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Oversight of Licence Condition 12 and jurisdictional boundaries at Devonport

  • Date released: 6 March 2026
  • Request number: 202602070
  • Release of information under: FOIA

Information requested

Please provide the following official information:

  1. Records of any requests made by the ONR to the licensee (AtkinsRéalis/Babcock) between 30 September 2025 and 6 February 2026 for the training, qualification, or SQEP records of personnel cited in my disclosure.
  2. Any internal briefing notes, policy advice, or legal guidance produced by the ONR regarding the jurisdictional boundary between the ONR and the DNSR specifically concerning the enforcement of Licence Condition 12 (Competence) on Licensed Nuclear Sites.
  3. The total number of times the ONR has exercised its statutory power to audit contractor SQEP records at the Devonport site during the last 24 months. 

Our response

I confirm that under s.1  of the FOIA, we hold some of the information you have requested. Please see below for a response to each of your questions in turn. 

1. Records of any requests made by the ONR to the licensee (AtkinsRéalis/Babcock) between 30 September 2025 and 6 February 2026 for the training, qualification, or SQEP records of personnel cited in my disclosure.

I confirm that we do not hold this information. Atkins Réalis is not a nuclear site licensee and is not regulated by ONR. If this question is referring to the licensee at Devonport, this is Devonport Royal Dockyard Limited (DRDL) which is owned by Babcock International Group, and we have not made any such requests to DRDL.

2. Any internal briefing notes, policy advice, or legal guidance produced by the ONR regarding the jurisdictional boundary between the ONR and the DNSR specifically concerning the enforcement of Licence Condition 12 (Competence) on Licensed Nuclear Sites.

I confirm that there is no information that references the jurisdictional specifics of Licence Condition 12, or any specific licence condition; they are treated as a collective when documenting the boundaries between ONR and the Defence Nuclear Safety Regulator (DNSR).

I can also confirm that ONR runs training courses for our inspectors on the legal basis for the areas for which we are the enforcing authority; and, we also have written guidance for our inspectors directly involved in the regulation of nuclear, radiological and conventional safety on the Ministry of Defence (MOD) defence-related nuclear sites. This is publicly available on our website: Regulation of Great Britain’s Defence Nuclear Programme.

The Memorandum of Understanding (MOU) between ONR and MOD outlines the relationship in discharging our respective roles and responsibilities for nuclear, radiological and conventional health and safety in respect of the Defence Nuclear Programme. This is available on our website: Memorandum of understanding between ONR and MOD. 

Sitting below the MOU, we have a Letter of Understanding with DNSR that details how the boundaries between our respective regulatory responsibilities are managed in practice. This is available on our website: Letter of understanding between DNSR and ONR[3].

3. The total number of times the ONR has exercised its statutory power to audit contractor SQEP records at the Devonport site during the last 24 months.

The Energy Act Part 3, Section 6 of HSWA and the implied requirements within the standard licence conditions permit ONR to carry out inspection and enforcement activity in relation to organisations that supply facilities or plant and equipment that may affect nuclear safety on a licensed site. ONR has not undertaken any audits or inspections of SQEP records of any such contractor organisations at Devonport in the last 24 months.

In that same period, I can confirm that we have carried out four inspections at Devonport where we have included reviewing the training and/or competence of DRDL licensee personnel. These inspections were focussed on a targeted sample of DRDL personnel associated with the design, maintenance, and operation of dockside cranes.

Further information regarding these inspections can be found on our website:

Exemptions applied

None

Public Interest Test (PIT)

N/A

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