Executive summary
Date(s) of inspection:
February 2026
Aim of inspection
To gain confidence that Babcock’s arrangements for complying with their client duties under the Construction (Design and management) Regulations 2015 at HMNB Clyde are ensuring that projects are carried out in a way that manages the health and safety risks.
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
Babcock (Clyde) routinely utilises numerous contractor organisations in undertaking extensive construction activities across the authorised site, under the Construction (Design and Management) Regulations (CDM). This planned inspection was undertaken by ONR to seek assurance that Babcock’s arrangements for discharging their client duties in relation to managing construction projects deliver adequate standards of health and safety in this area. Babcock Clyde is striving to improve its arrangements for complying with CDM and, to this end, has a CDM transformation plan in place.
The aim of the inspection was to gain confidence that Babcock’s arrangements for the complying with their duties under CDM are delivering adequate standards of health and safety at the authorised site. A particular focus was compliance with Regulation 4 of CDM: which set out the client’s duty to make suitable arrangements for managing a project and maintaining and reviewing these arrangements so the project is carried out in a way that manages the health and safety risks.
The inspection considered:
- The arrangements in place for the managing construction projects.
- The extent to which these arrangements were complied with for the construction activities sampled.
The inspection consisted of:
- Pre-inspection engagement to identify key documentation describing Babcock’s arrangements for complying with their client duties.
- Site walkdowns to observe how well hazards are controlled and verify compliance with Babcock’s arrangements.
- Office-based discussions on site to check compliance with Babcock’s administrative arrangements for the management of construction projects.
- A wash up discussion including hot feedback to Babcock and NBC representatives.
- A representative from NBC’s assurance function was present at all stages of the site inspection.
I reviewed the information provided pre-inspection and confirmed that Babcock has working level documents for the pre-construction phase of projects that incorporate client duties. These broadly map across to published guidance for regulation 4 of CDM (para 31 – To be suitable, the arrangements should focus on the needs of the particular project and be proportionate to the size of the project and the risks involved). The overall conventional safety management system at Clyde is structured arounds the Joint Services Publications (JSP) for safety. Babcock demonstrated compliance with the relevant JSP which aligns with elements of HSE publication HSG 65.
During the site walkdowns, the ONR team observed no matters of evident concern. However this finding should be treated with caution because only very limited contractor activity could be observed during the inspection.
- Babcock should provide further information to ONR describing any improvements planned or underway relating to improvements to their client CDM arrangements.
- Babcock should update ONR on progress with the improvements set out in the plan.
Conclusion
On the basis of the evidence sampled, concerning Babcock’s client duties under CDM, I judge that there is some evidence of a compliance gap in terms of written arrangements for client duties under CDM, and clarity as to extent of Babcock’s responsibilities and a potential overreach into PC duties. In addition, as there was no PC presence on site and no work activities taking place, the sample size as to how the arrangements worked in practice, including demarcation between client and PC.
Thus, the available evidence was insufficient to make an informed judgement. On this basis I consider that no rating be assigned at this stage pending further engagement with Babcock to understand the adequacy and timeliness of the CDM improvements underway, and to undertake a site walkdown to observe work taking place and thus judge whether the client arrangements are adequate to ensure that projects are carried out in a way that manages the health and safety risks.