Executive summary
Date(s) of inspection:
- February 2025
Aim of inspection
- To review the CDM arrangements for the STIM Project to provide regulatory confidence that the CDM roles are being discharged as prescribed in CDM 2015 Regulations.
- To review how NWS are managing contractors to provide regulatory confidence that NWS are complying with License Condition 26 with relation to the STIM Project.
Subject(s) of inspection
- CDM 15 - Rating: GREEN
- LC26 - Control and supervision of operations - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
Prior to the inspection, ONR asked for (and were provided with) the key documents related to CDM compliance – the Pre-Construction Information and Construction Phase plan, along with the arrangements on how NWS comply with CDM 2015.
NWS provided a site tour to familiarise the ONR with the LLWR site and the construction areas.
In order to judge compliance with CDM and LC26 on the inspection, ONR asked NWS to present on the arrangements for complying with CDM and how the CDM Roles were discharged on the Southern Trench Interim Membrane (STIM) Project:
- NWS provided information on the new arrangements for construction projects and CDM compliance, as well as the CDM Advisory Group.
- NWS gave an account of how they were an ‘Intelligent Client’ in fulfilling their CDM Client role and explained how they used a system to ensure responsibilities and accountabilities were assigned and tracked for CDM 2015 and License Conditions.
- As Principal Designer (PD), NWS were able to provide ONR with several examples of where they had addressed risks in the design phase.
- ONR discussed with the Principal Contractor (PC), John Graham Construction Ltd (“Grahams”), how they control the key risks on site. We also had the opportunity to observe the operation of unloading of aggregates from a delivery train on railway sidings. I spoke to the site supervisor about the controls in place for the handover process with the train driver, communication between the vehicles working in the area, pedestrian safety and challenges presented if the train arrives with multiple types of aggregate. The operation was well executed and I did not have any safety concerns.
ONR judged that the management of CDM and LC26 on the construction sites as adequate and rated the inspection as green.
I made 3 observations on issues that required a response related to the future work of the CDM Advisory Group, the frequency of deconfliction meetings between LLWR and the PC and the need for the PC to provide more detail in their risk assessment on communication between vehicles in the train unloading process. NWS provided a response to ONR via email on 3/3/25, adequately addressing my points.
Conclusion
From the discussions on how NWS’s arrangements on managing construction and compliance with CDM 2015 and the Southern Trenches Interim Membrane (STIM) Construction Project team’s demonstration of how CDM is complied with and the work that we sampled on the walk-downs of the railway sidings aggregate unloading site, we judged that the management of CDM and LC26 on these construction as adequate and rated the inspection as green.