets and the manual manipulation of data.  However, the software migration project is delayed, due to unforeseen complexity.  Additionally, BAESML did not adequately articulate the arrangements they are moving to or provide a realistic programme for how they will achieve it. 

Conclusion of Intervention

We judged that whilst there are improvements required in the stability and visibility of the training and competence arrangements, there was no specific risk relating to the nuclear safety of operations underway or planned.  The inspection team identified the importance of the operational readiness review process, in providing assurance that individuals undertaking nuclear safety important roles are competent to do so. 

The improvements to the arrangements are important.  Without them there is an increased risk that BAESML are unable to adequately manage the training and competency of those in nuclear safety important roles for the long term.  This introduces the potential that BAESML are unable to proactively identify and manage challenges to the baseline to ensure nuclear safety is not compromised.  As such, we rated the implementation of the arrangements for compliance with the licence conditions as follows:

The inspection team concluded that the existing regulatory issues 7849 and 8398 adequately cover the issues identified during this inspection, and as such it is not necessary or advantageous to raise further regulatory issues at this time.  However, I have requested continued input from the BAESML INA function and for level 4 interactions in February 2021 to track progress.  I will review the adequacy of the regulatory issues at that time, with a view to reinspection of the arrangements in autumn 2021.