Date(s) of inspection:
- August 2023
Aim of inspection
The aim of the inspection was to consider Dounreay’s revised site wide Construction (Design and Management) Regulations (CDM) arrangements and their implementation on relevant projects and work areas. The inspection also looked at general health and safety matters in a number of areas on site and sampled Dounreay arrangements for managing health and safety compliance.
Subject(s) of inspection
- CDM 15 – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This was a planned inspection on Dounreay’s arrangements and practices to comply with the requirements of the Construction (Design and Management) Regulations 2015 (CDM 2015). Currently there is an open ONR Level 3 Regulatory Issue (RI-10962) on Dounreay’s improvement plan for CDM 2015 following several incidents on the Advanced Transition Work (ATW) sites in 2020 and an Enforcement Letter (ONR-EL-21-044) that was served to Dounreay on its failings to comply with CDM 2015 Regulation 13(1) requirement to discharge its duties as appointed Principal Contractor (PC) for the project. The aim of this inspection was to collect evidence and give ONR confidence that Dounreay is effectively implementing the improvement plan to comply with CDM 2015.
ONR held discussions with the process owner for CDM 2015 (STD 2008) and the project teams for ATW project and D1217 concrete wall dismantling project. We also carried out a site walk-down on each of the projects, although we noted there was little work going on during the walk-down and this limited the basis of our judgement to discussions held, records seen, and physical site layout that was seen, rather than the adequate management of those activities. Based on the improvements seen, in particular on the ATW project, a ‘Green’ rating was assigned to this inspection. We also provided regulatory advice regarding compliance with CDM 2015 Regulation 8(1), specifically on ensuring consideration for assessing organisation capability for key CDM 2015 roles.
It was difficult to judge the effectiveness in practice of the implementation of Dounreay’s revised CDM arrangements given that little construction work was observed at the time of inspection, however, based on the limited evidence we have sampled on ATW and D1217 projects, in particular the improvement seen over the ATW project set-up, I judged that a Green rating is appropriate for this intervention. RI-10962 is updated to reflect this judgement but remains open as further evidence is required before it can be closed.