Office for Nuclear Regulation

Inspection of Work at Height and Workplace Transport arrangements during statutory outage

Executive summary

Purpose of Intervention

The purpose of this intervention was to provide regulatory confidence in the management of conventional health and safety (CHS) hazards present at EDF Energy Nuclear Generation Limited’s (NGL) Heysham 1 (HYA) power station during its outage.

The ONR CHS strategy has identified several priority CHS topics/activities to be covered during inspection activities. Workplace Transport and Work at Height are recognised as key areas of CHS concern during outage work.  ONR also sought an update on the stations management of lifting equipment following several recent adverse inspection reports received from the independent third-party inspection authority.  

Interventions Carried Out by ONR

The key regulatory activities undertaken during the one-day inspection were:

To provide regulatory confidence in the management of work at height risks present during the HYA outage and compliance with the Work at Height Regulations 2005. The focus was on three areas – planning and supervision of work at height activities, competence of staff carrying out the work and suitability of the equipment used. 

To provide regulatory confidence in the management of workplace transport risks present during the HYA outage and compliance with the relevant parts of the Workplace (Health, Safety and Welfare) Regulations 1992. The focus was the three areas of safe site, safe vehicle and safe driver as set out in HSE publication HSG136 A guide to workplace transport safety.

To discuss the recent adverse inspection reports received by ONR in relation to lifting equipment.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

I sampled work at height activities taking place as part of outage work. I observed good practice taking place in relation to the three focus areas – planning and supervision, competence of staff and suitability of equipment.

I sampled workplace transport activity observing examples of good practice in relation to the three focus areas of safe site, safe vehicle and safe driver.  However, there were matters identified which required station attention. In particular I had concerns around the effectiveness of station arrangements for the thorough examination and maintenance of fork-lift trucks as a relatively new machine had missed its statutory thorough examination as required under the Lifting Operations and Lifting Equipment (LOLER) Regulations 1998.  This machine was taken out of service until such time as the matter could be resolved. There were also several locations on the sites external roadway which had significant potholes which could present a stability risk to some fork-lift trucks. The station agreed to identify these locations via the use of barriers/cones until such time as repairs could be conducted.

During the inspection I also had a meeting with the station LOLER lead person around recent adverse inspection reports received by ONR from the independent third-party inspection authority in relation to station lifting equipment.  He confirmed that NGL are in the process of investigating these events and will provide a copy of their report to ONR within the next month.

During the inspection I made general observations in relation to COVID 19 control measures and found compliance with social distancing requirements, use of face coverings and hand washing.

Conclusion of Intervention

Good standards were seen during the inspection in the key focus area of Work at Height and this was rated Green with no formal action required from ONR.

Matters of concern identified during the inspection in the key focus area of Workplace Transport meant that a rating of Amber was appropriate. I will seek improvement on these matters in line with the ONR Enforcement Management Model (EMM).