Friday, 10 June 2011

MOD annual report on Safety, Environmental Protection

MOD has published its annual report on Safety, Environmental Protection andSustainable Development for 2010

As can been seen in the extract below from the DESB 2010 report it appears that
the lessons from the Haddon Cave Review and report have been ignored; in that,
decisions were taken in the SDSR/Defence Reform Review without a proper
consideration of their impact on safety generally and nuclear safety in

"43. SDSR/Defence Reform. The Strategic Defence and Security Review did not,
formally, assess the major implications for the safety of the department and
there has been insufficient time to properly assess the impact of the SDSR
options taken before decisions were made. Therefore the full impact of these
decisions might not be known for a number of years. That said, the major issues
raised by the Front Line Commands regarding wider PR11 options were discussed at
a DESB in January 2011, although timescales prevented a full assessment.

44. It is unclear what impact the Defence Reform Review will have on safety.
However the need to reduce costs and the severe reduction in personnel numbers
will undoubtedly place a severe strain on safety systems. The department must
ensure that mitigation plans are in place to maintain the appropriate standards.
SSD&C is in close discussions with the Reform Review team as to how any outcome
will impact on some of the wider aspects work and Defence safety as a whole."

The part of the report about Defence Nuclear Environment Safety Board (DNESB)
clearly indicates that the ability of MOD's internal Regulator DNSR to do its
job is being compromised by the lack resources to quote from the report "further
aggravated by constraints on regulatory capacity"

"11. The DNESB Chairman reports that an acceptable standard of nuclear and
radiological safety and environmental protection has been maintained in the
operation and delivery of the Defence nuclear programmes. Individually, none of
the DNESB's 8 issues reflect an immediate safety or environmental concern; but
together they represent a potential compromise to compliance or the
demonstrability of compliance and, taken together, they present a risk that it
will become increasingly difficult to maintain that the Defence nuclear
programmes are being managed with due regard for the protection of the
workforce, the public and the environment. The principal threats to safety in
the Defence nuclear programmes in the medium term are the adequacy of resources,
both money and staff complement, and the maintenance of a sustainable cadre of
suitably competent staff (RN, MOD civilians and in industry partners).
Confidence in making the Substantial Assurance judgement is reduced from 2009
due to the adverse trend in resources (which I expect will become yet more
painful), further aggravated by constraints on regulatory capacity.
12. Duty Holders have maintained Continuous at Sea Deterrence (despite
increasing pressures on manpower and some equipment fragility) and have safely
delivered the required military capability from the Submarine Arm despite
reduced platform availability; HMS ASTUTE has become the first new SSN in the
fleet since 1991. 13. The main risks/issues are:

a. Lack of adequate resource to deliver the Defence nuclear programmes safely.

b. Measures already in hand may be insufficient to address the present and
predicted shortage of Nuclear SQEP in the RN among MOD civilians and Defence

c. The frequency and significance of incidents remain too high as a result of
poor control of work."

Associated media reports

Daily Express


The Scotsman

Sunday Post

Caledonian Mercury

Rob Edwards Blog

Milcon R & C blog report on earlier DESB reports

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