Executive summary
Date(s) of inspection
- March 2026
Aim of inspection
Licence Condition (LC) compliance inspections are an essential element of ONR's intervention strategy on any nuclear site and consist of a series of inspections, each of which is intended to establish whether BAESML and it’s supporting services, have adequate arrangements in place, and are adequately implementing these arrangements, for compliance with a specific LC.
LC26 requires that: ‘The licensee shall ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee’.
The aim of this inspection is to gain assurance that the licensee is adequately implementing its arrangements for compliance with LC26, in relation to control and supervision of operations.
This will be a 1.5 day inspection onsite at BAESML (Barrow)
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) - Rating: GREEN
- Health & Safety at Work Act - Rating: GREEN
- LC 26 - Control and supervision of operations - Rating: GREEN
- Management of Health and Safety at Work Regulations - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
Introduction
The Office for Nuclear Regulation (ONR) conducted a planned inspection of BAE Systems Marine Limited (BAESML) to assess the adequacy of arrangements for the control and supervision of operations undertaken across the licensed site.
The purpose of the intervention was to:
- evaluate compliance with Licence Condition (LC) 26 – Control and Supervision of Operations, which requires that operations affecting safety are carried out under the control and supervision of suitably qualified and experienced personnel.
- ensure compliance with The Management of Health and Safety at Work Regulations 1999, which requires employers to make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.
The inspection sought to provide assurance that BAESML is effectively identifying, managing and controlling hazards associated with its activities and that appropriate governance, leadership and oversight arrangements are in place to support compliance with LC26 and The Management regs.
In particular, the inspection focused on:
- BAESML’s arrangements for compliance with LC26;
- Governance and organisational oversight supporting implementation of LC26 requirements;
- Assurance activities undertaken to monitor and verify compliance;
- The arrangements in place to ensure personnel undertaking control and supervision duties are suitably qualified and experienced (SQEP);
- Updates relating to recent operational incidents on site;
- The management and coordination of daily activities through the Plan of the Day (PLOD) process; and
- The implementation of control and supervision arrangements at the point of work.
The inspection comprised:
- Structured discussions with relevant BAESML personnel to review LC26 arrangements, governance processes and assurance activities;
- Observation of two Plan of the Day (PLOD) meetings to assess the effectiveness of arrangements for coordinating and controlling work undertaken by both employees and contractors; and
- A site walk-down within the Devonshire Dock Hall (DDH) to observe activities in progress and assess the implementation of control and supervision arrangements at the operational level.
Findings
Based on the evidence sampled during the inspection, ONR judged BAESML’s implementation of Licence Condition 26 – Control and Supervision of Operations and The Management of Health and Safety at Work Regulations 1999 to be adequate and assigned an inspection rating of Green (No Formal Action).
BAESML demonstrated that appropriate arrangements, governance structures and assurance processes are in place to support compliance with LC26. The inspection identified a number of positive developments, including the appointment of a permanent Control of Work Discipline Lead, the provision of additional dedicated resource to support the Control of Work function, and improvements in the recording, retention and communication of assurance findings.
Observation of the PLOD meetings provided evidence of an open and positive safety culture, with attendees actively engaged in discussions regarding work activities, hazards, operational interfaces and required control measures. Personnel involved in site activities demonstrated a clear understanding of the work being undertaken, the associated risks and the controls necessary to ensure safe execution of tasks.
The site walk-down confirmed that control of work arrangements were understood by those undertaking and supervising activities. Individuals were able to articulate the requirements of pre-job briefings, identify key hazards and explain the controls and permissions required before commencing work.
Whilst recent operational events emphasise the need for continued focus on planning, supervision and work execution standards, ONR did not identify any significant shortfalls in the implementation of LC26 arrangements during the inspection. Overall, the intervention provided confidence that BAESML is maintaining an effective framework for the control and supervision of operations and is continuing to drive improvements through leadership, assurance and organisational learning.
Recommendations
In order to support ONR’s ongoing regulatory oversight, BAESML is requested to provide the outcome of its SHE investigation into the lifting incident that occurred on 18 March 2026 involving the SA11 overhead crane within Devonshire Dock Hall.
Specifically, ONR requests:
- A copy of the completed SHE Investigation Report;
- Details of the immediate, underlying and root causes identified;
- The corrective and preventive actions arising from the investigation;
- Evidence of actions already implemented; and
- BAESML’s forward action plan, including arrangements for tracking, monitoring and verifying the effectiveness of corrective actions.
ONR will review the information provided and determine whether any further regulatory engagement or follow-up activity is required.
Conclusion
On the basis of the evidence sampled for the Control and Supervision of operations, discharging of CDM roles, and how work was being planned, organised, controlled and carried out on site, we judged that the management of CDM and LC26 as adequate and rated the inspection as green.