Regulating OME Safety in UK Defence

Transcription

1 Presentation to the PARARI 2017 UNSW Canberra 21 November 2017 Regulating OME Safety in UK Defence Bob MacNaught BSc CEng MIET FIExpE MAPM Defence Ordnance, Munitions and Explosives Safety Regulator / Chief Inspector of Explosives (MOD) UK Defence Safety Authority

2 The DSA s Independent Regulation of Safety in the MOD Secretary of State for Defence Reports to Director General (3*) Defence Safety Authority Military Aviation Authority Defence Fire Safety Regulator Defence Land Safety Regulator Defence Maritime Regulator Defence Nuclear Safety Regulator Defence Ordnance, Munitions and Explosives Safety Regulator Defence Accident Investigation Branch Organisational Separation Defence Safety Authority Defence Authority for HS&EP REGULATES ASSURES ENFORCES INVESTIGATES Defence Board OPERATIONAL Permanent Joint Headquarters Directorate Special Forces Force Elements GENERATES AND DEVELOPS Navy Command Army Command Air Command Joint Forces Command Systems and Services ACQUIRES and ENABLES Defence Equipment and Support (Weapons Operating Centre/Eng/DOSG) Information Systems and Services Defence Business Services, Defence Infrastructure Organisation, etc.

3 REGULATE: UK Legislation or MOD Regulation? UK Law Within the UK the MOD complies with all applicable Health, Safety and Environmental Protection (HS&EP) legislation. Overseas When activity is performed out of jurisdiction of the UK statutory regulator (i.e. overseas) the SofS requires us to apply our UK arrangements where reasonably practicable and, in addition, respond to host nations relevant HS&EP expectations. Where Defence has exemptions, derogations or dis-applications from HS&EP legislation, we maintain Departmental arrangements that produce outcomes that are, so far as reasonably practicable, at least as good as those required by UK legislation. MOD Regulations When we have a delegation from a statutory authority to regulate on their behalf. When SofS agrees there is a need to regulate Defence activity on the basis that military personnel are exposed to a higher level of risk to life compared to wider UK personnel and would therefore be above the risk threshold for regulatory activity by a statutory regulator (e.g. DG storage, Adv trg, etc).

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5 The Defence SEMS Implementation Products & Activities Implementation Products & Activities Step 1 - Define & Issue: Safety Policy, Regulation & standards Roles & Responsibilities, Organisational structures, RACI & delegations Competencies, approvals, mutual recognition Set Objectives Process, Procedures, Orders Planning cycles Governance structure & battle rhythm TNAs & Training Design Step 4 Undertake: Reviews of Hazard Logs & Risk Registers Review performance reports Analyse safety information (Measure of Effectiveness and Performance) Engagement with ITE, ISA, Subject Matter Experts, External Bodies to benchmark Conduct Horizon Scanning of Legislation, future Technology and Capability Equipment Programme Undertake OSAs to assess impact of Change of safety Undertake In-Year of funding (as affecting activity & safety) Consider SQEP & resilience of workforce Step 1 - Plan for Safety Plan Step 2 - Implement Safety Programs Do MoD Safety & Environmental Protection Management System Step 4 - Conduct Management Reviews Act Step 3 Monitor Performance & Assure Compliance Check Knowledge Management Step 2 - Deliver/Undertake: Establish & sustain safety organisations & governance Train & Educate workforce Issue delegations & report on individual & collective performance & culture Issue Organisational Approvals Issue licences Ensure compliance with safety policy, regulation & process Demonstrate leadership Empowered Workforce Ensure Just Culture Certify Equipment Maintain Equipment Manage safety risk to ALARP Retain records of decision making Ensure timely Corrective Action Step 3 - Deliver/Undertake: Conduct assurance 1 st /2 nd /3 rd Party Report & analyse safety performance Investigate, report & analyse incidents Anonymous reporting of workforce concerns Take Enforcement Action Undertake Independent Investigation Retain assurance records Undertake Information Knowledge Management to enable management reviews

6 Implement Steps 1 to 4 to deliver governance, to assure, to ensure SofS Defence Safety Committee Perm Sec 3 rd Party Reporting MoD SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM (SEMS) 2nd Party Reporting DG DSA TLB Holders, Senior Duty Holders, CEOs DSPA Define Organisation Application Accountability Policy MAA & Regs DFSR DLSR DMR DNSR DOSR DAIB Assure Compliance Enforcement Analyse & Plan DSA SEMS Investigate Regulator Group M O E JFC & SUB CMDs NAVY CMD ARMY CMD AIR CMD D NUC DE&S DIO DSTL DECA Notes: 1. JFC also Force Generate 2. DE&S are also Duty Holding Stakeholder Committees Operational Deployment Force Generation & Capability Development Delivering Capability Enablers Equip Infra Services Support Duty of Care TLB SEMS Duty Holding Environmental Protection Duty of Care Duty Holder Facing & Duty Holding SEMS Hierarchy TLB/SDH SUB CMD/HLB/ODH OPERATING CENTRE UNIT/BLB/ PROJECT TEAM ESTABLISHMENT Implement Steps 1 to 4

7 Scope of DOSR Regulatory Activity OME Acquisition 1300 items over 29 Project Teams Explosives Logistics 4000 Licences over 700 locations Explosives Classification UK Competent Authority for Military Explosives Major Accident Control 29 Locations Ranges 1700 Locations Lasers 500 Systems

8 DOSR Regulatory Activity Across OME Life-Cycle Phases (LCP) LCP1 LCP2 LCP3 LCP4 Acquisition Logistics In-Service Disposal REGULATE: Issues/Maintains Defence Regulations for Explosives Safety Management ASSURE AND ENFORCE: Conducts Audits for assurance of Safety Compliance

9 The MOD Ranges Safety Management System Safe Place Safe Practice Safe MOD Ranges and Training Areas Safe People Safe Equipment

10 The Major Accident Control SMS Prevent Control Major Accident

11 PRISM is the transformation programme that will deliver the DG s Vision for the future operation of safety in Defence, and the future Defence Safety Authority. Project #1 Organisational Separation Project #2 Report, Analyse & Exploit Project #3 Information Management/Information Knowledge Management Project #4 Regulation Project #5 Duty Holder Policy Project #6 Defence Accident Investigation Branch Project #7 Enforcement & Assurance Project #8 Workforce Project #9 Regulatory Practices, Processes and Operating Procedures Project #10A Business Management Project #10B Strategy, Organisation, Governance and Influence Project #11 Communications

12 Proposed OME Certification, Oversight and Approvals Project Team 1 st Party Assurance Safety Case etc Weapons Eng 2 nd Party Assurance OSRP/OSA Regulator 3 rd Party Assurance Approval

13 Policy, Regulations & Guidance B2 DOSR Team Structure Adopting a proportional and risk-based approach Defence OME Safety Regulator (DOSR) B1 Assurance & Enforcement B2 Analysis & Plans B2 2 x C1 5 x C1 1 x C1 3 x C2 6 x C2 1 x C2 1 x E1-1 x E1 Develop and maintain DOSR suite of DSRPs that ensures a blend of both goalbased and prescriptive regulation. Develop and maintain DOSR Guidance Material. Maintain DOSR Information and Web sites. Maintain DOSR Document Library on DOME (DOSR s new RAE Tool). Provide a Secretariat for DOSR Stakeholder Safety Committees and Working Groups. Conduct targeted risk-based audits and inspections where they can have the most beneficial effects. Gather evidence as to whether activity is being conducted safely, the degree of compliance with regulations, and confirmation that Risk-to-Life (RtL) and other safety and environmental outcomes are being well managed and mitigated. Manage DOSR Enforcement activity. Input reports to DOME (DOSR s new RAE Tool). Output = DOSR Annual Report to DG DSA DOSR A&P/RAE Lead responsible for conducting sophisticated, evidence-based risk analysis. Manage DOME input/output (DOSR s new RAE Tool). Manage DOSR Licensing and Permissions. DSA Environmental SME Lead (a shared DSA resource but principally supporting the newly established MACR Competent Authority).

14 Stephen Gillström McLean DOSR Assistant Team Leader Assurance MOVING TOWARDS RISK BASED ASSURANCE TO MAXIMISE THE RETURN FROM A LIMITED RESOURCE Defence Ordnance, Munitions and Explosives Safety Regulator

15 My Role / My Team Our Scope What we do now Why Change? New Methodology Questions Defence Ordnance, Munitions and Explosives Safety Regulator

16 Defence Ordnance, Munitions and Explosives Safety Regulator

17 Scope of DOSR Regulatory Activity OME Acquisition 1300 items involving 29 Project Teams Explosives Operations 4000 Licences over 700 locations Major Accident Control 29 Locations Ranges 1651 Locations Lasers 500 Systems

18 7500 Defence Ordnance, Munitions and Explosives Safety Regulator

19 680 Defence Ordnance, Munitions and Explosives Safety Regulator

20 What do we do now? Defence Ordnance, Munitions and Explosives Safety Regulator

21 Ranges Lasers Explosives MACR Acquisition Calendar based inspections, Peer reviews of LTARs. 10% check of Dstl selfcertification, LASER certification undertaken through DOSG. MACR sites with explosives are priority, Random selection of other large / small sites across MOD, Themed inspections on identified areas of concern, Assessment of 2 nd Party Assurance function across TLBs. Calendar based assessments, leading to MACR recertification when appropriate, Calendar based inspections of exercises, Follow-up visits to monitor progress of action needed to address serious issues. Audits of 8 OCs with OME responsibility, using a selected PT / Weapon System as a vehicle through the CADMID cycle; schedule then repeated using a different PT / Weapon System. Defence Ordnance, Munitions and Explosives Safety Regulator

22 Project #2 Report / Analyse / Exploit (RAE) To deliver: A reporting capability to share safety data An analysis capability to assess data The capability to make evidence based decisions Defence Ordnance, Munitions and Explosives Safety Regulator

23 What Evidence Do We Need? Defence Ordnance, Munitions and Explosives Safety Regulator

24 Risk Serial Factor High (Score = 4) Medium (Score = 3) Low (Score = 2) Very Low (Score = 1) Consequence Factors 1 HD Quantity MACR Threshold HD 1.1 up to MACR Threshold Non HD 1.1 up to MACR Threshold > 25 kg in AQ Store 3 IBD Off MOD Site Contained within MOD Site Contained within Explosives Area Contained within PES 4 Hazards to: Large numbers of the public and for long periods; young people (cadets); trainees Large numbers of the public for short periods, or a few for long periods; Large numbers of MOD staff for long periods A few of the public for short periods; Large numbers of MOD staff for short periods No public; Few MOD staff 5 Licence type Non-Standard Standard with justification Standard, fully compliant AQ Defence Ordnance, Munitions and Explosives Safety Regulator

25 6 Accidents / Incidents last 5 years Fatality TLB Performance & Event Probability Factors Major Injury; Minor Injury; Numerous major incidents Major Incident; Numerous minor incidents No Injuries; Minor incident 7 Condition of Infrastructure Poor, Mandated inspections not carried out; Serious rectification work outstanding Adequate, Some mandated inspections carried out; Some rectification work outstanding Good, All inspections carried out; Some non-essential rectification work outstanding Excellent, All inspections carried out; No rectification work outstanding 8 Regulator Inspection History Poor, Prohibition notices served Adequate, Improvement notices served Good, No enforcement notices but some non-confromances identified Excellent, Nothing worse than some minor observations have been made 9 Last DOSR Never Within 3 years Within 12 months Within 6 months Inspection 10 Self-Assurance None undertaken Some undertaken, no evidence available that areas of concern identified have been addressed Some undertaken, evidence available that areas of concern identified have been addressed Comprehensive programme in place, evidence available that areas of concern identified have been addressed 11 Corrective Action No progress made to address Some progress made but not completed i/a/w agreed plan All actioned i/a/w agreed plan None issued 12 Activity Processing HE; Process Non-HE; Storage with frequent issues / receipts; Storage with infrequent issues / receipts Defence Ordnance, Munitions and Explosives Safety Regulator

26 Defence Ordnance, Munitions and Explosives Safety Regulator

27 DOSR Questions?