SHEF Annual Report Health, Safety & Environmental Department HM Naval Base Clyde 2008 – 2009
In association with FOREWORD BY MANAGING DIRECTOR (CLYDE) BABCOCK MARINE & NAVAL BASE COMMANDER
It is our pleasure to introduce HMNB Clyde’s Annual Safety Report, for 2008-2009. HMNB Clyde continues on its journey in implementing an ambitious programme to improve the safety culture throughout the Base thereby enhancing our overall safety performance. This programme, ‘Our Challenge on Safety’, is well on the way to creating a unified Clyde safety culture, embracing all who live on, work on and visit the Base. The efforts of our Naval Base community have resulted in a significant improvement in our safety performance as outlined below.
It is important that each objective, task or initiative is sustainable and it will build on our ambition to make the Base a safer environment, with that in mind we have listed just some of the activities that have and are contributing to our overall aim of an Incident and Injury free Clyde:- Capability Clyde a competency framework, Single Event Reporting/Recording System, REDF life extension project, SHEF Website, Point of Work Check process, NARO response improvement, re-certification to ISO 14001 Environmental Management System, environmental clean up of the Base using a ‘Kaizen’ approach and a defined set of Safety Performance Indicators.
Throughout the year the IIF programme brought together MoD/RN Base personnel, FASFLOT and BM (C) employees, a remarkable achievement when you consider that we managed to deliver 3000 personnel through the ‘Orientation’ Workshops. There have also been in excess of 150 Supervisors/Team Leaders attend the Supervisors Skills Workshops designed to commence the application process of Incident and Injury Free. The predominant focus for this year will be the establishment of Departmental IIF Teams which has already begun with Hotel & Catering, Estates, Fleet and Nuclear Activities. This year will also see our focus turn towards the wider Naval Base community with functions such as Ministry of Defence Police being progressed through the Orientation Workshops.
Overall we have seen another successful year where no major injuries were recorded, reportable accidents reduced by 48% and total accidents by 7.9%. These statistics proving indeed that the Naval Base is becoming a safer environment. Another success criteria of any cultural change programme is the number of near misses reported; this year there was an increase of 256% in reporting which indicates that our people are becoming more aware of the hazards and their surroundings. Our challenge remains for 2009-2010 to build on these successes and continue our progress towards sending our people home safely every day.
The primary objectives for 2009-2010 are equally, if not more challenging and will continue to build on the excellent progress already made. Some of the major initiatives are as follows: HMNB Clyde SHEF Annual Report 2008-2009
• Implement the SHEF Training Strategy to underpin our cultural change programme • Enhance our control of contractors’ process by establishing a Site Control Office • Creating and supporting departmental safety teams • Publication of departmental Safety Improvement Plans • Reduce near misses instances attributable to unsafe conditions by 50% • Further the Clyde ‘Fire Safety Strategy’ • Implement a Safety Improvement driven Reward & Recognition Policy • Introduce Time Out for Safety (TOFS)
This will be a challenging and exciting year in which we can all play a part in continuing to make the Naval Base a safer place to live, work and create an environment where we are regarded as a good neighbour.
Craig Lockhart Commodore Chris Hockley Managing Director (Clyde) Babcock Marine Naval Base Commander
HMNB Clyde SHEF Annual Report 2008-2009
CONTENTS 1. INTRODUCTION
1.1 Performance against targets 1.1.1 Reduction in work related injuries 1.1.2 Requirements 1.1.3 Learning and Development 1.1.4 Combined Nuclear & Conventional Safety Culture 1.1.5 Communication 1.1.6 Process Initiatives 1.1.7 Behavioural Safety 1.1.8 Environmental Management System (EMS) Developments 1.1.9 Occupational Health 1.2 Incident Injury Free - Progress 1.3 Diving Safety 1.4 Introduction of Event Review Boards (ERB’s)
2. STATISTICAL ANALYSIS - ACCIDENTS
2.1 Cause 2.2 Accident by Directorate 2.3 Dangerous Occurrences 2.4 Near Misses 2.5 Unsafe Acts and Unsafe Conditions
3. ENVIRONMENT
3.1 Environmental Management System (EMS) 3.2 ISO 14001 Certification 3.3 Integrated Pollution, Prevention and Control (IPPC) 3.4 Land Quality Assessments (LQA) 3.5 SEPA Site Visits 3.6 HMNB Clyde Utility Policy and Strategy 3.7 EU Emissions Trading Scheme 3.8 Defence Fuel Group Audit 3.9 Water Environment Oil Storage (Scotland) Regulations 2006 3.10 Scottish Pollution Release Inventory (SPRI) 3.11 Environmental Exercises 3.12 Environmental Incidents 3.13 Environmental Workshops 3.14 Waste Management
4. NUCLEAR SAFETY EVENT REPORTING
4.1 Categorisation of Event 4.2 Investigating Officers 4.3 Findings 4.4 Operational Feedback Experience, Reports and Trend Analysis 4.5 NSER Process Developments 4.6 NSER Statistics 2008-09 4.7 Inspection for RSA 93
HMNB Clyde SHEF Annual Report 2008-2009
5. WEAPONS SAFETY ASSURANCE
6. FIRE
6.1 Organisation 6.2 Fire Risk Assessment 6.3 Fire Safety Management Plan 6.4 Fire Incident Statistical Analysis
7. OCCUPATIONAL HEALTH
7.1 BM (C) Occupational Health 7.1.1 Introduction of e-Opas 7.1.2 Management of Sick Absence 7.1.3 Case Management 7.1.4 Treatments 7.1.5 Workplace Visits 7.1.6 Health Assessments/Surveillance 7.1.7 Physiotherapy 7.1.8 Potential Man hours saved 7.1.9 Clinical Audit 7.1.10 Health Promotion 7.1.11 Collaboration with External Public Health Organisations 7.1.12 Summary
7.2 MOD Occupational Health 7.2.1 Organisation 7.2.2 Noise at Work 7.2.3 First Aid Training 7.2.4 Health Surveillance 7.2.5 Health Promotion 7.2.6 Department Activity Statistics
8. OCCUPATIONAL HYGIENE
8.1 COSHH 8.2 Vibration 8.3 Noise 8.4 DSEAR 8.5 Emergency Issues 6.6 Statistical Summary of Occupational Hygiene Activities
9. ENVIRONMENTAL HEALTH
9.1 Food Safety 9.2 Pest Control 9.3 Port Health 9.4 Awareness Campaigns 9.5 Emerging Issues 9.6 Other Activities 9.7 Legislative Impact 9.8 Achievement of Objectives Set for 2007/2008 9.9 Statistical Summary of Environmental Health Activities
HMNB Clyde SHEF Annual Report 2008-2009
10. CARRIAGE OF DANGEROUS GOODS
10.1 Introduction 10.2 Volumes of Dangerous Goods Transported 10.3 Material Assessment Centre – Hazardous Waste 10.4 Dangerous Goods Incidents 10.5 Training 10.6 Audits and CMS 10.7 Legislation Changes
11. REGULATORY AUTHORITIES
11.1 HSE Visits 11.2 SEPA Visits 11.3 Environmental Health
12. AUDIT & VERIFICATION
13. SELF REGULATION NOTICES
14. LEGAL CLAIMS
14.1 BM (C) 14.2 MOD
15. OBJECTIVES & TARGETS 2008/09
15.1 Requirements 15.2 Learning & Development 15.3 Combined Nuclear & Conventional Safety Culture 15.4 Communication 15.5 Process Initiatives 15.6 Behavioural Safety 15.7 Environmental
HMNB Clyde SHEF Annual Report 2007-2008
1.0 INTRODUCTION
The total number of injury accidents recorded for HMNB Clyde continues to fall. This year’s decrease was 7.9% (175). The number of reportables has fallen by almost a half at 48% (10). There were no reportable major injuries this year.
350 322 312 301 300
250 219 191 200 175
150
100 63 55 47 50 25 19 10 0 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09
Reportable Total Accidents
1.1 Performance against targets
This section provides a summary of HMNB Clyde’s performance during the past year against the targets set in our Annual Report for 2007-2008.
1.1.1 Reduction in work–related injuries
All-accident Numbers 191
175 A 7.9% reduction from the previous year was achieved. .
2007/08 19 2008/09
10 RIDDOR Reportable Injuries
A 48% reduction in reportable accidents was achieved. • 2007/08
2008/09
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1.1.2 Requirements
• Agree Periodic Safety Review Strategy – this is complete.
• Establish a Just Culture – this has progressed well and a draft policy has been discussed with the Trade Unions. The intention is to have this agreed and in place within first quarter 2009-2010.
• Integration of Lodgers and Contractors into IIF programme – this is ongoing, a Commitment Workshop was held where Lodgers and Contractors were introduced to the IIF ethos. Their employees will attend the Orientation sessions throughout this year.
• Establish Directorate Safety Leadership Teams – this is work in progress Hotel & Catering and Estates have put in place their teams, the other key Departments will have theirs in place by end August 2009.
1.1.3 Learning and Development
• Deliver 4hr IIF Orientation programme covering FASFLOT, BM (C) and MoD employees – this is complete.
• Deliver 4hr IIF Orientation programme covering Lodgers and Contractors – this is in progress. . • Complete delivery of Accident Investigation Leadership Toolkit (Root Cause Analysis) - this is complete.
• Deliver IIF Supervisors Skills Workshop – this is complete, over 150 Supervisors/Team Leaders attended.
• Develop and deliver training programme for Directors and Senior Managers – this is in progress as part of the SHEF Training Strategy.
1.1.4 Combined Nuclear & Conventional Safety Culture
• Single event reporting and recording system – this is complete and now captures all events that occur on the Base through one single point of contact.
• Instructions to persons on site – AC9 – this is ongoing and will become a major part of next year’s objectives encompassing a ‘Site Control Office’, new Induction Training package for all employees, an uprated Computer Based Training (CBT) Module for contractors provided at the Visitors & Contractors Induction Centre (VCIC) and a update of the Base health & safety video.
• Base-wide lessons learned process – this is complete, regular monthly bulletins issued.
• Integrated Annual Report – this is complete.
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1.1.5 Communication
• Develop communication strategy – this is complete.
• Develop SHEF Website – this is complete.
• Enhancement of Base-wide communications – this is complete.
1.1.6 Process Initiatives
• Time Out For Safety (TOFS) – this is ongoing.
• Launch Point of Work Checks – this is complete.
• Control of Contractors Phase 2 – this is ongoing and linked to the setting up of a ‘Site Control Office’.
• Roll out of EMMA Incident Reporting system – this is complete.
• Complete rollout of COSHH programme (Sypol) - During 2008/09 it was identified that the Sypol CoSHH Management System within HMNB Clyde had encountered technical problems. These related to our use of an intranet based system as opposed to an internet based system. Following investigations and discussions with Sypol it was agreed to develop an internet system. Work has commenced to transfer data from the intranet system to the internet system in conjunction with the creation of new more user friendly work areas. The new internet based Sypol CoSHH management system will be available to all Team Leaders at Faslane and Coulport following completion of this transfer. Meanwhile the existing system has been modified to operate via the Safety Department to ensure services are maintained during the transition.
• Produce updated Base Induction video – this is ongoing.
• Improve reporting of near Misses – this is complete in that the reporting of Near Misses increased by 256% during the year however this is an ongoing objective to continue to increase Near Miss reporting.
1.1.7 Behavioural Safety
• Develop and launch a Recognition & Reward Scheme – this is ongoing, a draft is with the IIF Leadership Team.
• Develop a Behavioural Safety Strategy – this is ongoing, will require to link into the present IIF programme at some point.
• Undertake Integral Safety Assessment (Pulse Survey) – the survey was issued in March ’09 and report will be available by end June 2009.
1.1.8 Environmental Management System (EMS) Developments
• Maintain ISO 14001 registration – HMNB Clyde EMS continued to meet the requirements of ISO 14001 and successfully gained recertification to the standard in
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October 2008. The April surveillance visit had identified 4 major non-conformances which were all closed out during a special surveillance visit in June 2008.
• Pollution Prevention Control (PPC) Permits – the Oil Fuel Depot (OFD) continues to meet the requirements as laid down in its PPC permit and now comes under the control of Defence Fuels Group, although the OFD Garelochead is still within the scope of HMNB Clyde’s EMS. The chlorination of the pipework in the NUB became critical during 2008 due to excessive marine growth. The chlorination methodology is being agreed with SEPA to allow a one–off cleaning and then a process to ensure that further chlorination can take place within the limits of the PPC permit.
• EU Emission Trading Scheme – Coulport and Faslane fall within the scope of Phase II of the EU ETS but are now classed as small emitters. This means our invoices can be used as verification of our CO2 emissions. Both Faslane and Coulport were under their allocated allowances which means neither site has to buy any carbon credits.
• Water Environment(Oil storage)(Scotland) Regulations – Work has been approved to upgrade the diesel tanks at Coulport and Faslane as well as the petrol tank at Faslane in order to ensure that they are compliant with the regulations.
• Environmental Aspects Records – the aspects records have been reviewed and replaced during 2008/09 with a simplified form which is intended to make the process easier to understand and use. These new forms will link into the legislation register as well as the relevant processes help on CMS. These forms will also cut down the number of aspects records held on CMS.
1.1.9 Occupational Health
• Complete programme of Workplace visits – this is complete.
• Carry out a minimum of 6 health promotions – this is complete.
• Implement e-OPAS Occupational Health software system – this is complete; all employee health records have now been transferred to the system.
• Implement a Drug and Alcohol policy – this is ongoing.
• Continue implementation of First Aid requirements – this is complete.
• Continue development of a robust system for reducing sick absence – this is complete.
1.2 Incident and Injury Free - Progress
Supporting HMNB Clyde is “Our Challenge on Safety” campaign is the Incident and Injury- Free Programme. This programme elevates our personal relationship to safety and supports the values of care and concern; thus underpinning the site’s commitment in achieving breakthroughs in safety performance.
The Incident and Injury-Free Programme was initiated in October 2007 with a series of on- site interviews to asses our perception to safety. Since then an array of IIF focused activities have taken place and vital safety learning has been achieved. The IIF Orientations reached a major milestone in December 2008 with over 2600 participants from the site’s diverse
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organisations being successfully aligned with the joint commitment on safety. This Orientation Programme is led by volunteers who personally championed the roll out and achieved an overwhelmingly positive response from the workforce. Orientations continue to occur, aligning new members of the community with the site’s safety values regardless of employer.
A series of Supervisor Skills Workshops, focused on the site’s Leadership Community have also taken place. These Workshops assist in developing three main skills: Assigning IIF work, Recognising IIF work and constructively correcting At-Risk work. When applied consistently, these skills promote high level sustainable safety practice. To date 160 members of the site’s Leadership Community have successfully completed the workshop with another 120 participants planned in the coming months.
IIF Department Teams have also been established and continue to be established across several of the largest departments. These department teams again consist of volunteers who focus on more localised issues and bring with them a deeper understanding and practical knowledge of the potential hazards and areas for improvement. Supporting localised activities and empowering these teams to make the necessary changes towards Incident and Injury-Free is a main objective for this year.
A 4th IIF 2 day Commitment Workshop has also taken place offsite facilitated by JMJ Associates. This workshop continues to align the Clyde management team with the values of Incident and Injury-Free. The workshop allows participants to explore their beliefs and attitudes about safety, as they do so, new perceptions and thinking surface and a commitment towards IIF is realised. This particular session allows fifty members of Babcock Marine, Royal Navy, Ministry of Defence, Police, Guard Force, Fire Services and primary Lodger Units to join the previous 150 participants in experiencing the profound impact the 2 days will have.
The site IIF Leadership Team consisting of a cross-section of membership, including trade unions, continues to meet. The team has recently been strengthened with the membership of the Fleet Services Director. This team looks at the technical fixes required and the adaptive challenges facing the site in relation to IIF.
Overall the site’s journey towards Incident and Injury Free has made substantial advances in the past 12 months. Promoting IIF and the values of care and concern has created a strong foundation for a culture intolerant of any compromise relating to safety as the joint number one goal on the Clyde. The commitment has been made and demonstrated in our day to day actions. This foundation will continue to be strengthened by a process of continuous improvement and shared safety learning.
1.3 Diving Safety
This year the Diving at Faslane has been exceptionally busy with ongoing work on the Jetties giving high diving time.
This year there has been one event of note. Two Northern Diving Group (NDG) divers strayed into an area where they received a slightly higher dose of radiation than expected although well within our accepted Level (which is set at 6msv. per year, well below the legal requirement of 20msv per year). It immediately triggered a high level Event Review Board (ERB), headed by a Director and Senior Naval staff. The board quickly identified improvements to prevent a re-occurrence of the incident.
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The Estates Department have renewed their contract with Shearwater and have agreed on an improved communication process.
Our membership of the Association of Diving Contractors (ADC) includes the Devonport Site.
During the year we receive Bulletins and monthly updates which keep us well informed of risks and current industry standards. This information is then distributed to relevant persons on site.
NDG recently had an audit looking at their facilities and husbandry practices. No CPARS were raised during this audit although some advice was given on minor non-conformances.
1.4 Introduction of Event Review Boards (ERB’s)
During the previous reporting period, Incident Review Boards were introduced at HMNB Clyde to improve accident investigation standards and ensure effective measures to prevent recurrence were implemented. Boards are convened by Heads of Department for all injury accidents and for other significant incidents. Their function is to review the initial incident investigation findings, determine the root causes, consider any additional factors not identified and provide feedback to all staff to prevent recurrence.
In December 2008, a Single Event Reporting system was introduced to enable more effective capture and co-ordination of details arising from accidents, incidents, nuclear safety events, weapons and explosives accidents/incidents and near misses. As a consequence, there is now greater scope for convening boards which have subsequently been retitled Event Review Boards (ERB's). All RIDDOR Reportable Events are chaired by a Director.
Other than in very exceptional circumstances, ERB's must be held within ten days of the event and the outcome will result in:
• Enhancement of existing safe systems of work.
• Dissemination of those issues which are likely to have site-wide implications (Safety Alerts, Lessons Learned, etc.).
• Monitoring of trends arising and reporting the results at departmental SHEF committees for consideration.
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2.0 STATISTICAL ANALYSIS - ACCIDENTS/INCIDENTS
The use of statistics provides an effective means of measuring our health and safety performance. Continuing improvement in health and safety standards requires knowledge of the effectiveness of existing arrangements.
The top three issues in relation to the cause of accidents were, slips/trips and falls, manual handling and striking against.
2.1 Cause:
The major accident causes for this period were, slips/trips and falls, manual handling, striking against and struck by moving falling object. This was similar to last year except that slips/ trips and falls took over from manual handling as the top cause of accidents. Accident numbers fell in all categories except slips/trips and falls, we had a sharp rise in slip incidents during the winter months partially as a result of some unusual weather conditions. Campaign resources have been allocated to raise awareness and improve winter preparedness planning.
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2.2 Accidents by Directorate:
There were reductions in Major, RIDDOR over 3 day and Minor categories across the board. It should be noted that the year on year comparators are affected by restructuring of the business which results in departments transferring to different directorates.
MAJOR MINOR TOTAL >3DAY Business Services 0 0 11 0 11 0 HR & Crew Services - 2 - 35 - 37 Fleet Services 3 8 45 68 48 76 Operations - 8 - 48 - 56 Estates 5 - 73 - 78 - Nuclear Operations 1 - 14 - 15 - Technical 0 - 2 - 2 - Captain HMS Neptune 0 0 9 8 9 8 DW 0 1 7 9 7 10 Superintendent Fleet Maintenance 1 0 1 1 2 1 DSA 0 0 2 2 2 2 EDC 0 0 0 0 0 0 Clyde Strategic Programmes Director 0 0 1 1 1 1 TOTAL 10 19 165 172 175 191 Note: figures in blue are for the period 2007/2008
2.3 Dangerous Occurrences:
There was only one RIDDOR dangerous occurrence reported during the reporting period.
Incident No. Incident Date Event 7873 02 October 2008 Source container failed to return to a safe location following exposure. Emergency plan was prepared and the source and pigtail were reconnected to the winder cable and successfully withdrawn in to the normal source container.
2.4 Near Misses:
The roll out of IIF in conjunction with increased awareness and coordinated campaigning has resulted in a 256% increase in the number of near misses reported at HMNB Clyde compared with last year’s 31.2% decrease.
The significant increase in near miss reporting has allowed us look at the relationship between unsafe acts and unsafe conditions.
The top 10 causes produced below shows that the category “remaining other causes” is the largest with 111. This is simply because of the wide range of different near misses reported and the figure represents incidents which did not fall into the other nine categories.
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2.5 Unsafe Acts and Unsafe Conditions
Analysis of last year’s near miss reports has identified that we need to focus effort into reducing the number of unsafe acts and conditions on the site. The aim of this approach is to ensure that by intervening appropriately we can remove a factor which will prevent the chain of events which leads to an injury accident.
Last year there were 181 unsafe acts which resulted in near miss reports and 169 unsafe conditions which resulted in near miss reports.
By pursuing an active safety policy based on the elimination or remediation of unsafe acts and conditions, it is possible to achieve a reduction in bad habits and practices and hence accidents. Similarly, the unsafe conditions listed below are fairly typical of the types of unsafe conditions dealt with regularly by the Safety Department.
Unprotected openings or hatches Unguarded machinery Defective, rough, sharp, slippery, decayed, cracked surfaces Poor housekeeping, Inadequate lighting, glare, reflections Ungritted areas during icy conditions Unsafe loads Inadequate vehicle and pedestrian segregation
Analysis of reported unsafe conditions will be used over the coming year to improve our performance and drive down the number of near misses leading to injury accidents.
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Total 350
Unsafe Conditions 169
Unsafe Acts 181
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3.0 ENVIRONMENT
3.1 Environmental Management System (EMS)
The HMNB Clyde environmental Management System continues to develop within the CMS frame and during the year an Environmental Compliance Module has been developed as part of the CMS system. This has been designed in order to “signpost” the relevant sections of the standard and to guide the user through ISO 14001. The new aspects process has been developed to enable links to the relevant legislation and processes held on CMS and to make the system of identifying environmental aspects more user friendly. Further technical audits have been scheduled into the audit programme to ensure we are looking at all environmental impacts base wide.
3.2 ISO14001 Certification
During 2008 the EMS underwent some major changes. The 5th surveillance audit in April resulted in four major non-conformances being raised. HMNB Clyde had three months to address these issues before a special surveillance audit would decide whether enough work had been carried out in order to close them out. This additional visit went well and all four major non-conformances were closed.
The second visit by LRQA was the recertification audit for the ISO 14001 EMS. The audit went well with HMNB Clyde being awarded the recertification with no major non- conformances being raised. Six minor non-conformances were raised throughout the week and CPAR’s have been raised internally to address these.
The development of the aspect register and the compliance Module on CMS were both commented on favourably by the auditors.
3.3 Integrated Pollution, Prevention and Control (IPPC)
No incidents were reported during 2008 as part of the NUB permit. SEPA has again scored the base highly on it’s annual performance assessment which means our inspection frequency by SEPA should be reduced.
The only outstanding issue with regards to the NUB permit is the requirement for a functioning chlorination unit. Work has been ongoing throughout 2008 to find a solution that is acceptable to both SEPA and HMNB Clyde. The initial cleaning of the system is scheduled for April 2009 with the chlorination unit taking over this function once the system has been cleared of marine growth.
A noise survey was carried out as part of the permit requirements during 2008 and the annual reports were sent to SEPA on time. No adverse comments have been received from SEPA on the reports provided.
3.4 Land Quality Assessment (LQA)
As per the MoD Sustainability Development Appraisal Plan these assessments are not required to be carried out annually. HMNB Clyde has in date land quality assessments that met the MoD requirements.
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3.5 SEPA Site Visits
The Operator performance Assessment for 2008 was received during January and once again HMNB Clyde received a high score. This score will be used by SEPA to calculate the inspection frequency for this site during 2009. During 2008 SEPA made 19 routine sampling visits to the sewage treatment works with no adverse findings being recorded. Two further visits were made to the NUB as part of the permit requirements. The second visit concentrated on the chlorination unit and the team has been working with SEPA to resolve the issue of excess marine growth. SEPA granted permission for a one off cleaning of the system of marine growth.
3.6 HMNB Clyde Utility Policy and Strategy
Energy consumption continued to be a key focus area during 2008 with the Utility Review Working Group meeting on a monthly basis. The chair of the Group has now been taken over by the Estates Director. The focus of the group will be to link in with the business objectives and MoD targets for energy.
Energy audits have been carried out in various, representative, areas of HMNB Clyde and a report has been made available highlighting areas where improvements can be made – some of these at little or no cost.
3.7 EU Emissions Trading Scheme
2008 was the first year of Phase ii of the Emission Trading Scheme and Lloyds Register carried out two verification visits to finalise the emission figures for 2008. These were carried out in November and February and the emissions for 2008 have been entered onto the EU registry. For the second year in a row both Faslane and Coulport were under their allocation for CO2 emissions so no internal trading was required for 2008. The allocations are also on the registry for 2009 so the balance listed below will cover the emissions for this current year.
Site CO2 Allocation Actual CO2 Emissions Site Balance Faslane 23956.5 te 21158 te +26755 te Coulport 9406 te 7592 te +11220 te
3.8 Defence Fuel Group Audit
The MT installations have full licenses valid until 2010 with the exception of the forecourt at Coulport which is working on a restricted licence due to the requirement for a water/oil interceptor to be installed. The jetties temporary licence has been extended to August 2009 to allow for completion of the installations of the two new diesel tanks.
3.9 Water Environment Oil Storage (Scotland) Regulations 2006
Work will be completed during 2009 on the Clyde Marine Unit (CMU) diesel tanks at Coulport and Faslane with work being started on the CMU petrol tank at Faslane. Until this work is complete a Base risk will remain in place.
Surveys were carried out on the Oil Storage at Faslane and Coulport by Royal Haskoning during December 2008 and January 2009. Work is currently under way to produce a plan for
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2009/10 to highlight the work that is required to meet the second deadline for general land based oil storage. The date for compliance is 30th April 2010.
3.10 Scottish Pollution Release Inventory (SPRI)
As one of the major industrial sites in the West of Scotland and a class A site under the Radioactive Substances Act 1993, HMNB Clyde is required to complete an annual SPRI return for both Faslane and Coulport. The SPRI is a public register of sites that release emissions to air, water, land or any combination of the three. The returns for HMNB Clyde were completed on-line for 2008. The information provided is on the public register and SEPA sends the information to Europe to be included in the European Pollution Release Inventory.
3.11 Environmental Exercises
MACR requires that each site should exercise on-site emergency plans on a regular basis and in accordance with this requirement, an environmental table top exercise was conducted at Coulport in December 2008.
In determining the exercise scenario, consideration was given to identifying an area where a significant risk to the environment could arise. The area selected was the Clyde Marine Unit fuel tank located on the Loch Long shore side and the scenario related to re-fuelling of the fuel tank during silent hours working, when only a limited number of staff would be present.
While the outcome of the exercise concluded that the competence of Coulport duty staff and the resources available were adequate for controlling and containing a fuel spill, there was scope for further enhancement of existing arrangements. These would be addressed through CPAR's raised by the exercise assessment team.
3.12 Environmental Incidents
No. of Incidents RELEASE OF SUBSTANCE TO LAND 11 6 RELEASE OF SUBSTANCE TO WATER 16 6 RELEASE OF SUBSTANCE TO AIR 0 3 MACHINERY/EQUIPMENT 2 2 POL PAINT OR OIL LEAK 10 19 OTHER ( ANIMAL& HOUSEKEEPING 2 6 TOTAL 41 40 Note: figures in blue are for the period 2008/2009
The number of reported environmental incidents remained almost the same as for 2007/08. The majority of incidents fell into two categories – oil spills and sewage discharges from hoses. All the reported oil spills had different causes but procedures were rewritten to improve the way these incidents are reported and in all cases the spill was cleaned up using the appropriate spill material which was then correctly disposed of via the Material Assessment Centre (MAC). The sewage incidents related to the process not being followed due to inaccuracies in the procedures. This has been addressed and the process updated. There were several incidents from the Water Treatment Works but these were resolved with the cooperation of the Base Response Team and Project Aquatrine.
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3.13 Environmental Workshops
The first set of workshops held in conjunction with Envirowise related to Waste Management and Recycling. Two workshops were held in October and November 2008 and covered ways of increasing the waste segregation to improve our recycling figures. As a result of the workshops an Action Plan was developed which has been incorporated into the Pride in the Clyde Initiative.
The second workshops centred around water usage and these workshops took place during February and March 2009. During the visits leaks were identified in two areas which were reported and repaired. The final report and recommendations is expected by the end of May 2009.
3.14 Waste Management
A Waste Forum Focus Group consisting of MoD and Babcock Marine employees was formed on January 2009, spearheading the opportunities to recycle throughout both Coulport and Faslane.
Various avenues of the media have been employed to publicise the requirement to increase recycling throughout HMNB Clyde. Shaun Baxter, Grounds, Waste & Buildings Manager and Richard Ireland, Estate Requirements Manager were invited along to Your Radio and gave a short but informative talk on the initiatives being delivered at present here at the Base
Articles have also been published in Clyde Courier, Basetalk, The Helensburgh Advertiser, Lennox Herald and the Evening Times, these newspapers ran articles, highlighting the drive to improve recycling.
The goal for 2010 is to reduce the amount of waste by 5% and to recycle at least 40% of our total waste. At present we are achieving 36% which is commendable but still short of our target. Further waste initiatives such as centralised waste locations for toner cartridges are imminent and investigations into new recycling techniques are planned for later this year.
2008 to 2009 has seen a 10% reduction of waste being sent to landfill and an increase of 7% recycling. This is excellent progress; however the challenge we have is to continue to improve on previous efforts.
Achievements to date
2008-2009 Landfill reduced by 10% 2008-2009 % waste recycled increased by 7%
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4.0 NUCLEAR SAFETY EVENT REPORTING
Reference(s)
A. SJ-STAN-013 Base Standard 13 Nuclear Safety Event Reporting & Operational Experience Feedback Policy. B. NSA-PM-005 Investigation of Nuclear or Radiological Safety Events and Incidents. C. NSA-PM-006 Nuclear Weapon Safety Event Recording and Reporting. D. NSA-PM-001 Issue and Control of Internal Regulatory Improvement and Prohibition Notices.
Reference A is HMNB Clyde’s Policy for Nuclear Safety Event Reporting and Operational Experience Feedback. This Policy is applicable to all nuclear safety related incidents and events within HMNB Clyde Authorisee’s delegation. It does not change reporting requirements stipulated by other Authorisees and other reporting systems but does call for all incidents and events within the site or aboard vessels within a facility to be captured within HMNB Clyde’s Nuclear Safety Event Report system. Thus an incident may be reported by more that one means but will normally be the subject of a single investigation. The reporting system is not a means for attaching blame to any person making a mistake which leads to an event. Nuclear Accident Arrangements are outside the scope of this policy.
The Nuclear Safety Event Reporting system is the means by which nuclear and radiological events and incidents occurring in HM Naval Base Clyde are recorded, investigated, assessed, findings actioned and lessons learned disseminated. The DNSR requires the Authorisee to define the arrangements under Naval Base and Nuclear Weapon Authorisation Conditions (AC7 and AC23). The processes are essential tools for continuous improvement and the maintenance of a robust safety culture.
HMNB Clyde has arrangements (processes) in place for the reporting, notification, investigation, review and assessment of nuclear and radiological safety related events. These processes are at References B and C.
The Nuclear Safety Assurance Manager (NSAM) is responsible for sponsoring and administrating, in collusion with Base Quality Assurance (BQA), the Clyde Nuclear Safety Event Reporting System and the loss of shore supply reports. This includes assessing nuclear safety events and incident reports for bearing on nuclear safety.
4.1 Categorisation of Events
Events are categorised in accordance with their potential consequences initially by NSAM and the Nuclear Safety Assurance Section (NSAS) and then by a Suitable Qualified Experienced Personnel (SQEP) body, currently the Vessel Support Coordination Meeting (VSCM), such that appropriate depth and speed of investigation can be applied.
There are four categories used, A through to D and consequences are summarised below:
A. High potential for or actual radioactive release to the environment. B. Actual or potential for a contained release within Building or submarine. C. Potential for future release by failure to adopt good practice and continuous improvement . D. No or little potential for release.
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The reporting scales, notification and the level of investigation requirements are laid out in Reference A.
4.2 Investigating Officers
The Investigating Officer is to ensure that the event is investigated to the prescribed Level of Investigation, in the designated timescale, in the correct format and includes the appropriate detail i.e. stating the immediate and root causes, recommendations and corrective actions required preventing recurrence. Where required, Investigating Officers are to be appropriately trained in Root Cause Analysis.
4.3 Findings
A target date of 6 months is set for the completion of all recommendations and corrective actions resulting from an investigation. Where this timescale is not achievable a SQEP review panel decides on the appropriateness of extending the deadline, the application of greater resource or regulatory censure (Reference D).
4.4 Operational Feedback, Experience, Reports and Trend Analysis
Lessons Learned summaries and Site Incident Report Assessments are distributed to the principal Output Directors and their key managers for line dissemination. CAPFASFLOT is included for all events concerning submarines.
Summaries are copied to MoD Operational Experience Learning Groups (OELG) members (HMNB Devonport, BAE, VULCAN, NRPA and NPOS SM) and the National OELG. Completed Nuclear Safety Event Reports (NSERs) are returned to the reportee and copied to other Base departments involved in the event.
NSERs are reported routinely to the Nuclear Safety Committee (NSC) and to DNSR at the Site (Level 3) Regulatory Interface Meetings. Arrangements are in place to notify DNSR immediately for serious incidents.
In administering the NSER system, the AD monitors for trends that may require urgent corrective actions and provide appropriate warning/advice. NSERs are reviewed on a quarterly basis and trends reported to the CNSC in an annual report.
4.5 NSER Process Developments
Nuclear Safety Events are now recorded and managed using the Single Event Reporting Process (CMS-PM-017) which was introduced in December 2008. The new process provides a single point of contact for all reportable events that occur at Clyde which are then recorded in the EMMA database. The NSAO(S) is the lead discipline for all nuclear safety events.
4.6 NSER Statistics 2008-09
• (71) NSERs were raised in the period from April 2008 to Mar 2009. • (53) of these have been closed in this period April 2007 to Mar 2008. • (18) of these remain open, either under investigation or awaiting confirmation that actions have been completed, of which (2) are overdue. • (47) NSERs were carried over which remained open from previous periods. • All of these were closed in the period April 2008 to Mar 2009.
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Breakdown of the NSERs raised
NSERs raised 2008/09 Category Total A B C D NUMBER 0 8 32 31 71 ASSOCIATED S/M IR 0 3 3 0
NSERs raised Category 2007/08 Total A B C D NUMBER 2 7 59 28 96 ASSOCIATED S/M IR 1 5 5 0
NSERs by Category 3-year comparison
60
50
40 30 20 D 10 C 0 B A 06-07 07-08 08-09
Analysis
Clyde had no Category A events this year.
The number of Category B events has remained similar to that of last year with the root causes remaining broadly similar i.e. significant procedural errors, low levels of contamination detected and avoidable doses received. It should be noted that in all instances where contamination was found, the follow up actions were prompt and robust and also a Prohibition Notice is still in place as a result of additional dose accrued during diving operations.
Category C events almost halved this year. This may be attributable to the large number accrued last year during the RAMP undertaken by the Trafalgar Class submarine and also those accrued by visiting submarines.
Approximately 50% of all events recorded are losses of electrical shore supplies to the submarines; the majority of which are as a result of electrical panel operations undertaken on the submarine. These are recorded as Category D events. The figures have been elevated due to the number of losses that have occurred whilst undertaking tests on submarine electrical machines following their repair or significant overhaul. Future events of
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this nature i.e. losses that occur whilst machines are being tested under procedural control will not be recorded.
Root Causes
There is usually more that one root cause surrounding an NSER; the data below shows what was considered to be the principal cause.
Breakdown of Closed-out NSERs by Principal Root Cause (2007/08 figures for comparison.
NSERs closed-out between Apr 2008 and Mar 2009 broken down by Root Cause Root Human Documentation Technical Training Resource Other Total Cause Factors Number 70 11 16 1 1 2 100
NSERs closed-out between Apr 2007 and Mar 2008 broken down by Root Cause Root Human Documentation Technical Training Resource Other Total Cause Factors Number 68 13 20 2 3 3 109
Closed Out NSERs in 2008-09 by Principal Root 2% Cause 1% 1% 11% Human Factors Technical 16% Documentation Training Resource 69% Other
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Closed Out NSERs in 2007-08 by Principal Root Cause 3% 2% 3% 12% Human Factors Technical Documentation Training 18% 62% Resource Other
Root Cause Groups above are a general heading for the root causes identified.
4.7 Inspection for RSA 93
SEPA operational assessment against RSA 93 was unsatisfactory, as a result of the HMS Torbay Primary Effluent Barge (PEB) incident in 2008. Action is in hand to address these shortfalls. DNSR/NII/SEPA are satisfied with the progress being made and it is anticipated will gain a satisfactory assessment next year.
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5.0 WEAPONS SAFETY ASSURANCE
Nuclear Weapon Authorisation has now matured to the point where its implementation and control is now very similar in principle and philosophy to that of Nuclear Propulsion. A number of findings from the DNSR pre-authorisation inspection remain open but continue to be worked out, including those that rely upon the delivery of documentation from sources outwith Clyde. A NWAC audit programme has been initiated.
A regime similar to that for Nuclear Activities has been established for Warships in Harbour (WIH) covering warships of any class when berthed in Faslane. WIH is regulated by the Naval Authority Explosives and covers all UK naval bases where warships are berthed with their explosives maintained in a quiescent state. Where handling activities are required, a licensed berth, such as the Explosives Handling Jetty (EHJ), must be used. Clyde’s current certification expires in September 2009 and recertification requires demonstration of progress with Authorisation Condition Compliance Statements, very similar to the Nuclear ACs but less in number, close-out of Forward Action Plans (FAP), and demonstration of ownership of all aspects of WIH. Good progress has been made and all of the Compliance Statements have been through Due Process and published on CMS. All areas have recognised owners and a significant number of FAP’s have been referred to the Regulator. Continuous Improvement, as with Nuclear Authorisation, is expected by the Regulator.
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6.0 FIRE
6.1 Organisation
In September 2004 the Minister for the Armed Forces directed that the MoD Fire and Rescue Services, encompassing all the Civilian fire-fighters, RAF Trade Group 8 and RN Aircraft Handlers (RN(AH)), should be merged into a single, integrated and regionally based organisation to be known as the Defence Fire & Rescue Management Organisation (DFRMO). The formation of this organisation was to be achieved in two stages beginning with the Initial Operating Capability (IOC), on 4 September 2006, followed by Full Operating Capability (FOC) in April 07.
The transition to the new organisation had little impact on the “customer base” other than new job titles for Fire Service staff. One of which was the change of the Area Fire Prevention Officer (North) (AFPON(N)) title, which has now become DFRMO Group Manager (Scotland), 51 (Scottish) Brigade.
6.2 Fire Risk Assessment
On the initial implementation of the Building Co-ordinators it became apparent that there was a shortfall in the fire safety management systems throughout HMNB Clyde. The reason for the shortfall arose from the Building Managers receiving a lack of training and information.
With the change in legislation and DFRMO’s structure, the Building Manager and Health & Safety Department have been working very closely with the Station Officer to resolve this shortfall by introducing a comprehensive management system. The changes will include:-
• Fire Safety Policy • Fire Safety Log Book • Fire Evacuation Teams in each building • Training for both Building Co-ordinators and Fire Evacuation Teams • Building Fire Safety Toolbox Talk for building occupants
Fire evacuations commenced in April 2008 and will continue to be conducted in a phased approach, as each evacuation is conducted the requirements for evacuation teams will be assessed and implemented on a lessons learned basis.
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6.3 Fire Safety Management Plan (FSMP)
Breakdown of FSMP assessments delivered during 08/09 for HMNB Clyde and its outstations was:
Establishment High Medium Low Total
HMNB Clyde – Faslane 3 12 12 27
HMNB Clyde – Coulport 0 0 0 0
HMS Caledonia 0 0 0 0
Navy Buildings Greenock 0 0 0 0 Scottish NATO POL 0 0 0 0 Depots
Note: 1. There were no FSMP’s schedule for HMS Caledonia or Navy Buildings Greenock during 08/09.
6.4 Fire Incident - Statistical Analysis
Fire Incidents 2008 - 2009 2007 - 2008 Fires 13 14 Fire False Alarm - Equipment 133 100 Fire False Alarm - Good Intent 10 12 Fire False Alarm - Malicious 20 22 Fire False Alarm - Unwanted 214 272 Total 399 420
There has been a (5%) reduction in Fire Incidents from the previous year. Actual fires have decreased by (9%).
Ongoing replacement of old fire detection systems and more rigorous controls regarding the occupation of living accommodation has resulted in an increase of (33%) in False Alarms due to Equipment. These results may appear misleading however, as with the greater sensitivity of equipment, the opportunity of a fire developing is greatly reduced. It is envisaged that continuing replacement of detection systems over the coming months will result in fewer fully developed fires within the Base area and subsequently the greater safety of all RN Personnel.
Unwanted False Alarms have seen a reduction of (27%) possibly due to increased awareness. Fire Alarms, due to maliciousness have decreased by (9%), this is an area where education or ultimately discipline will reduce this category.
The establishment of the Building Co-ordinator Organisation should assist in achieving further reductions in the future through improved control of portable electrical equipment,
- 22 - HMNB Clyde SHEF Annual Report 2008-2009 improved education of building occupants and Contractors. Also the improved liaison with DFRMO staff will assist in raising Fire Safety Awareness amongst Base Staff.
An analysis of the main causes of Unwanted False Alarms is provided below:
Fire False Alarms - Unwanted - Causation 2008 - 2009 2007 - 2008 Steam/Dust/Gases/Aerosols 125 123 Accidental Damage/Activation 18 21 Cooking Processes 31 68 Smoking Materials 4 15 Exhaust/Cigarette Fumes 8 5 Machinery/Equipment 0 18 Hot Work 4 2 Heat from irons/fires/bulbs 2 5 Fire Alarm System Fault 10 0 Other 12 15 Total 214 272
Release of steam/dust/gases/aerosols is the predominant cause of alarm activations and relates to steam leaks and sensitivity of detector heads to aerosol sprays and steam from showers in the living accommodation, there has been a (1%) increase in this category. Occurrences of accidental activation by personnel working on alarm systems continues to be an issue, although there has been reduction of (14%). Cooking processes have seen a dramatic and encouraging decrease (55%) in the past 12 months. A trend which is testament to the good work being carried out in the Fire Safety of this establishment.
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7.0 OCCUPATIONAL HEALTH
7.1 Occupational Health – BM (C)
7.1.1 Introduction of e-Opas
e-OPAS is a web based application. All data is stored centrally on secure servers. As a fully integrated health management software application, e-OPAS facilitates a pro-active occupational health solution with the potential for targeted health surveillance and improved staff awareness to health. With a view to electronic storage, all new employee records are added as and when the employee’s initial appointment is made. Pre-existing and ongoing employee cases have been added to the database with existing records scanned into e- OPAS.
7.1.2 Management of Sick Absence
The company target has been set at 3%. This is calculated by the actual number of days absence in month, divided by actual number of employees in a 30 day month, expressed as a percentage.
6.00%
5.00%
4.00% 05/06 06/07 3.00% 07/08 08/09 2.00% Target
1.00%
0.00% April May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar
The total number of days lost form April 08 – March 09 was 13,785. Of these:
• 27% were 1-7 days i.e. self certificated • 19% were 8 – 21 days i.e. medical certificated • 54% were >21 days i.e. long term sick
OH continue to provide an early intervention triage of sick absences at 3 and 8 days to offer advice/support and appointments as appropriate (e.g. physiotherapy/employee assistance). Management are encouraged to address frequent short term absence via return to work interviews and the Capability Policy.
Long term absence has consistently accounted for an average of 49% of the total days lost. These cases are closely managed by OH liaising with Management and HR regularly and discussing actions / decisions at monthly case management meetings
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7.1.3 Case Management
Employees absent from work through illness account for the majority of case management. OH role is to provide early intervention, support the employee throughout their absence, and encourage a return to work at the earliest stage (vocational rehabilitation is considered where appropriate). All formal case management interventions generate an outcome report to management and HR to assist and inform their actions.
Table 1 Referral Type 2006/07 2007/08 2008/09 Short Term Sick 199 546 672 Attendance 38 40 37 Fitness for Work 33 38 14 Long-Term Sick 221 447 479 Pre-employment 107 20 153 Total 598 1091 1355
The referral type has been changed from previous annual reports to accommodate the data extracted from e-Opas.
7.1.4 Treatments
The total number of treatments on site for minor injury, incidental illness and primary care reviews (e.g. blood pressure checks, wound dressings), and physiotherapy was 2424. Table 2 contains a breakdown of treatment services provided:
Table 2 Treatment Type 2006/07 2007/08 2008/09 Accident on Duty 111 99 139 Fitness For Work 63 42 29 Review 51 313 132 Physiotherapy 1147 1455 1572 Incidental Illness 330 516 372 Total 2010 2424 2244
NB. The category breakdown for gathering the above information was improved in 07/08 and accounts for the difference in some comparison categories.
7.1.5 Workplace Visits
It is a priority of OH to understand the specific work areas and practices on site. In order to achieve this we have commenced a proactive work place visit plan resulting in a comprehensive knowledge of working teams in all areas. The aim is for OH to compile a risk register, identifying potential health hazards and instigate health surveillance as appropriate. The risks identified and preventative measures taken to date include:
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• Respiratory Sensitisation – annual spirometry and face fit tested PPE • Noise Induced Hearing Loss – 2 yearly Audiometry (or sooner, results dependent) • HAVS – all employees potentially exposed have an annual review • Occupational Dermatitis – PPE advice + awareness presentations + annual skin surveillance
In some job roles fitness for work is dependent on medical criteria. OH has introduced safety critical and confined space medicals where appropriate with review being age dependant. e-Opas has given OH the ability to produce a comprehensive recall system for all of the above.
7.1.6 Health Assessment/Surveillance
A variety of health assessments were carried out during the year. These included certain groups of employees, who, by the nature of their work may place themselves or others at risk if they develop certain medical conditions e.g. MHE drivers, radiation workers. There have been 8 cases of HAVS diagnosed and 1 case of Occupational Dermatitis.
Table 3 Health Assessment/Surveillance 2006/07 2007/08 2008/09 Type Lifestyle Screening (Voluntary) 120 21 22 Display Screen Equipment 4 0 2 Night Workers 12 16 4 Food Handler 3 5 4 Audiometry 18 134 182 Lung Function 77 31 118 Skin 2 147 198 HAVS 2 4 116 Visual Acuity 135 95 67 Confined Spaces Medical 66 120 185 Safety Critical Medical (Driving / MHE) 99 67 146 Radiation Medical 15 13 8 Total 554 629 1052
1. Safety critical and confined space medicals include visual acuity and are not shown separately in the table. 2. Confined space medicals include lung function and are not shown separately in the table.
7.1.7 Physiotherapy
Musculoskeletal disorders are one of the most important health risks facing any business, as a cause of occupational injury / ill health and as a cause of sickness absence. The physiotherapy service provides treatment interventions that have been shown to positively impact the employee’s ability to remain at or return to work.
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Total Number of Physio Appointments - 3 year comparison 200
150
100
50
0 Apr May Jun July Aug Sept Oct Nov Dec Jan Feb Mar
Total 06/07 Total 07/08 Total 08/09
7.1.8 Potential man hours saved
Treatments
If onsite treatment of minor injury, incidental illness and primary care reviews (E.g. blood pressure / cholesterol checks) were not provided, the expectation is that the employee would take either ½ day notional (4 hours) to see for example a practice nurse or a full day absence (8 hours) to see their GP. This is the basis on which the potential hours saved is calculated.
The potential man hours saved year to date is 3351. This conservatively equates to £67,020 (based on £20 hour)
Physiotherapy
If the onsite physiotherapy treatment service was not available it is predicted that employees would take an average of 2 days (16 hours) off following initial injury to rest and make GP appointment, followed by a ½ day notional (4 hours) for each treatment by an NHS or private physiotherapist
The potential man hours saved year to date is 9360. This conservatively equates to £187,200 (based on £20 hour).
Cumulative total for treatment service is £254,220
Potential Man Hours Saved Total - 3 year comparison
14000 12000 10000 8000 6000 4000 2000 0 April May June July Aug Sep Oct Nov Dec Jan Feb Mar
Yr 06/07 Yr 07/08 Yr 08/09
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7.1.9 Clinical Audit
With the introduction of e-Opas, audit this year has been focused on the data input, to ensure accuracy and consistency of the clinical records.
7.1.10 Health Promotion
OH present a rolling programme of health promotion topics that focus on the prevention/reduction of occupational diseases and personal risk factors. The promotions were delivered using a variety of media including, poster, leaflets, tool box talks and on site campaigns.
The topics covered this year included:
• Occupational Dermatitis • HAVS • Workstation Ergonomics • Ergonomic Driving Posture • Prevention and Recognition of Bowel Cancer • Food Safety • A Sensible Attitude to Alcohol • Travel Health • Finances and Relationships • Men’s Health • Get Fit for Summer – Circuit Training - £445 was raised for Breakthrough Breast Cancer • Smoking Cessation
7.1.11 Collaboration with External Public Health Organisations
The Anthony Nolan Trust
The Anthony Nolan Trust recruits and manages donors to a UK bone marrow register. They provide a lifeline to patients with bone marrow disorders like Leukemia where there is no other hope of a cure. OH hosted a recruitment day in October, inviting any employees on the base to come forward. Despite the strict criteria for donors, there were 8 successful entrants to the register.
The Scottish Blood Transfusion Service
OH now co-ordinate and host twice yearly visits form the Blood Transfusion Service. This year 204 employees volunteered with 168 units of blood being donated.
7.1.12 Summary
Duradiamond Healthcare is to continue as Babcock Marine’s preferred OH provider for a further three years. We will continue to develop our services to meet the changing demands of the business. We are increasing our physiotherapy service to 4 days per week and intend to introduce counselling interventions to address psychological conditions.
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7.2 Occupational Health –MoD
7.2.1 Organisation
The MoD Occupational and Environmental Health and Hygiene Department (OEHHD) is responsible for providing a comprehensive occupational health service to Service and MoD civilian personnel working at HMNB Clyde and to other MoD customers in the FOSNNI area. In addition to this, the OEHHD provides environmental health, pest control and occupational hygiene services to HMNB Clyde as a whole, including the commercial partner. Led by a Consultant Occupational Physician, the department comprises of three specialist nurses, one occupational hygienist, two environmental health officers, a certified pest control officer, one first aid instructor and two administration staff
7.2.2 Noise at Work
Employees working in “hearing protection zones” identified by a noise survey receive regular health surveillance, having an audiogram every 2 years, or more frequently if required. In addition to the occupational hygiene section, the occupational health section of the OEHHD also supports the HS&E Department in their ongoing programme of noise assessments at HMNB Clyde.
The OEHHD is running the Medical Centre hearing conservation programme for all Servicemen and local MDPGA personnel as well as MoD civilian employees exposed to noise.
7.2.3 First Aid Training
The OEHHD provides a variety of first-aid training courses, including appointed person training. Table 1 shows the breakdown of this provision in terms of Base-Partnered areas and the remainder which will comprise, service personnel, Base lodger units and FOSNNI areas establishments. The ability to conduct internal first-aid courses rather than have an external supplier gives a considerable saving to both the Base and to MoD Establishments. Based simply on training costs per person, as supplied by The Red Cross, FAAW would have cost £12,648 and Appointed Persons £10,829. Level 2 training in HMS EXCELLENT would have cost £31,400 in T&S.
Table 1: First aid training outputs
Course Type Number of Numbers trained Courses Held: Per Course Type: First Aid Level 2 20 157 FAAW 7 51 Appointed Persons 15 119
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7.2.4 Health Surveillance
The OEHHDs health surveillance activities over the last year are summarised in Table 2:
Table 2: Statutory Medicals and Health Surveillance
STATUTORY MEDICALS AND HEALTH SURVEILLANCE ACTIVITIES APPRENTICE 13 11 BASCCA 44 55 BLOODS 3 3 CONFINED SPACE 21 33 DF&RS 18 - DIVING 22 17 ENG/MCA 120 99 EYE TESTING 159 99 FLT/MHE 55 67 FOOD HANDLING - - HEALTH SURVEILLANCE (COSHH) - - INITIAL HEALTH ASSESSMENT 6 11 JETTY CRANE 2 12 LGV/PCV 21 21 MEDICAL PRELIMS 134 122 OTTO FUEL/THALLIUM 16 18 OVERHEAD CRANE 8 11 SPIROMETRY/VITALOGRAPH 154 190 Note: figures in blue are for the period 2007/2008
7.2.5 Health Promotion
OEHHD maintains an active programme of health promotion activities as shown in table 3. This programme is co-ordinated through the Health Promotion Committee working closely with colleagues in other departments to maximise the impact of health promotion activities across HMNB Clyde.
Table 3: Health Promotion Activities 2008 -2009
HEALTH PROMOTION ACTIVITY MARCH OH and GP – No Smoking Day (National and Military). Poster campaign and Mobile Stand and Materials. OH and Practice Nurse led advisory session in mess SEPTEMBER Diabetes Awareness. OH led. Poster Campaign in RNSQ. OCTOBER Flu Vaccination and Awareness Campaign. (Scottish Government – Healthier Scotland.) GP led. NOVEMBER Choose Life. One Day Workshop on Self Harm. DCMH led. NOVEMBER Mouth Care Action Week. (National) Poster and Leaflet Campaign. Dental Department led with OH assistance.Mental health, Suicide Awareness week
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7.2.6 Departmental Activity Statistics
The activities of the OEHHD, other than health surveillance, for the last two years are summarised in Table 4:
Table 4 Summary of OEHHD Activity
ACTIVITY FRESH CASES 296 252 TOTAL REVIEWS 329 336 RETURNS TO WORK 65 55 ACCIDENTS AT WORK 40 21 CONTRACTORS 262 273 AUDIOMETRY 579 790 VACCINATIONS 20 36 WORKPLACE VISITS 13 - TELEPHONE CONSULTATION 148 - Note: figures in blue are for the period 2007/2008
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8.0 OCCUPATIONAL HYGIENE
8.1 COSHH
There has been little activity for the majority of the year as regards exposure to specific hazardous substances that has required the services of the department. This latter quarter however has seen an increase in activity and currently investigations into exposures to isocyanates, styrene and a number of solvents are being held.
On the policy side, for MoD the deliberations on revitalising the guidance on the COSHH Regulations in JSP 375 are now at the drafting stage. It is hoped that 2009 will see the publication of this and its associated JSP leaflets.
8.2 Vibration
The assessment and mitigation of risks to health from exposure to vibration tend to be based mainly from managerial actions. The role of monitoring within the hygiene sphere of activity would be considered very minor and as expected there have been no requests to carry out field tests for vibration exposure this year.
Whilst this appears to be good news in that apparently the Base has no vibration assessments that may give rise to a risk of health effects, the ability for the section to undertake field monitoring, for a variety of reasons, has ceased.
8.3 Noise
There has been a steady stream of requests for assistance in either noise monitoring or in undertaking assessments throughout the year. The more unusual ones have come from the MoD Police, mainly in regards to the procurement of new equipment and the associated understanding of noise as part of the overall risks in the use of this equipment.
8.4 DSEAR
For most of this year there has been little activity under the Dangerous Substances Explosive Atmosphere Regulations. The section did provided lead support for an audit on DSEAR and it is likely that further work will follow from that audit.
8.5 Emergency Issues
Air quality has always been a problem across the Base requiring an input from both the OH and EH sections. This work load is probably due to a combination of declining integrity of some of the older buildings and the need to find additional work spaces in building originally designed for other purposes. To enhance our ability to monitoring air contaminants, a new indoor air quality meter was purchased in late 2008.This has proved to be a useful tool, although our ability to realise its full potential has substantially decreased since the introduction of DIIF in the MoD computer systems. The situation remains unresolved.
Another new item purchased in this year was a special light meter that is able to compare the relative brightness of both illuminated and luminating surfaces. An ordinary light meter generally measures light falling onto a horizontal, or near-horizontal, surface, giving an illumination value for that surface. However in work situations, that is only part of the problem, with the eye having to accommodate light being emitted from reflecting and
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luminating surfaces (such as computer screens). The meter is able to measure parts of the eye’s field of view and give luminance values for comparison with acceptable levels.
There have been some recent health concerns over the use of compact fluorescent, CF, bulbs. The Health Protection Agency has issued warning with regards to the release of mercury vapour should a CF lamp break and what actions to take. In addition, there are concerns over the output levels of UV light with certain style CF lamps and as such, direct replacement of the tungsten filament and halogen bulbs in desk lamps by CFs, should be taken with care. *HPA news release 9th October 2008
8.6 Statistical Summary of Occupational Hygiene Activities
The outputs are given in the same format as last year so as to differentiate the OH outputs to the Base partnered areas; the Base but MoD as lodger units (e.g. MDPGA) areas and finally the rest of the FOSNNI area for units and establishments within the DE&S TLB.
Table 5: OH Outputs
OH OUTPUTS Advisory work; external to Base 11 15 Advisory work; internal MOD only 8 16 Advisory work; internal 17 20 OH visits/survey work; external to 9 6 Base OH visits/survey work; internal MOD 19 4 only OH visits/survey work; internal 13 3 OH Meetings; all MOD 5 15 OH Meetings; Base only 21 20 OH Training/toolbox talk; Base only 1 0 Note: figures in blue are for the period 2007/2008
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9.0 ENVIRONMENTAL HEALTH
9.1 Food Safety
The majority of food safety inspections were undertaken in conjunction with the Local Authority EHO, from Argyll and Bute Council. There were no major findings. Several food safety spot checks have been carried out in Faslane and Coulport. In addition, a substantial amount of reactive advice has been offered, in particular the Supermess construction and its affect on the existing Fieldhouse Building Main Galley structure.
9.2 Pest Control
Extensive demolition and construction work throughout Faslane has led to an increase in the sighting and reports of rodents. Rat control is a very high priority and all reports have been actioned and followed up promptly.
Populations of the Herring Gull and Black-back Gull have been increasing steadily, along with reports from individuals of dive-bombing and aggressive behaviour. Several Herring Gull nests had to be destroyed on the Supermess building to allow contractors to continue safely with their construction programme.
An ongoing control programme of pigeons and jackdaws in the Shiplift and under the jetties has reduced the amount of bird guano and subsequently the exposure of personnel working on equipment in these areas.
Bird proofing of the old dog kennels at DM Coulport to prevent seasonal nesting of wild birds allowed for their scheduled demolition and construction of the administration facilities.
Fox control on MoD land continues in order to fulfil the MoD’s vermin control responsibility to its tenant sheep farmers. It was a successful year with numerous foxes culled resulting in a very successful lambing period for the tenant farmers.
The feral cat population at Faslane has remained constant following the re-homing of several young kittens during the year and the neutering of older cats before returning them to the base. A kitten was rescued from the razor wire by the Pest Control Officer and a Ministry of Defence Police Officer. This resulted in widespread coverage of the story in the local and national press.
9.3 Port Health
The Naval Base continues to be represented at the Scottish Port Health Liaison Network, which meets on a quarterly basis in the Glasgow City Council Offices.
The Environmental Health Department has been issuing the new Ship Sanitation Control Exemption Certificate (SSCEC), which replaced the Deratting Exemption Certificate and educating the executive regarding their responsibilities. The new system is working well, with certificates issued to Ships, Submarines, Royal Fleet Auxiliary and Commercial Vessels.
The Ship Sanitation Inspection (SSI) required prior to the issue of this SSCE certificate covers food safety and potable water management, habitability, communicable disease control and pest control management.
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9.4 Awareness Campaigns
No official awareness campaigns were undertaken however several articles were published in the Clyde Courier highlighting issues within the base and the role and responsibilities of the environmental health department.
9.5 Emerging Issues
The demolition of the Timbacraft site has led to a marked increase in the number of reported rodent sightings in the southern area of the naval base. The pest control officer has worked hard to ensure prompt action in each case and remains vigilant to respond to further incidents.
Populations of the Herring Gull and Black-back Gull have started to increase steadily and earlier due to the mild winter. The population will be closely monitored in conjunction with Babcock Marine building officers and additional controls maybe put in place to address the problem. The Common Gull licence from the Scottish Government has just been received and will give authorised individuals the ability to deal with this protected seagull where it nests in areas where access or use of equipment is required for operational reasons.
A submarine was treated for an infestation of rust red flour beetles whilst alongside. This involved de-storing, treatment of the infestation and taking on new food stores over a weekend. All the organisations involved worked well together enabling the submarine to continue unhindered with its operational programme.
This office has also inspected HMS DARING, the new DARING class Type-45 ship prior to its commissioning. A recent inspection was also carried out on HMS DAUNTLESS. Several inspections have also been carried out HMS ASTUTE, alongside in Barrow in Furness. Further inspections will be carried out in future vessels of the Astute and Daring Classes.
On request from the Naval Command Catering Adviser several visits have been made to Royal Marine and Naval Reserve units to give advice on meeting MoD requirements and statutory food safety legislation.
9.6 Other Activities
The Pest Control Officer took part in the very successful Families Day. As well as allowing his ferrets to be taken for a walk he raised awareness of the environmental health and pest control issues within the Naval Base.
A Ship Sanitation Inspection Presentation was given by the Naval Environmental Health Officer at a Training Day organised by Falkirk District Council.
The Naval Environmental Health Officer achieved Chartered EHO status through the Royal Environmental Health Institute for Scotland Continuing Professional Development Scheme.
9.7 Legislative Impact
There were no major pieces of environmental health related legislation implemented during this reporting year.
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9.8 Achievement of Objectives Set for 2007/2008
There were no major concerns following inspections of the Wardroom Galley, Main Galley, Civilian Canteen and the Spar Shop by the Local Authority EHO from Argyll and Bute Council indicating that informal spot checks and keeping in regular contact with catering staff has raised the standard of food hygiene practices.
The implications of the International Health Regulations are now fully understood by Captain Faslane Flotilla Vessels with regard to the Ship Sanitation Inspection requirements and the issue of the Ship Sanitation Control Exemption Certificates.
Numbers of incidents involving seagulls were decreased due to proactive work by the Pest Control Officer ie. Bird proofing, egg replacement, and close liaison with Building Officers and Supermess Site contractors.
9.9 Statistical Summary of Environmental Health Activities
ACTIVITY SHIP SANITATION INSPECTIONS1 – 6 4 SHIPS SHIP SANITATION INSPECTIONS1 - 4 2 SUBMARINES SHIP SAFETY AND READINESS 2 5 CHECKS (SARCS) DERATTING EXEMPTION 8 (19) 24 INSPECTIONS2 FOOD SAFETY INSPECTIONS – 4 5 SHORE ESTABLISHMENTS3 FOOD SAFETY SPOT CHECKS 3 4 PEST CONTROL VISITS4 249 180 REACTIVE VISITS– SHIPS 3 4 REACTIVE VISITS – SUBMARINES 2 4 REACTIVE VISITS – SHORE 10 2 ESTABLISHMENTS POTABLE WATER SAMPLING – 5 6 SHORE ESTABLISHMENTS5 LECTURES AND PRESENTATIONS 13 18 Note: figures in blue are for the period 2006/2007
1. Formerly Naval Medical Officer of Health (NMOH) Inspections. Since June 07 NMOH inspections have been combined with deratting exemption inspections under the new title of Ship Sanitation Inspections (SSIs). 2. Conducted alongside Local Authority EHOs 3. Follow-up visits included 4. Routine water sampling on ships and submarines has now been delegated to the medical representative onboard 5. Reports issued by signal.
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10.0 CARRIAGE OF DANGEROUS GOODS
10.1 Introduction
All dangerous goods (including hazardous waste) transported by HMNB Clyde are classified, packaged, marked, labelled and documented in accordance with the provisions laid down in statutory instrument 1573 (The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007) and ADR (European agreement concenring the carriage of dangerous goods by road).
10.2 Volumes of Dangerous Goods Transported
Below is a detailed breakdown of all dangerous goods transported on the public highway by HMNB Clyde (including its outstations) throughout 2008
Oil Fuel Depots Class 3 (Flammable Liquids) 4808274 litres
RNAD Coulport Class 1.1 (Explosives) 18710 kg Class 1.3 (Explosives) 10 kg
Medical Centre Class 6.2 (Clinical Waste) 977.6 kg
Crombie (RS 29) Class 2.1 (Flam Gas L/R/D) 205 kg Class 2.2 (Non Flam Comp Gas) 3891 Class 2.2 (Refrigerant) 1697 kg Class 5.1 (Oxidizers) 400 litres Class 9 (Miscellaneous) 6810 kg
GPSS Class 2.1 (Flam Gas L/R/D) 2539 kg Class 2.1 (Flam Comp Gas) 250 litres Class 2.2 (Non Flam Comp Gas) 9376.4 litres Class 2.2 (Refrigerant) 4944.2 litres Class 3 (Flammable Liquid) 16565 litres Class 4.1 (Flammable Solid) 956.5 kg Class 5.1 (Oxidizers) 11302 kg Class 6.1 (Toxic Substance) 75 litres Class 8 (Corrosive Liquid/Solid) 9170 l / 1340 kg Class 9 (Miscellaneous) 41575 kg
Nuclear Compliance Class 7 (Various isotopes/UN Nos) 1.07E+12 Bq
NSRS Class 2.2 (Non Flam Comp Gas) 9535 l Class 4.3 (Dangerous When Wet) 170 kg Class 9 (Miscellaneous) 241 kg
MT Garage Class 2.1 (Flam Gas L/R/D) 40 litres Class 2.2 (Refrigerant) 266 kg Class 5.1 (Oxidizers) 95 kg Class 9 (Miscellaneous) 3900 kg
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10.3 Material Assessment Centre - Hazardous Waste
HMNB Clyde produced 46,756 litres of liquid and 17,903 kilograms of solid waste that were subject to dangerous goods carriage legislation during 2008.
The vast majority of the waste falls mainly within three hazard classes, Class 3 Flammable Liquids, Class 8 Corrosives and Class 9 Miscellaneous. The figure for Class 5.1 Oxidizing Agents was inflated solely because the new EOG style of Oxygen Candle entered service last year, resulting in all old style SCOG Oxygen Candles being disposed off.
% Hazardous Waste by Class
7% 2% 0% 2% 0% 6%
40%
20%
3%0%
16% 0% 2% 2%
2.1 (R/L/D) 2.1 (Aerosol) 2.2 (C) 2.2 (Aerosol) 3 (Flam Liquid) 4.1 (Flam Solid) 4.2 (Spont Comb) 5.1 (Oxidizer, Liquid) 5.1 (Oxidizer, Solid) 5.2 (Organic Peroxide) 6.1 (Toxic, Liquid) 8 (Corrosive, Liquid) 8 (Corrosive, Solid) 9 (Misc, Liquid) 9 (Misc, Solid)
10.4 Dangerous Goods Incidents
There was only one dangerous goods incident that occurred in 2008, the incident did not lead to any environmental spillage, damage to property or injury to personnel.
Incident No 7183 (19/05/08)
Event - FDS trailer was being offloaded in the GPSS transit shed. During the offloading process it was discovered that four jerrycans of Sodium Hypochlorite (a corrosive material) had become loose from their pallet. The jerrycans were insufficiently secured for the normal
- 38 - HMNB Clyde SHEF Annual Report 2008-2009
rigors of transport and ended up at an angle of 45 degrees resting against another similarly shrink wrapped pallet. Offloading stopped, DGSA consulted.
Remedial Action - DGSA conducted a visual inspection of the jerrycans, no spillage or damage to product or vehicle. Jerrycans were carefully secured to the pallet using existing shrink wrap and offloaded with care. Before onward shipment, the jerrycans were secured to pallets using shrink wrap, cardboard separators and banding. Unsafe load proforma, DG incident report and near miss reports raised. DGSA from consigning yard informed of incident.
10.5 Training
The training records of staff involved in the carriage of dangerous goods are continually reviewed by the DGSA. Currently we have adequate numbers of suitably qualified staff in all key areas. During the reporting year Logistics provided ADR consignor training to 12 staff and several MT drivers successfully re-qualified as ADR drivers. ADR driver and consignor training will continue to be provided by commercial companies. It is anticipated that the DGSA will provide dangerous goods general awareness training to all Logistics warehousing staff.
10.6 Audits and CMS
HMNB Clyde (excluding RNAD Coulport) was audited in Feb 08 by MoD’s DE&S Dangerous Goods Branch, no major compliance issues were identified with our processes or activities. Dangerous goods policy, process map and supporting documentation will be amended to reflect the up and coming changes to legislation which are due to come into force on 01 July 09.
10.7 Legislation Changes
The carriage of dangerous goods by road is regulated in this country by CDG Road 2007 and ADR. The new addition of ADR came into force for international journeys. In January 2009 and should be made applicable to domestic traffic in EU Countries by 1 July 2009. The main changes that will or are likely to impact on HMNB Clyde activities are outlined below:
• Changes regarding the provision and contents of instructions in writing (known as Tremcards). The responsibility for providing Tremcards has previously been that of the consignor, this will change to that of the carrier/operator. UN Working Party 15 has agreed to replace the existing system with a single ADR specified instruction. The new system is more aligned to ADR driver training.
• New criteria and marking requirements for environmentally hazardous substances across all Modes. Additional marking will be required on combination packages containing inner receptacles exceeding 5 litres or 5 kilograms.
• New “Exempted Quantity” criteria which is in addition to “Limited Quantity” criteria. The new criteria will be subject to the relaxation of certain requirements.
• New “Limited Quantity” marking requirements (black writing 65mm high placed on a white background) for transport vehicles exceeding 12 tonnes when carrying dangerous goods in excess of 8 tonnes.
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• ADR now stipulates that training shall be undertaken before taking on responsibilities concerning the carriage of dangerous goods.
• When documenting dangerous goods the net mass of the substance in litres or kilograms must be declared not the gross mass of the package. This also applies to articles such as Life Rafts, Lithium Batteries in equipment and Refrigerating Machines where previously the gross mass was acceptable to establish load limits.
• Changes to the classification criteria for Nitric Acid and to classification, package marking and labelling requirements for Lithium Batteries and Lithium Ion Batteries.
• Extension of the requirement for drivers of vehicles under 3.5t to receive appropriate training and hold ADR vocational training certificates if required transporting loads in excess of ADR load thresholds. (Not a new requirement but worth reiterating).
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12.0 REGULATORY AUTHORITIES
12.1 HSE Visits
There were no HSE visits or enforcement notices received during the reporting period. Enforcement Notices are a legal procedure by which regulators require us to improve an operation in an agreed time-scale if there is thought to be a potential significant safety risk.
12.2 SEPA Visits
Faslane Reason for visit Outcome of visit Jan 08 (2 visits) Routine sampling/inspection against No adverse findings permit conditions Feb 08 (2 visits) Routine sampling/inspection against No adverse findings permit conditions Mar 08 (3 visits Routine sampling/inspection against No adverse findings permit conditions Apr 08 (2 visits) Routine sampling/inspection against No adverse findings permit conditions May 08 (2 visits) Routine sampling/inspection against No adverse findings permit conditions Jun 08 (2 visits) Routine sampling/inspection against No adverse findings permit conditions Jul 08 (2 visits Routine sampling/inspection against No adverse findings permit conditions Jul 08 ( 1 visit) Visit to discuss chlorination unit at Action plan agreed NUB Aug 08 ( 1 visit) Routine sampling/inspection against No adverse findings permit conditions Sep 08 ( visit) Routine sampling/inspection against No adverse findings permit conditions Oct 08 (1 visit) Routine sampling/inspection against No adverse findings permit conditions Nov 08( 1 visit) Routine sampling/inspection against No adverse findings permit conditions Dec 08 ( 1 visit) Routine sampling/inspection against No adverse findings permit conditions
OFD Garelochhead Reason for visit Outcome of visit SEPA carried out several routine No adverse findings visits throughout the year as per the permit requirements.
Coulport Reason for visit Outcome of visit SEPA carried out several routine No adverse findings visits throughout the year as per the permit requirements.
12.3 Environmental Health
Reason for visit Outcome of visit 25th Feb 09 Routine inspections of the Wardroom The premises were considered Galley, Main Galley, Civilian Canteen satisfactory. and Spar Shop. Records examined included HACCP, temperature monitoring and cleaning schedule.
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13.0 AUDIT AND VERIFICATION
A total of 6 SHEF audits were conducted from April 08 to March 09.
AP/EXT/B/289 LRQA ISO14001 Surveillance
The audit concluded that HM Naval Base Clyde had failed to maintain an Environmental Management System (EMS) that fully complies with the requirements of ISO14001. The raising of major NCs required that a special surveillance be conducted within 3 months of this audit. The Major non-compliances related to:
• Roles & responsibility / Calibration regime • Scope of the EMS & ISO14001 certification • Management review
These major non compliances were reviewed again during a special surveillance in June 08 and the auditor stated that each of these major NCs have been closed. This reflects a concerted and coordinated approach to addressing the issues and the underlying root causes. There is also now a more visible engagement of top management from MoD and Babcock with respect to environmental management and ISO14001 EMS requirements
AP/EXT/B/289 LRQA ISO9001 Surveillance
The audit concluded that whilst the organisation was able to demonstrate some improvements to address previously reported non-compliances, three new major NCs were identified during the visit. It was stated that these findings required immediate attention by the organisations management team and resulting actions would be reviewed to assess effective implementation during a special surveillance visit. The major non-compliances related to:
• Design and Development Planning (Neptune) • Competence, Training and Awareness • Asset Survey and Registration
These major non compliances were reviewed again during a special surveillance in June 08 and the auditor stated that the company has demonstrated that they have investigated the circumstances surrounding the findings and effectively established the root cause associated with them. The Competence, Training and Awareness finding remains open at minor status and is being addressed by Capability Clyde. The other two major non- compliances were closed.
AP/INT/B/280 Legionella
The audit concluded that arrangements for the management of legionella at Faslane/Coulport and NB(G) are not adequate. The audit found a range of non-compliances some of which have existed for a long period of time and some of which have had the potential to leave systems at risk of legionella colonisation. In total 20 CPARs were raised (3 Category B and 17 Category C). Significant findings included the lack of a co-ordinated legionella management system at Coulport going back some years. Within Coulport the audit found no formal Responsible Person appointment, out of date legionella risk assessments and an absence of many of the basic control and monitoring functions required in the Health and Safety Executive’s Approved Code of Practice and guidance document, L8. At Faslane a systematic failure to analyse and act upon temperature monitoring data
- 42 - HMNB Clyde SHEF Annual Report 2008-2009 provided by Building Co-ordinators and other personnel was found. Evidence included graphs showing unsatisfactory readings at outlets over many months and the failure to act on reports showing that monitoring could not be undertaken because the correct equipment was not available. The audit also identified numerous instances where records, which are required to be kept for five years, were missing.
To date a total of 6 CPARs have been closed, 14 remain outstanding.
AP/INT/B/283 Flourinated Gases
The audit concluded that that there is effective implementation of the F-Gas Regulation within the Base. However, there are certain areas where the management arrangements in support of implementation were found to be inadequate. In particular a number of maintenance schedules need to be amended to incorporate the Refrigerant Plant F-Gas Inspection procedures and there are no processes in place to meet the MoD reporting requirements on Fluorinated Greenhouse Gases. In addition there is a need to formally recognise essential quality records that support F-Gas Regulation compliance to meet the requirements of ISO 14001:2004. A total of 4 Corrective and preventative Action Reports were raised and agreed, the CPARS centre on developing and updating supporting CMS documentation.
To date a total of 3 CPARs have been closed, one remains outstanding.
AP/INT/B/166 DSEAR
The audit concluded that adequate Base Policy and Organisational arrangements were not in place to satisfy the requirements of DSEAR 2002, JSP 375 Volume 2 leaflet 56 and where applicable, the requirements of JSP 317 in its relation to storage and handling of petrol. Therefore compliance with the Regulations cannot be demonstrated and assurance that controls are in place to ensure safe operation of processes involving such dangerous substances not shown.
A total of 3 CPAR’s were raised and agreed. However, the audit report and CPARs have not yet been published as a meeting of key stakeholders of the audit is required in order to review the audit output to assess whether the CPAR’s will be effective in making a significant change to how we handle DSEAR compliance on the base.
AP/INT/B/298 Statutory Licences
The audit concluded that there are shortfalls in the existing management arrangements to ensure compliance with the specific statutory conditions laid down by the Scottish Environment Agency (SEPA). On a positive note the audit team found a significant improvement in the management and general housekeeping of the Material Assessment Centre and Waste Segregation Areas since previous audits.
A total of 5 CPAR’s were raised and agreed. The two most significant findings relate to a failure to comply with the conditions laid out in abstraction licences; CAR/R/1004412 and CAR/R/1013818 issued under ‘The Water Environment (Controlled Activity) (Scotland) Regulations 2005 as amended’ and not having a Waste Management Licence Exemption for the temporary storage of medical waste in the RNSQ. The remaining 3 CPAR’s relate to updating CMS documentation to meet the Control and Monitoring & Measurement requirements of ISO14001:2004 applicable to the processes outlined in HSE-PM-004, REDF-PM-001 and SOP 338.
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To date 1 CPAR has been closed and 4 remain outstanding.
CPAR Management
A total of 38 CPAR’s were raised as a result of these audits and 23 remain outstanding.
At the start of March 2009 we reported that 83 (33%) of current CPARs are SAFETY related issues and 25 (20%) of OVERDUE Findings are SAFETY related.
Summary
The Basewide Audit Programme continues to include specific SHEF related audits. The 2009 Audit Programme was published in January and key stakeholders from Environment and Safety were included during its design. Many of the audits this year will be manned by experts from Quality, Safety and Environment so these audits will be fully integrated and should cover aspects of each discipline.
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14.0. SELF REGULATION NOTICES (Internal Enforcement Notices)
During 2008-2009 8 Prohibition Notices and 8 Improvement Notices were issued.
Details of the 8 Prohibition Notices and 8 Improvement Notices issued are as follows:
Reference Date of Issue Issued to Brief Description Number CA/INT/K/29 24/02/09 Head of Unsafe access to plantrooms in new accommodation Prohibition Estates blocks. Management CA/INT/K/28 20/02/09 Head of Unsafe loading operations being undertaken creating Prohibition Estates significant hazards to operators, road users and Management pedestrians. CA/INT/K/27 09/02/09 Head of Employees were being exposed to paint fumes and Prohibition Fleet low workshop temperature, painting activity was being Production carried out by a contract painter. Inadequate COSHH assessments for task. CA/INT/K/26 16/01/09 Head of While coating the DSRV seal on board Sceptre it was Prohibition Fleet identified that the painter working for RA 3 had Production accessed the vessel when there was no sufficient assessment of the guard rails and work area with regards to falling from height. CA/INT/K/25 16/12/08 Head of Hotel An investigation revealed that a hoist lift had never Prohibition and Catering been handed over to Babcock Marine staff and therefore an asset number was never given to the equipment. This has resulted in the lift not being maintained since installation and has never been subject to statutory inspection. CA/INT/K/23 01/09/08 Head of The air handling system for the general ventilation of Prohibition Fleet the workshops in 1241 is on the flat roof about 12 -15 Production metre from the aforementioned exhaust. This air handling unit under certain climatic conditions is drawing in fumes which will be carbon monoxide and carbon dioxide gases into the general ventilation duct. The workshop offices had a strong smell of fumes. CA/INT/K/30 23/03/09 Head of Naval Contractor failed to comply with the instructions Prohibition Base Projects contained with the contract and also worked out with the safe method of work and site rules by intentionally breaking into a live air system without the correct permits to work in place. CA/INT/K/31 26/03/09 Head of Fleet Two pressures systems (oxygen and acetylene) were Prohibition Production under pressure, out with the requirements of their scheme of examination under the Pressure System Regulations 2000. CA/INT/J/89 17/02/09 Head of Hotel Racking in the storage facility at Senior Rates has not Improvement and Catering been subject to any formal or informal inspection process. CA/INT/J/88 09/02/09 Head of Inadequate arrangements in place to control the work Improvement Fleet of contractor. Production CA/INT/J/87 16/01/09 Head of General risk assessment documentation provided for Improvement Fleet the task were of an out-of-date format and did not Production adequately identify significant hazards or control measures. COSHH risk assessments provided for the task were of an out-of-date format and had not been reviewed since 4/3/04.
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CA/INT/J/86 17/12/08 Estates An investigation revealed that a lift within senior rates Improvement Director Clyde galley had never been handed over to Babcock Marine staff and therefore an asset number was never given to the equipment. This has resulted in the lift not being maintained since installation and has never been subject to statutory inspection. CA/INT/J/85 05/12/08 Estates Morgan Ashurst failed to report damage to an LV Improvement Director Clyde electrical cable and permitted the unauthorized repair to said cable in contravention of site service clearance constraints. Permitted demolition work proceeded before arrangements for the isolation of local LV supply had been completed. CA/INT/J/84 07/11/08 Head of Large amounts of combustible materials had Improvement Fleet accumulated throughout in the bottom area of building Production 1109. Due to the open design of the area and false floor this additional fire loading increases the risk of a small fire becoming a serious life threatening event CA/INT/J/83 17/10/08 Lodger Unit Pedestrian routes were found to be blocked by gas Improvement bottles, oil drums and various stores. This prevented separation of pedestrians and vehicles due to pedestrians being forced to walk on Montclaire road. CA/INT/J/82 28/08/08 Fire Service Racking in the Fire Station has not been subject to any Improvement formal or informal inspection process. CA/INT/J/81 21/08/08 Head of Hotel Build up of debris and rubbish in the corridors of the Improvement and Catering accommodation block.
Compliance Notice Status 2008/09
6 5 4
Number 3 Prohibiton 2 Improvement 1 0 Open Closed Status
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15. LEGAL CLAIMS
15.1 Babcock Marine (Clyde)
There were 15 new claims against Babcock Marine during this period which represents a 36.4% increase from the previous year. 23 claims have been settled during 2008-09 to a value of £158.7K, equating to an average cost of £6899 per claim. This compares to an overall payment of £55.8K for the 11 claims which were settled in the previous year at an average cost of £5580 per claim.
At the time of writing this report, 26 claims were awaiting closure and the outstanding reserve value of these claims equates to £286.6K.
Below is a departmental breakdown of claims brought in 2008-09, detailing their status and value and a further table providing details of all outstanding claims in the department:
Departmental Breakdown of Claims 2008-2009
Total Settled Pending Repudiated Paid Outstanding Directorate No of (£k) (£k) Claims (Reserve) Crew 5 1 4 0 3.8K 16K Services Logistics 1 0 1 0 0 17K Fleet 2 0 2 0 0 13K Production Nuclear 2 0 2 0 0 41K Activities Estates 3 0 3 0 0 12.5K SWS 1 0 1 0 0 7K Lodger 1 0 1 0 0 10K 15 1 14 0 3.8K 116.5K
Departmental Breakdown of All Outstanding Claims
Total Outstanding (£k) Directorate No of (Reserve) Claims Crew Services 5 45K Logistics 3 31K Fleet Production 6 49.8K Nuclear Activities 4 53.5K Estates 6 90.3K SWS 1 7K Lodger 1 10K 26 286.6
Of the 11 claims reported in 2008-09, the following breakdown of cause is as follows:
Cause Number of Claims Slips, Trips and Falls 7 Strike Against Object 1 Exposure To Hazardous 1 Substances
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Electric Shock 1 Manual Handling 3 Burn 2 Total 15
15.2 Ministry of Defence
There have been 3 new claims against the MoD. The details are as follows:
• IP fell down stairs • IP tripped over obstruction • IP slipped on grease on the EHJ floor
The outstanding claims and cost element information is not available.
Public Liability
There have been 2 public liability claims during the reported period.
1) IP caught her shoe in the runner of partition door and fell over causing bruising and a cut on her nose.
2) Forklift truck ran over IP’s foot.
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16.0 OBJECTIVES AND TARGETS FOR 2009 – 2010
Introduction
The objectives and targets for 2009 – 2010 will continue to build on the successes already achieved whilst concentrating on those areas where improvements need to be made in managing safety and reducing workplace injuries and ill health. The following objectives and targets will support and underpin the cultural improvements already made, under the banner of ‘Our Challenge on Safety’.
16.1 Requirements
• Develop HoDs Safety Improvement Plans; • Establish a Just Culture Policy • Complete/establish Directorate IIF Safety Leadership Teams;
16.2 Learning and Development
• Deliver an IIF Road show; • Produce and implement an Induction programme for Base employees; • Update VCIC Computer Bases Training (CBT) Contractor training package; • Develop and implement SHEF Training Strategy; • All Trade Union Safety Representatives to spend a week in Safety Department;
16.3 Combined Nuclear & Conventional Safety Culture
• Put in place a ‘Site Control Office’; • Improve Safety Performance Indicators (SPI’s) process;
16.4 Communication
• Launch Time Out For Safety (TOFS) programme; • Update the Base SHEF video; • Produce an in-house Lessons Learned video;
16.5 Process Initiatives • Control of Contractors Phase 2, review and improve vendor assessment process for BM(C) and MoD. • Complete rollout of CoSHH Programme (SYPOL); • Continue to improve reporting of Near Misses – reduce unsafe conditions by 50% • Review of the provision and selection of PPE; • Launch Alcohol & Drug policy;
16.6 Behavioural Safety • Launch a Recognition & Reward Scheme • Develop a Behavioural Safety Strategy
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16.7 Environmental
• Implement the MoD requirement for Sustainability Appraisals to be carried out on projects. • Capture the total carbon footprint for HMNB Clyde - to be extended to electricity • Implement action plan for compliance to the water Environment (oil storage)(Scotland)Regulations 2006 • Develop the reporting required for the Carbon Reduction Commitment • Organise annual Energy and Environmental Awareness week.
- 50 - Produced By: Babcock Marine Health, Safety & Environmental Department HM Naval Base Clyde Building 1281 Faslane, Helensburgh G84 8HL Tel +44 (0)1436 674321 Ext 7009 Fax +44 (0)1436 674321 Ext 6545
REF: GLB121442