Executive summary
Date(s) of inspection:
- December 2023
Aim of inspection
The purpose of this Inspection is to sample evidence of implementation of the Sellafield Limited (SL) arrangements for compliance with Licence Condition (LC) 28, The Lifting Operations and Lifting Equipment Regulations (LOLER) 1998, The Provision and Use of Work Equipment Regulations (PUWER) 1998 and The Management of the Health and Safety at Work Regulations 1999, specifically within the B13 at the Sellafield site in West Cumbria, to inform a regulatory judgement regarding the dutyholders’ compliance with its legal duties.
This inspection follows two recent lifting events that were reported to ONR (INF-3230 and INF-3452).
Subject(s) of inspection
- Health & Safety at Work Act – Rating: Not rated
- LC 28 – Examination, inspection, maintenance and testing – Rating: Not rated
- Lifting / LOLER – Rating: Amber
- MHSWR – Rating: Amber
- Provision and Use of Work Equipment Regulations 1998 (PUWER) – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
This was a reactive inspection following two recent lifting events that were reported to ONR (INF-3230 and INF-3452) associated with manual lifting equipment.
The aim of the inspection was to inform a regulatory judgement regarding the dutyholder’s compliance with Licence Condition (LC) 28, The Lifting Operations and Lifting Equipment Regulations (LOLER) 1998, The Provision and Use of Work Equipment Regulations (PUWER) 1998 and The Management of the Health and Safety at Work Regulations 1999, specifically within the B13 at the Sellafield site in West Cumbria.
Licence Condition 28
The Lifting Equipment Regulations (LOLER) 1998
The Management of the Health and Safety at Work regulations 1999 – Regulation 3 – Risk assessment.
PUWER – Regulation 4 – Suitability of work equipment
PUWER – Regulation 5 – Maintenance.
I identified deficiencies regarding the adequacy of risk assessments, suitability of manual lifting equipment and adequacy of maintenance. The risk assessments did not identify key risks associated with manual lifting activities or a broader consideration of the suitability of equipment and the associated maintenance. The deficiencies were associated with risks to workers and not on equipment or activities associated with nuclear safety and the nuclear safety case.
The dutyholder self-imposed a cessation of all manual lifting activities in response to the second event. Therefore, in my opinion, there is not a current Risk of Serious Personal Injury (RoSPI).
Conclusion
Adequacy of Risk Assessment
In my opinion, in both events, the risk assessments were not suitable and sufficient as they did not fully identify the risks associated the equipment and activity. The risk assessment for the MSM operation did not fully identify key risks associated with the activity such as the high probability of a snagged load leading to a potential dropped load. The risk assessment for the lifting hoist did not identify failure of the hoist due to inadequate design or construction and the associated maintenance required to ensure people were not put at risk.
Suitability of Equipment
Adequate risk assessments would have led to broader consideration of whether the lifting beam (INF-3230) and lifting hoist (INF-3452) were suitably constructed for the purpose for which they were used and whether the equipment was suitable for the stated purpose given the risks to people.
In my opinion, for INF-3230, the cross travel lifting beam and chain block used for the removal of MSM’s and the associated instructions, were not suitable for the purpose of removing a MSM. There are limited operator aids such as load cells and there was also limited detail within the instructions regarding the risk of a snagged load and the potential consequences. The deviation from the original design intent, in terms of the number of supports to the C-beam from the main wall, increased the probability of the lifting beam coming loose from the C-beam.
In my opinion, for INF-3452, the configuration of the lifting hoist was not suitable for the purpose of lifting, as there was a clear failure mode which had not been identified in the risk assessment and protected against with a design change or alternatively with adequate preventative maintenance.
Lifting Equipment – Nuclear Safety Case
The sample of equipment that is formally claimed in the nuclear safety case, the 60T Anderson Grice, provided assurance of adequate maintenance and instructions associated with the arrangements for Licence Condition 28 and Licence Condition 24 respectively. In my opinion, the nuclear safety case arrangements duplicate the requirements of The Management of Health and Safety at Work Regulations 1999 (Regulation 3) and Provision and Use of Work Equipment Regulations 1998 (Regulations 4 and 5) regarding risk assessment, suitability of equipment and risk-derived maintenance. Therefore, I am satisfied that the deficiencies identified with manual lifting equipment do not extend to equipment that is formally claimed in the nuclear safety case.
NNL Arrangements for Introduction of New Equipment
In my opinion, the arrangements for the introduction of new equipment, as described by NNL, are consistent with relevant good practice and their description also included assessments of compliance against Provision and Use of Work Equipment Regulations 1998. Therefore, I am satisfied that the deficiencies associated with legacy equipment, do not extend to newly procured equipment.
NNL Arrangements for Safe System of Work
The NNL arrangements for SSoW are logical and consistent with good practice. However, the implemented arrangements did not lead to the identification of the deficiencies in the risk assessments for the tasks, including the equipment used in the tasks.
Adequacy of Lifting Plans
In my opinion, the deficiencies identified in lift plans are caused by the deficiencies in the risk assessment. There is an implicit assumption that the risk assessments have identified key risks associated with the equipment and activity.
Status of Manual Lifting Operations in B13
NNL investigated the failure of the cross travel lifting beam and self-imposed a cessation of all manual lifting operations following the failure of the lifting hoist. Therefore, in my opinion, there is no immediate serious risk of personal injury from lifting operations.
In my opinion, there are evident deficiencies against the requirements of The Management of Health and Safety at Work Regulations 1999 (Regulation 3) and Provision and Use of Work Equipment Regulations 1998 (Regulations 4 and 5). I support the conservative action of NNL in self-imposing the cessation of all manual lifting operations. I will consider the appropriate enforcement actions and associated corrective actions through application of the ONR Enforcement Management Model.