Executive summary
Date(s) of inspection:
February 2026
Aim of inspection
The purpose of this inspection was to sample evidence to determine the adequacy of EDF Nuclear Generation Limited's (NGL's) arrangements for work conducted during the statutory outage at Torness to inform a regulatory judgement regarding the licensee’s compliance with The Construction (Design and Management) Regulations 2015 (CDM) and associated relevant good practice.
For statutory outages EDF take on the following named CDM roles: Client, Principal Designer and Principal Contractor. This inspection sampled how EDF NGL comply with these defined roles.
Subject(s) of inspection
- CDM 15 - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The inspection sampled EDF Nuclear Generation Ltd’s (EDF NGL) arrangements for managing health and safety during construction activities in accordance with the Construction (Design and Management) Regulations 2015 (CDM). The sample focused on occupational health risks, informed by site intelligence, recent incidents, and previous walkdowns.
The inspection identified specific failures to meet legal duties under CDM. In particular:
As Client, EDF NGL was unable to demonstrate that it had taken reasonable steps to ensure that the Principal Designer and Principal Contractor were fulfilling their duties, as required by CDM Regulation 4(6).
As Principal Contractor, EDF NGL did not adequately plan, manage, and monitor some occupational health risks during the construction phase, as required by CDM Regulation 13(1).
This included deficiencies in the review of contractor risk assessments, management of control of substances hazardous to health and noise risks, and monitoring of contractors health surveillance arrangements.
These shortfalls indicate systemic weaknesses in assurance and occupational health controls, rather than isolated administrative errors, and fall within EDF NGL’s arrangements under CDM. It is noted however, there was no evidence of actual health or safety detriment. Based on the evidence sampled, ONR rated EDF NGL’s compliance with CDM as Amber (seek improvement).
Conclusion
We judged an Amber rating is appropriate for this inspection because specific legal requirements were not adequately demonstrated as being met, namely CDM Regulations 4(6) (Client duties) and 13(1) (Principal Contractor planning, management and monitoring of the construction phase, including occupational health). The shortfalls were systemic across assurance and occupational health controls rather than isolated administrative errors. These matters are being tracked through RI‑13006.