Date(s) of inspection
- September 2023
Aim of inspection
The purpose of this inspection was to assess, through sampling, the station’s compliance with the requirements of Licence Condition 10 (Training) and Licence Condition 12 (Duly Authorised and Other Suitably Qualified and Experienced Personnel).
The inspection considered:
- LC10(1) The Licensee shall make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.
- LC12(1) The Licensee shall make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.
The inspection was rated against the requirements of LC10 and LC12 in accordance with ONR’s guidance (https://www.onr.org.uk/intervention-records/onr-inspection-rating-guide.pdf)
This is also a follow-up to an equivalent inspection conducted 12-months ago, from which two significant Level 3 Regulatory Issues were identified and remain open, relating to:
- the assignment of post and role profiles to enable training compliance, and training governance and oversight.
Subject(s) of inspection
- LC10 – Training – Rating: Green
- LC12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This planned inspection assessed Heysham 2’s (HYB) training and suitably qualified and experienced personnel against NGL’s extant arrangements.
NGL has introduced a new Learning Management System, My Learning Hub, since the last inspection. This had been identified as a key enabler to addressing the station’s post and role assignment and training compliance shortfalls.
In preparation for the inspection, I sampled a selection of post and role training profiles plus training compliance records. During the inspection, I conducting targeted discussions with the Training Administration Team and personnel at all levels in the organisation sampling training compliance.
I found that:
- HYB has been pro-active in establishing enhancements to My Learning Hub to enable a step change in the assignment of post and role training profiles and the validity of compliance records;
- There has been a significant transfer of ownership of training to the line and recognition that responsibility for compliance resides with the individual. This has greatly reduced friction between the training administration team and the line. Nevertheless, it was reported that approximately 50% of personnel continue to rely on the Training Admin Team to manage their training compliance;
- There are shortfalls in the management of contractor training compliance arising from the lack of an adequate process for the on-boarding/ off-boarding of contractor personnel and contractor organisations are not cleansing data in a timely manner;
- My Learning Hub does not assist in the management of contractor training compliance due to limitations in the ability to assign contractors to managers.
- The station has defined a two-phase approach to address the training governance regulatory issue (phase 1 – re-establish; phase 2 – continuous improvement).
I reviewed the structure of HYB’s training governance, sampled records of the Strategic Training Committee (STC) and departmental Training Advisory Committees (TACs), Training Oversight Committees (TOCs) and Curriculum Review Committees (CRCs). From this, I held focused discussions on the:
- Implementation of governance and oversight arrangements with members of the STC and the NSG TAC;
- Effectiveness of training governance and oversight with personnel at all levels in the organisation from Station Director to Team Leader. I also canvassed views from Site INA and Safety Representatives.
I found that:
- HYB’s training governance and oversight structures have been re-established fully, in accordance with NGL’s arrangements;
- The line now has ownership of each training governance forum, with the training team only facilitating the meetings;
- Appropriate lagging performance metrics are being used at all levels and HYB using these effectively;
- The governance areas sampled demonstrated:
- Effective escalation of issues and cascade of information;
- A proactive approach to continuous improvement of both the effectiveness of training governance, including the identification of leading indicators to provide a forward look, and HYB’s training performance.
I judge that the station has made a concerted effort to address the existing training-related regulatory issues:
The implementation of My Learning Hub, pro-actively augmented by station-developed enhancements, has been instrumental in cleansing the assignment of post and role profiles. This has enabled greater training compliance management through:
More accurate identification of training requirements;
- Empowering individuals to take responsibility for their training compliance.
- The gaps in HYB’s training governance structures have been addressed and the effectiveness of training governance is improving markedly, with clear plans for further improvements training governance has been fully re-established
- Nevertheless, challenges continue in each area covered by the regulatory issues:
- It was stated that approximately 50% of station personnel continue to rely on the training admin team to manage their training compliance;
- Contractor training compliance is consistently ‘red’ against NGL’s performance indicators;
- Having re-established the structures, HYB has identified requirements for training governance improvements
The station has credible plans to address each of these challenges and, therefore, I have rated this inspection GREEN for both LC10 and LC12 and determined that the extant regulatory issues should remain open but, recognising the progress made, each should be down-graded to a lower (minor) Level 4 level.