- Site: Devonport
- Inspection ID: 51057
- Date: August 2022
- LC numbers: N/A
Purpose of inspection
The purpose of this intervention is for the Office for Nuclear Regulation (ONR) to review and examine compliance with ONR-IN-21-001 – the Improvement Notice on the management of Work at Height risks with the (extended) compliance date of 30th September 2022. This inspection will judge:
- The effectiveness of work at height risk control measures on the nuclear licensed site.
- The effectiveness of systems that DRDL employs to monitor and control the work at height risks for contractors working on the nuclear licensed site.
- The readiness of DRDL to instigate management arrangements for work at height on site as required by ONR-IN-21-001.
Subject(s) of inspection
- Working at Height (Rating: Green)
- Health & Safety at Work Act (Rating: Green)
- MHSWR (Rating: Green)
This inspection took place over 2 days, 9 August and 31 August 2022 – the inspection was separated in this way at DRDL’s request due to availability of their staff.In meetings over the two days, ONR asked questions on DRDL’s readiness on implementing the new system of work as required by Improvement Notice ONR-IN-21-001. It was established that training of personnel in the required Work at Height (WaH) knowledge was either complete or planned in, the system for monitoring work at height is established, improvements in planning WaH jobs is complete, WaH audits are planned for the near future and the new standards for work at height are complete and awaiting internal approval. ONR requested a small number of further documents as evidence of compliance with ONR-IN-21-001.
ONR also sampled Work at Height risk management over the two days.
On 9 September ONR conducted a walk-down of 9 Dock. We took the opportunity to go on the scaffold around the fin of BN05 and look at access equipment around the dock.
ONR took the opportunity to meet with the Trade Union Representatives from various areas of DRDL to get their opinion on the improvements as a result of DRDL receiving an ONR enforcement notice. Their response was largely positive especially on the communications on improvements and the WaH training that some of them had attended.
ONR also observed notable Work at Height activities at the CHS CDM Inspection on 10 Dock and the 5 Basin Wall improvements on 11th September 2022: The use of a scissor lift to assist with the insertion of props in the 10 Dock demolition site and the use of a cherry-picker to make external enhancements to the MIP offices at N166. Both of these activities were well planned and managed.
Further examples of WaH risk management observed On the morning of 31 August 2022 ONR observed to pieces of work involving work at height: MEWP work by the Estates Team to inspect and clear blocked guttering at a building on Bullpoint and scaffolding outside buildings 215 and 215a to complete external repairs.
At a walk-down of SRC and work at height on a Butterley Craneon 31 August 2022 we met a Crane Maintenance team on SRC and I spoke to the supervisor on the risks of working at height on the cranes for both the job that they were performing and their other tasks.
There were some minor shortcomings in certain areas, which were largely dealt with at the time, however ONR has requested the Synergi reports for these issues to ensure that they are actioned and managed correctly to prevent reoccurrence.
From the documents collected and the discussions of the implementation of the new work at height management system as well as the work that ONR sampled on the walk-downs we judged that the DRDL management of work at height risks on the licensed site as adequate and rated the inspection as green.
Overall, I am satisfied with the progress made and recognise the amount of work that DRDL has done in order to comply with this Improvement Notice. If DRDL provide the furtherinformation that I have requestedand this proves satisfactory, then I will write to DRDL formally to state that ONR agrees that Improvement Notice ONR-IN-21-001 has been complied with.