Links to the Milcon Research and Consulting pages on Facebook and to the FOI requests on the "What do they know" website have been added to this Blog.
These can be found on right side of this page under the list of external links.
Monday, 10 October 2011
Tuesday, 4 October 2011
Staff cuts on submarines impact on nuclear safety
Telegraph reports
“A fifth of submarine medics serving on board
Trident nuclear deterrent and hunter killer submarines have been axed,
including one who cared for the wounded on the HMS Astute after a crewman went
on the rampage. It is understood that several sailors were told they were
losing their jobs while conducting covert operations after their captains
received a signal at sea from the Ministry of Defence”
“Medical
Assistants (Submariners), known as MASMs, play a key role as they have to give
both primary and secondary care to personnel on board when the boats are many
miles from land. They also provide the main radiation checks
and radiological safety on the Navy’s 11 nuclear powered submarines.”
“Their role is so important that if there are
less than two on a Vanguard nuclear deterrent boat it cannot sail.”
“We were told that the Submarine Service was
protected from cuts but now medics have fallen into the bracket which is
absurd,” one submariner told The Daily Telegraph. “Submarine medics are sought
after but we a losing almost a quarter of our quota of available medics.”.
“It is understood that between 15 and 25 out of
100 deployable medics have been sacked. The medics receive two years intensive
training, including NHS placements, and train intensively on dealing with
radiological illness and exposure. On special missions a doctor will join them
on board.”
If true this indicates how safety is again
being trumped by the urgent need to find cost savings. I also suspect that no
assessment of the impact of these cuts on safety has been carried out, as
required by para 45 of Chapter 3 of JSP 815 “Management of Organisational
Change”. The MOD failed duty to respond to a FOI request on this issue dating
back to July, despite a legal duty to do so within 20 working days.
Below is an extract from a course prospectus that gives a good
indication of Medical Assistants (Submariners) and the their
radiation protection duties.
- I.A.W City
and Guilds Radiation Safety Practice Scheme Handbook 7410
- Biological
Aspects of Ionising Radiation
- Radiation
Protection
- Radiation
Detection and Measurement
- Structure
of Matter and Radioactivity
- Dosimetry
- Storage and
Transport of radioactive material
- Accidents
and Incidents.
- Industrial
uses of radioactive material
- Regulation
and Guidance
- Environmental Control
This
Guardian report on the 2010 DNESB annual report gives an indication of how the
MOD is using the cuts in the number posts as a means of reducing the number of
vacant SQEP posts which gives the appearance of an improvement in the situation.
SQEP staffing has been raised as a significant risk for a
number of years in both the DESB and DNESB annual reports. See para 16 of the
2010 DNESB report.
So the statement “A Royal Navy spokesman said: "There
will be no shortage of medical personnel on our submarines. Redundancies are
only being made in surplus areas." This
seems very strange when set against the 2010 DESB and DNESB reports leaving
open the question as to what is the true position!!
The cuts also demonstrate how little notice Ministers take
of reports from the MODs main nuclear and safety committees and the Defence
Nuclear Safety Regulator.
Friday, 26 August 2011
Defence Nuclear Environment and Safety Board report 2010
The 2010 Defence Nuclear Environment and Safety Board report has been published.
The DNESB 2010 assurance report again shows that the ever continuing reduction in resources is putting the safety of MOD staff and the public at increasing and indeed unacceptable risk.
The DNESB assurance reports clearly show the inability of the Defence Nuclear Safety Regulator to influence decisions by Ministers and the Defence Board to ensure the provision of adequate resources for the delivery of nuclear safety within the MOD. This also demonstrates the need for a Nuclear Regulator independent of the MOD with proper powers of regulation and enforcement.
The 2010 DNESB and earlier reports clearly demonstrate how the MOD has failed to allocated sufficient resources to nuclear safety in particular the lack of progress on recruiting suitably experienced and qualified staff, the commitment to produce a decommissioning strategy supported with the necessary funding.
The DNESB 2010 assurance report again shows that the ever continuing reduction in resources is putting the safety of MOD staff and the public at increasing and indeed unacceptable risk.
The DNESB assurance reports clearly show the inability of the Defence Nuclear Safety Regulator to influence decisions by Ministers and the Defence Board to ensure the provision of adequate resources for the delivery of nuclear safety within the MOD. This also demonstrates the need for a Nuclear Regulator independent of the MOD with proper powers of regulation and enforcement.
The 2010 DNESB and earlier reports clearly demonstrate how the MOD has failed to allocated sufficient resources to nuclear safety in particular the lack of progress on recruiting suitably experienced and qualified staff, the commitment to produce a decommissioning strategy supported with the necessary funding.
Wednesday, 6 July 2011
Office of Nuclear Regulation and the Health & Safety Executive (ONR/HSE) effective regulators of Government ?
In a recent FOI the HSE was asked; could you please tell me what action ONR/HSE is taking under Health and safety legislation to ensure that standards of safety are maintained in light of MODs’ own admission that safety performance has been and continues to be compromised as a consequence of ever reducing resources.” The full text of the request is given at Annex A.
The ONR/HSE have so far failed to provide an answer to this FOI request.
The fact that the Strategic Defence and Security Review ( SDSR ) is a politically driven process within Government and that the ONR/HSE is part of the Government albeit at arms length might explain the HSEs’ reluctance to take action against the MOD whereas the HSE is far more proactive when it comes to the safety failures of commercial operators.
It is also notable that MODs own requirements for the prior assessment of the impacts of organisational changes set down in JSP 815 “Management of Organisational Change” by MODs ( Annex B) own admission have been largely ignored.
It is clear that the political agenda driving the SDSR and the need to save money are trumping the health and safety of MOD employees and the public.
It is also clear that the ONR/HSE is failing to act as an effective Regulator and in doing so is complicit in putting the safety of MOD employees and the public at unacceptable risk.
Annex A
“MOD have just published annual report on Safety, Environmental Protection and Sustainable 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 particular
Link to Haddon cave Report
"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 contractors.
c. The frequency and significance of incidents remain too high as a result of poor control of work."
Could you please tell me what action ONR/HSE is taking under Health and safety legislation to ensure that standards of safety are maintained in light of MODs’ own admission that safety performance has been and continues to be compromised as a consequence of ever reducing resources.”
Annex B
Defence Environment and Safety Management JSP 815 CHAPTER 3ORGANISATION “MANAGEMENT OF ORGANISATIONAL CHANGE
45. Without adequate planning and analysis, change may result in
the inadvertent erosion of the emphasis on high standards of
environment and safety performance. This may manifest itself in the
loss of established formal and informal environment and safety
processes, loss of critical safety culture, knowledge and
expertise, or lack of sufficient personnel to safely operate and
maintain a process with consequent increased likelihood of
accidents and incidents.
46. Duty holder organisations shall, prior to any significant
changes, conduct an environment and safety assessment to baseline
the existing arrangements for critical environment and safety
activities; analyse the impact and justify the proposed changes.
The rigour of the assessment shall be proportionate to the
significance of the change. Where appropriate and proportionate,
the organisation should seek the views of the relevant FSBs or
discipline leads.
47. It shall be the responsibility of the individual or team
proposing the initiative to implement and complete the assessment
prior to making any changes. Outcomes of assessments shall be
included in any submissions seeking endorsement to continue with
the implementation phase. Once implemented, the impact of the
changes shall be reviewed after an appropriate period.”
The ONR/HSE have so far failed to provide an answer to this FOI request.
The fact that the Strategic Defence and Security Review ( SDSR ) is a politically driven process within Government and that the ONR/HSE is part of the Government albeit at arms length might explain the HSEs’ reluctance to take action against the MOD whereas the HSE is far more proactive when it comes to the safety failures of commercial operators.
It is also notable that MODs own requirements for the prior assessment of the impacts of organisational changes set down in JSP 815 “Management of Organisational Change” by MODs ( Annex B) own admission have been largely ignored.
It is clear that the political agenda driving the SDSR and the need to save money are trumping the health and safety of MOD employees and the public.
It is also clear that the ONR/HSE is failing to act as an effective Regulator and in doing so is complicit in putting the safety of MOD employees and the public at unacceptable risk.
Annex A
“MOD have just published annual report on Safety, Environmental Protection and Sustainable 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 particular
Link to Haddon cave Report
"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 contractors.
c. The frequency and significance of incidents remain too high as a result of poor control of work."
Could you please tell me what action ONR/HSE is taking under Health and safety legislation to ensure that standards of safety are maintained in light of MODs’ own admission that safety performance has been and continues to be compromised as a consequence of ever reducing resources.”
Annex B
Defence Environment and Safety Management JSP 815 CHAPTER 3ORGANISATION “MANAGEMENT OF ORGANISATIONAL CHANGE
45. Without adequate planning and analysis, change may result in
the inadvertent erosion of the emphasis on high standards of
environment and safety performance. This may manifest itself in the
loss of established formal and informal environment and safety
processes, loss of critical safety culture, knowledge and
expertise, or lack of sufficient personnel to safely operate and
maintain a process with consequent increased likelihood of
accidents and incidents.
46. Duty holder organisations shall, prior to any significant
changes, conduct an environment and safety assessment to baseline
the existing arrangements for critical environment and safety
activities; analyse the impact and justify the proposed changes.
The rigour of the assessment shall be proportionate to the
significance of the change. Where appropriate and proportionate,
the organisation should seek the views of the relevant FSBs or
discipline leads.
47. It shall be the responsibility of the individual or team
proposing the initiative to implement and complete the assessment
prior to making any changes. Outcomes of assessments shall be
included in any submissions seeking endorsement to continue with
the implementation phase. Once implemented, the impact of the
changes shall be reviewed after an appropriate period.”
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