Executive summary
Date(s) of inspection
- November 2025
Aim of inspection
The primary purpose of this intervention is to review Vulcan NRTE’s arrangements for managing safety of their ongoing / upcoming construction projects and related works. This will focus on compliance with the Construction (Design and Management) Regulations 2015 (CDM15), but other health and safety regulations are also relevant and may be considered.
Subject(s) of inspection
- CDM 15 - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The inspection at Vulcan NRTE assessed compliance with Construction (Design and Management) Regulations 2015 (CDM 2015) focusing on pre-construction phase, particularly those of the client. Rolls-Royce Submarines Ltd, were the CDM 2015 client under the MoD “Unity” contract, was responsible for CDM compliance, supported by site-specific procedures (Vulcan Standing Orders).
The client duties of allocating adequate resources, appointing CDM 2015 dutyholders (principal designer and principal contractor), and providing pre-construction information were acknowledged in procedures but lacked clear, formalised arrangements to ensure effective implementation and documentation. Similarly, duties of the principal designer in planning and managing health and safety during pre-construction phase were recognised but not adequately embedded in procedures.
Two construction projects that were in the planning stage with no active construction work ongoing — the active equipment store stabilisation project and the auxiliary trades building reclad project — were reviewed. Gaps were identified in the arrangements for managing health and safety in construction.
- For the active equipment store stabilisation project; the temporary works design lacked proper certification and construction/dismantling plans, which posed potential safety risks.
- For the auxiliary trades building reclad project; incomplete design and construction planning, incomplete risk assessments, and inconsistency in competence assessment arrangements between internal and external CDM 2015 appointees, indicated weaknesses in the management arrangements for complex construction projects.
Overall, the inspection highlighted significant shortfalls in documentation, procedural clarity, and project management. Rolls-Royce Submarines Ltd need to review and update its procedures to fully comply with CDM 2015 primarily in relation to demonstrating arrangements for planning, risk assessment, and CDM 2015 appointments. A level 3 regulatory issue was raised to address the shortfalls identified.
Conclusion
Overall, the review of arrangements for the management of construction activities at Vulcan NRTE did identify significant weakness in the arrangements contrary to the requirements of the Construction (Design and Management) Regulations 2015 (CDM 2015). There were no ongoing construction activities in progress, so there was no immediate risk to those who may be affected by construction works.
The Vulcan specific arrangements (VSOs) examined were out of date and had not been updated to reflect Rolls-Royce Submarines procedures for managing construction standards e.g. HSE MS 18-00 Management Standards.
It appeared from the inspection that the general requirements set out in CDM 2015 for the planning and scoping of construction works, and the arrangements for discharging the duties associated with being a client were being met, but the evidence to demonstrate this was not readily available for inspection and verification. There were shortfalls identified with the upcoming construction projects, specifically how the principal designer role is discharged, and the competence of Rolls-Royce to fulfil the role of principal contractor.
On this basis, the inspection was rated AMBER – seek improvement. A Level 3 Regulatory Issue will be written to address weaknesses in the arrangements seen, and to ensure proposed construction work has been appropriately planned, managed and monitored.