Executive summary
Date(s) of inspection:
September 2025
Aim of inspection
To gain confidence that Devonport Royal Dockyard Ltd’s (DRDL's) leadership and management arrangements for the selection and control of contractors are delivering adequate standards of health and safety with regard to activities undertaken by contractors at the licensed nuclear site.
Subject(s) of inspection
- MHSWR - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
Devonport Royal Dockyard Ltd (DRDL) routinely utilises numerous contractor organisations in undertaking extensive construction and operational activities across its nuclear licensed site, and some of these activities are high risk in terms of health and safety. This planned inspection was therefore undertaken by ONR to seek assurance that DRDL's arrangements for the selection and control of contractors are delivering adequate standards of health and safety management in terms of contractor activities. DRDL is also striving to improve its organisational culture. This is an area of interest to ONR because if DRDL's organisational culture is poor, this will undermine health and safety performance. The inspection included discussions with DRDL senior leaders to enable ONR to seek assurance that DRDL's leadership behaviours and attitudes are consistent with the positive organisational culture that they aspire to.
The aim of the inspection was to gain confidence that DRDL’s arrangements for the selection and control of contractors are delivering adequate standards of health and safety at the licensed nuclear site. A particular focus was compliance with Regulation 5 of the Management of Health and Safety at Work Regulations 1999 (MHSW) and the relevant good practice (RGP) in HSE publication HSG65 ‘managing for health and safety’.
The inspection included gathering information regarding:
- The management arrangements in place for the selection and control of contractors.
- The extent to which these arrangements were complied with for the contractor activities sampled.
- The influence of senior leadership on DRDL’s organisational culture around contractor selection and management.
The inspection consisted of:
Pre-inspection engagement to identify key documentation describing DRDL’s arrangements for the selection and control of contractors.
- Review of documentation to determine which elements of DRDL’s arrangements to target during the inspection.
- Site walkdowns to observe how well hazards are controlled and verify compliance with DRDL’s arrangements.
- Office-based discussions on site to check compliance with DRDL’s administrative arrangements, in particular around contractor selection.
- Focused discussions on site with two DRDL senior leaders.
- A wash up discussion including hot feedback to DRDL representatives.
Representatives from DRDL’s Trade Unions accompanied the ONR team at all stages of the site inspection.
I reviewed the information provided pre-inspection and confirmed that DRDL have written arrangements for the selection and control of contractors that incorporate ‘plan-do-check-act’ (PDCA) elements as described in HSG65.
During the site walkdowns, the ONR team observed no matters of evident concern or non-compliances against the risk assessment and method statement (RAMS) for the job in question. However this finding should be treated with caution because only very limited contractor activity could be observed during the inspection.
Our verification activity during the site walkdowns revealed two shortfalls against expectations:
- The arrangements for active monitoring of contractor activities are described in DRDL’s arrangements. We found no evidence to confirm that suitable active monitoring arrangements were in place for potentially high-risk scaffolding activity undertaken on DRDL’s behalf by Kaefer Ltd.
- The Technical Representative, or TR, is a key role in DRDL’s arrangements for selection and control of contractors. We found evidence that TRs experience high workloads and conflicting priorities that could compromise their ability to undertake safety critical TR tasks and impair their decision making.
A recent internal contractor management audit has identified non-compliances by TRs. We understand that DRDL will carry out a root cause analysis (RCA) exercise to understand the reasons for these non-compliances. This provides an opportunity for DRDL to consider how TR workload influences compliance with safety critical procedures.
We noted examples of positive leadership attitudes during discussions with DRDL senior leaders. Level 1 compliance processes have been recognised by senior leadership as an area requiring improvement. This aligns to ONR’s findings concerning active monitoring, which may be undertaken as a Level 1 compliance process.
ONR have formally requested that DRDL respond to them detailing how they intend to address the two points raised below:
- DRDL should provide further information to ONR describing any improvement activity relating to active monitoring elements of their health and safety management arrangements, in particular those concerning contractors.
- DRDL should update ONR regarding the outcome of their RCA on TR non-compliances and any associated corrective actions. ONR’s expectation is that the RCA will consider the extent to which TR workloads may hinder them from delivering safety critical tasks associated with the TR role, and identify any necessary remedial actions.
Conclusion
On the basis of the evidence sampled concerning selecting and controlling contractors, I judge that there was evidence of a shortfall against HSG65 in terms of the implementation of active monitoring arrangements. There was also evidence of shortfalls in managing of the workloads of individuals in safety-critical roles. On this basis I consider that the inspection should not be rated green. However the sample size is insufficient to show whether these shortfalls are repeated or systemic. Furthermore, DRDL have indicated that work is already in hand that may address these issues. I therefore recommend that no rating be assigned at this stage pending further engagement with DRDL to understand the adequacy and timeliness of the work underway.