Date(s) of inspection:
- April 2023
Aim of inspection
The purpose of this intervention is for the Office for Nuclear Regulation (ONR) to determine compliance to the relevant conventional health and safety regulations, including live fire safety across ongoing project works at Inutec Ltd. The inspection sought to confirm Inutec Ltd. has made and implemented adequate quality management arrangements in respect of matters which may affect safety and specifically conventional health and safety.
Subject(s) of inspection
- CDM 15 – Rating: GREEN
- Fire (Life Safety) Compliance Inspection – Rating: GREEN
- LC17 – Management systems – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
The inspection assessed Inutec Ltd’s arrangements to support Life Fire Safety (LFS) and sampled the implementation of those measures on site. The inspection consisted of examination of the licensee’s arrangements regarding LFS covering the entire site, meetings to assess the implementation and management of LFS at a site level and a walkdowns of the B49 and B45 facilities. From the enquires and sampling undertaken it was noted that, in some instances, approved Fire Risk Assessments (FRA) were significantly out of date against internally recommended review dates. Revised draft FRA had been produced for B45 however, it had yet to be formally accepted. The draft FRA contained several adverse findings which had still to be sentenced. It was noted that staff responsible for conducting FRAs had recently left the business and new assessors were in the process of being trained. Given the significant material changes taking place on site there is a risk that appropriate fire risk knowledge will not be maintained. Regulatory actions have been placed to monitor implementation of revised FRAs and implementation of suitable training for new fire risk assessors.
The inspection assessed Inutec Ltd’s arrangements to support Conventional Health and Safety (CHS) and sampled the implementation of those arrangements on project 19B currently undergoing construction on site. The organisation and management of the CDM site and control of contractors was examined with no areas of concern identified. Discussions were held with the Safety Security Health Environment Quality (SSHEQ) team to understand risk priorities, the evidence used to establish these and what risk control measures are put in place for the priority risks. A good standard of housekeeping was observed throughout the walkdown of the site. Although there is a system to manage asbestos containing materials on site, these are not fully in line with the requirements of Reg 4 of Control of Asbestos Regulations 2012 and the associated ACOP. Regulatory actions have been placed to monitor implementation of risk assessment and risk management following a revised asbestos survey due May 2023.
It was observed on a number of occasions that the duty holder had difficulty locating documentation including procedures and records. It was also noted that many risk assessments and some procedures were beyond their 3 yearly review date as required the Inutec Ltd business management system. These observations reflect shortfalls against ONRs LC 17 inspection guidance. Whilst this has been self-recognised by the licensee and a programme of improvements put in place, I consider it proportionate to monitor the implementation of the improvement programme.
Although some minor shortcomings were observed regarding asbestos risk assessment and management, based on the evidence sampled during the inspection, ONR was satisfied with how Tradebe Inutec is prioritising and is managing CHS risks on site and the inspection is rated Green (no formal action).
Conventional health and safety arrangements were confirmed fully integrated within the licensee’s business management system in accordance with ONR inspection guidance Principles 2. Shortfalls were observed against ONR inspection guidance Principles 2 and 4 as I consider there is a lack of optimisation and issues regarding accessibility of the BMS as evidenced by the number of out of date risk assessments. The licensee has recognised the issue and a programme of improvements has already been initiated. On the basis that the shortfall has already been identified and an action plan is being implemented, I consider an inspection rating of Green (no formal action) is appropriate for LC17 as actions are already in hand to address identified shortfalls.
There is some outstanding work is required by the licensee to update fire risk assessments. There is concern regarding the loss of expertise in fire safety due to the departure of key personnel. However, the licensee has taken steps to appoint a replacement and provide appropriate training. Notwithstanding these concerns, I consider that the site complies with the requirements of the Regulatory Reform (Fire Safety Order) 2005 and therefore consider that an ONR Inspection rating of Green (no formal action) is appropriate.