Executive summary
Date(s) of inspection:
- January 2024
Aim of inspection
To undertake a regulatory compliance inspection against all duties imposed by the Fire Safety Order 2005, (Articles 8 to 22), or by regulations made under Article 24, to ensure that the licensee is compliant in respect of the premises.
Assurance that the Licensee’s arrangements associated with all applicable articles are suitable and adequate, and that the licensee is working to those arrangements.
Subject(s) of inspection
- Control of Contractors - Rating: Green
- Fire (Life Safety) Compliance Inspection - Rating: Amber
- Fire Risk Assessments - Rating: Amber
- Fire Safety Strategies - Rating: Amber
- Leadership & Management for Safety - Rating: Amber
- Regulatory Reform (Fire Safety) Order 2005 - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The inspection consisted of assessment of the licensee's arrangements regarding life fire safety (LFS) This inspection assessed Devonport Royal Dockyard Limited’s (DRDL) arrangements to provide suitable fire precautions measures to ensure adequate Life Fire Safety (LFS) across the site, and sampled the implementation of those measures on site. Compliance was assessed using relevant Office for Nuclear Regulation (ONR) inspection guidance, specifically Technical Inspection Guide (TIG) NS-INSP-GD-073 Issue 2 – The Regulation of Life Fire Safety Provision on GB Nuclear Sites.
Following pre-inspection examination and subsequent on-site discussions with the DRDL fire safety inspectors, I found the standard of the fire risk assessments to be adequate, but identified that a significant number of required remedial actions were still outstanding due to apparent lack of ownership for the instigation of remedial measures. Later walk-downs of the targeted buildings confirmed this.
This presented situations where improvements in the arrangements for the control of ignition and fire risk levels in office environments were required to reduce the risks to tolerable levels.
It is my judgement that aspects of the Licensee's administrative arrangements for compliance with the statutory requirements of the Fire Safety Order 2005 are inadequate.
I further conclude and confirm that this inspection identified no matters that may impact significantly on nuclear safety, but noting the ONR guidance on inspection ratings, I determine that an inspection rating of AMBER (formal action required) is merited for this Fire Safety inspection in line with ONR enforcement guidance, which will be followed up with the issue of a Regulatory Issue and meetings with the licensee/duty holder, at an appropriate level.
This judgement was communicated to, and accepted by the site senior managers at the inspection close-out meeting.
This judgement was communicated to, and accepted by the site senior managers at the inspection close-out meeting.
Conclusion
DRDL/Babcock recognises the challenging context of some areas within these facilities, and are committed to managing the risks to life in these locations.
Throughout the inspection, all of those that we had contact with demonstrated a clear focus, support and attention to life fire safety requirements.
Throughout the inspection, all of those that we had contact with demonstrated a clear focus, support and attention to life fire safety requirements.
However, given the number of significant remedial actions identified from the fire risk assessments provided that remain open, and the apparent inability to assess how may similar actions remain unresolved from other FRA's undertaken on site, we were not satisfied that the overall the duty-holders arrangements in relation to the statutory requirements of the Regulatory Reform (Fire Safety) Order 2005 are suitable and adequate, and I have therefore rated the intervention amber - formal action required.
This rating is in line with the established ONR guidance as follows in that there are:
“Significant shortfalls against an identified relevant good practice when compared with appropriate benchmarks.”
“Specific legal requirements not met, but without prejudice to overall nuclear safety, safeguards or security objectives.”
“Significant or systematic failure to implement or meet compliance arrangements.”
“Deficient arrangements for compliance with legal requirements.”
This judgement was communicated at the inspection close-out meeting, but the inspection rating of AMBER was not confirmed to them until 26/01/2024 in order for me to take appropriate advice from the nominated ONR site inspector.
Subsequent to this, the following actions have been taken:
- A Level 3 meeting has been scheduled for 12/02/2024 to identify and discuss any significant shortfalls with the licensee/duty holder.
- The shortfalls have been reviewed against the ONR Enforcement Management Model (EDR - 23/075) which indicates a base enforcement level (BEL) of the issue of an Enforcement Letter.
- A Regulatory Issues Database entry at Level 3 (RI-11878) has been raised to log the enforcement communication and to track progress