Office for Nuclear Regulation

Working at height (WAH) activities, and conventional health and safety follow-up

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation (ONR) Strategy, each year ONR performs a series of planned interventions at nuclear licensed sites. This intervention forms part of ONR’s 2020/2021 Integrated Intervention Strategy (IIS) for DRDL.

The purpose of this intervention was for ONR to examine the adequacy of the arrangements that Babcock Marine & Technology (Babcock) has in place to manage its working at height (WAH) activities at its Devonport Royal Dockyard Ltd (DRDL) licensed site. There was a long-standing open ONR Level 3 Regulatory Issue (RI) for improvement on WAH arrangements at DRDL, the inspectors also sought evidence to close out the actions outlined within the RI. In addition, the intervention included a follow-up on an incident involving use of ladders on a vessel, and the inspectors made further inquiries on a schedule of conventional health and safety (CHS) shortfalls (Annex A) raised by the recent Periodic Review of Safety (PRS) at 15 Dock.

Interventions Carried Out by ONR

This two-day intervention was carried out by two ONR Nuclear Internal Hazards and Site Safety (NIHSS) specialist inspectors on 30 and 31 March. I had prepared an agenda for the intervention and shared with DRDL prior to the intervention (CM9 reference 2021/33277). During the intervention, the inspectors strictly adhered with control measures outlined within ONR-GEN-GD-022 (Visit to licensee and other duty-holder premises and other relevant locations during the COVID-19 pandemic) and the local COVID-secure control measures at DRDL.

The intervention comprised of discussions with DRDL staff, contractors working on site and Trade Union Safety Representatives, site walk-downs on a number of DRDL locations accompanied by DRDL staff, and sampling of associated records.

Regulatory advise and judgement were based on determining compliance with Sections 2 and 3 of the Health and Safety at Work etc Act 1974 and the relevant statutory provisions made under the Act, including Work at Height Regulations 2005, Management of Health and Safety at Work Regulations 1999, Confined Space Regulations 1997. I also consulted the relevant good practice such as the selection, management and use of mobile elevating work platforms (MEWPs) (HSE General Information Sheet No. 6) and the code of practice on safe use of MEWPs (BS 8460:2017) on a specific work activity involving using a MEWP as access to a flat roof that I had observed during the intervention.

For the inspection ratings I referred to the ONR General Inspection Guidance (ONR-INSP-GD-064).  

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

I considered that the sample size on WAH activities on this intervention to be limited, which meant the I was unable to get a true picture of how DRDL managed the WAH activities on the licensed site.

I identified the following areas of good practice:

I identified the following areas of shortfalls:

I provided regulatory advice on:

Whilst I was on site, I observed and followed the COVID-19 workplace control measures that DRDL had put in place, including testing regime, COVID Marshalls, hand-sanitising stations at the entrance of workplace and buildings, social distancing. Whilst I did not scrutinise the overall arrangements on COVID-19 as it was not part of the agenda for this intervention, based on my observations, I considered the measures that DRDL had put in place was adequate.

My regulatory advices and findings were shared with, acknowledged, and accepted by key DRDL staff involved in the intervention. DRDL was content with the outcomes of this intervention.

Conclusion of Intervention

From the evidence I sampled during this intervention, I identified a number of shortfalls in DRDL’s practice against the relevant good practice when working at height. In addition, DRDL did not make sufficient progress to address the actions outlined in the existing ONR Level 3 RI 5296. As a result, I judged that an inspection rating of ‘Amber’ (seek improvement) was merited for DRDL’s arrangements in managing working at height activities on the licensed site, and the Level 3 RI would remain in place.

There is a ‘Holding to Account’ meeting between ONR and DRDL on 20 April, where the lack of work control that I observed during this intervention will be raised. Furthermore, ONR will write to DRDL on the matters of control and monitoring for WAH activities. DRDL’s response will be reviewed, and ONR will consider further enforcement action should the response was deemed to be inadequate.

From the evidence I sampled during this intervention, I was satisfied that the CHS shortfalls schedule (Annex A) raised by the 15 Dock PRS, in particular the nine high risk items that had potential to create risk of serious personal injury or ill-health (ROSPI), have either been addressed or were incorrectly categorised. As a result, I judged the follow-up on Annex A of the 15 Dock PRS merited a ‘Green’ (no formal action) rating.