The “STRATEGIC WEAPON SYSTEM ACTIVITIES FUTURE DELIVERY OPTIONS PROJECT (SWSAFDOP) – SPECIAL TEAM BRIEF No. 002/11 24 May 2011” ( ref 3 ) indicates that “MoD will remain in overall charge, with Naval Base Commander (Clyde) retaining overall responsibility for Nuclear Activities, Explosive Safety Policy, Security and Emergency Management Planning, including retention of the Incident Commander role in response to all contingency scenarios and the role of dual authorisee for the site.”
This is arrangement is dependent on MOD demonstrating that MOD exercises a sufficient degree of control of the work. Annex A ( ref 3 ) suggests that rather than exercising control the MOD role is surveillance and assurance rather than day to day control of work activities. It is therefore debateable whether MOD exercises sufficient control to be considered “in control of the work”
The proposal for the contractorisation also recalls some years ago a similar and unfortunate situation at Dounreay where it was found that the complex web of relationships for responsibility of safety made it very difficult to understand where responsibility for safety lay and can lead to hazards and risks falling into gaps between the various interfaces between site owner and the various contractors etc. This can lead to failure to address and control the hazards and risks. The potential for confusion is further demonstrated by the reference to “dual authorisee “; I am not aware of any other licensed/authorised sites where there are two authorisation/license holders.
If contractorisation goes ahead It would be far better at RNAD Coulport to follow the model MOD adopted at AWE ( 4 ) where the site is operated and controlled by a contractor, regulated by ONR and licensed under the Nuclear Installations Act.
1: http://www.heraldscotland.com/news/home-news/anger-as-us-arms-dealer-takes-over-running-of-scottish-nuclear-bomb-base-1.1104095 or http://tinyurl.com/3e4nowa2: http://en.wikipedia.org/wiki/RNAD_Coulport