- Site: Rosyth
- IR number: 22-033
- Date: May 2022
- LC numbers: N/A
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Strategy, each year ONR performs a series of planned interventions at nuclear licensed sites. This intervention forms part of ONR’s 2022/2023 Integrated Intervention Strategy (IIS) for Rosyth Royal Dockyard Ltd (RRDL).
The purpose of this intervention was for ONR to examine the adequacy of the arrangements that RRDL has in place to manage its activities on its licensed site, and to judge the compliance with the Health and Safety at Work etc Act 1974 and Relevant Statutory Provisions made under the Act.
Interventions Carried Out by ONR
This one day intervention on 31 May 2022 was a site-based inspection consisting of meetings with relevant RRDL site staff to understand how conventional health and safety (CHS) was managed on the licensed site and what risk control measures are put in place for the priority risks, as well as a site walk-down to observe risk control measures at the work face.
I prepared an inspection scope and agenda and shared this with RRDL prior to the intervention. Regulatory advice and judgement were based on determining compliance with Sections 2 and 3 of the Health and Safety at Work etc Act 1974 and the relevant statutory provisions made under the Act, particularly the Management of Health and Safety at Work Regulations 1999, as well as the following provisions:
- Provision and Use of Work Equipment Regulations 1998
- Control of Substances Hazardous to Health Regulations 2002
- Dangerous Substance and Explosive Atmospheres Regulations 2002
- Confined Spaces Regulations 1997
- Work at Height Regulations 2005
- Lifting Operations and Lifting Equipment Regulations 1998
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
I identified the following areas of good practice:
- I judge that RRDL have focussed their efforts on the correct conventional health and safety areas, and in balance, these priority risks have received requisite attention and control measures.
- RRDL have a mature health and safety management system and a positive safety culture which is reflected in their low incident rate.
- The Trade Union representatives confirmed the positive safety culture and stated that the workforce can confidently stop work if they feel that safety measures are not correct with full cooperation from management.
I also provided regulatory advice for several minor issues found on the walkdown of 2 Dock and the Active Waste Accumulation Facility (AWAF):
- There were examples of many trailing cable trip hazards in some areas at the top of the dock.
- A construction subcontractor who was drilling holes in concrete at dock-bottom was unaware of the controls in place to protect him from Hand Arm Vibration Syndrome (HAVS) or silica dust. I asked him to stop work and refer to the risk assessment or speak to a supervisor.
- A worker was operating a Mobile Elevated Working Platform (MEWP) to conduct work on top of the boat and had to manoeuvre around electrical cables hanging from the top of the dock to the submarine, raising questions about deconfliction.
- In the AWAF facility, I came across a scaffold tower that had passed the inspection date (RRDL removed the scaffold tag to indicate it should not now be used until it has been inspected).
RRDL agreed to take action on these minor issues and reported remedial actions taken via email on 15 June 2022.
Conclusion of Intervention
From the evidence I sampled during this intervention, in the main, I was satisfied with how RRDL decides on which CHS risks to prioritise and how these risks are managed and controlled on the licensed site. As a result, I judged that this intervention merited a ‘Green’ (No Formal Action) rating.