Date(s) of inspection:
- November 2022
Aim of inspection
To perform regulatory compliance inspection of Cyclife UK focussing on preparations for active commissioning of the cold cutting facility.
Subject(s) of inspection
- LC21 – Commissioning – Rating – Green
- LC22 – Modification or experiment on existing plant – Rating – Green
- LC23 – Operating rules – Rating – Green
Key findings, inspector’s opinions and reasons for judgement made
Sampling of the LC21, LC22 and LC23 arrangements showed that Cyclife have put in place adequate arrangements for compliance with the requirements of these licence conditions.
LC21: Commissioning: Whilst the size of the tank filling the available space in the C3 cell creates some challenges with regard to its safe dismantling during active commissioning, Cyclife demonstrated that they were aware of these challenges and put forward fit for purpose risk control measures, based on administration and procedural controls, to mitigate them. The commissioning is divided into sensible stages as per normal practice and is governed by a strategic project plan and sound operating procedures. The operations of the facility are not complex and are basically routine manual handling operations. Therefore, I rate the compliance with LC21 Commissioning ‘Adequate’ (Green)
LC22 Modification and Experiment on Existing Plant: Inspection of the documents showed that they were well written and comprehensive. Inspection of the facility did not reveal any evidence to suggest that the arrangements for LC 22 compliance were inadequate or not being followed. Therefore, I rate compliance with LC 22 Modification or Experiment on Existing Plant as ‘Adequate’ (Green)
LC23: Cyclife were able to document a process that started with the safety case HAZOP studies and went on to derive appropriate safety measures applied to the plant, based on the analysis of the risks. The documentation was in good order and conformed to industry good practice. I was not able to identify any shortfall in the process and therefore I rate compliance with LC 23 Operating Rules as ‘Adequate’ (Green).