This was a planned inspection in line with the ONR Integrated Intervention Strategy (IIS) plan for 2020/21, of HMNB Clyde (Faslane) and SUBFLOT arrangements.
The intervention consisted of a remote compliance inspection against the Ionising Radiations Regulation 2017 (IRR17) arrangements. The inspection focused on areas where:
The inspection sampled the implementation of arrangements for site radiography and supporting procedures relating to radioactive source management, control and supervision of work, designation of areas and co-operation of employers.
During the IRR17 inspection, I held telephone discussions with managers, supervisors and operators from the relevant duty holders to obtain evidence to determine the level of compliance. I sampled relevant documentation and I assessed compliance against:
No matters were identified requiring immediate regulatory attention during the inspection.
I concluded that there were no significant shortfalls identified against Relevant Good Practice (RGP), with respect to Radiological Protection requirements under IRR17.
I did however observe minor shortfalls in relation to a number of regulations and some good practices under IRR17. The minor shortfalls related to radiation risk assessment for site radiography, local rules and contingency plan rehearsals and planning of such rehearsals. I also noted that the duty holders had not completed integration of CAPTEM 04/20 as planned. I will track these to closure via level 4 issues which will be managed through routine level 4 meetings between the duty holder and myself.
Based on the sampling undertaken during the IRR17 remote compliance inspection, I am satisfied that, the duty holders have adequate arrangements for sustained compliance with IRR17.
Therefore, I consider that an inspection rating of Green (no formal action) is merited.