Executive summary
Date(s) of inspection
- May 2026
Aim of inspection
The aim of this inspection (which will be joint with DNSR and INA) is to test the adequacy of BAESML's arrangements, and their implementation, to translate its safety case claims into the appropriate and suitable written instructions, and the governance of this. This relates specifically to LC 24 (1), (2) and (4).
Subject(s) of inspection
- LC24 - Operating instructions - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
This inspection identified shortfalls in BAESML’s LC24 arrangements and in their implementation across the sampled business areas, with the more significant weaknesses evident in Operations/Docking and Nuclear Services Authorisation Group. We identified inadequate processes, guidance, training and support for those responsible for authoring, reviewing and authorising written instructions, resulting in inconsistency and weaknesses in the quality and usability of some operating instructions. By contrast, we judged that arrangements within RTS/RTG were more mature and effective, although gaps against relevant good practice were still identified, similar to those identified within Operations/DNSAG. This broadly aligns with the findings identified by Independent Nuclear Assurance (INA) and we welcome the advice note that INA have issued. The impact of such inconsistencies and weaknesses across BAESML has potential to be wide ranging and to limit the effective implementation of the nuclear safety case, as evidenced through shortfalls identified during recent operational readiness inspections and recent safety case breaches.
Taking account of the evidence gathered, I rated the inspection AMBER (seek improvement) with an ONR Level 3 regulatory issue to track the improvements sought. Whilst BAESML described an intention to improve its arrangements, training, human factors input and presented an associated improvement plan (in response to INA note), it was not able to demonstrate a sufficiently mature or resourced plan for delivery. ONR will focus on both short-term, risk-targeted actions to improve the quality of written instructions for upcoming activities, and longer-term actions to strengthen LC24 arrangements and their consistent implementation across the business.
Conclusion
We identified shortfalls in BAESML’s LC24 arrangements and their implementation, with the more significant shortfalls in Operations/DNSAG. These included a lack of process, guidance and training to support those who write, amend, review and authorise written instructions in producing good-quality, consistent and user-friendly documents. I therefore rated the inspection AMBER (seek improvement) in accordance with ONR Guide ONR-INSP-GD-064.
In considering proportionate regulatory enforcement, we were mindful of wider recent regulatory engagement related to SA breaches and BAESML’s stated intent to undertake further work in this area and the strong response by INA in their formal advice note. However, because BAESML had not shared a resourced plan to deliver this intent, and similar previous efforts have not delivered the improvements being sought, we judge it appropriate to raise a Level 3 regulatory issue. It is important that this issue is used to both drive shorter-term, risk-targeted improvements to the quality of written instructions and to hold BAESML to account for longer-term improvements to arrangements in a timely manner.