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Nuclear Build - Construction Challenges Conference, 9 March 2010, Hilton Kensington Hotel, London, UK

Health and safety challenges for nuclear construction - Judith Hackitt CBE, HSE Chair

Download accompanying slides

Slide 1: title slide

Good afternoon everyone. Thank you for asking me to contribute to this conference on behalf of the Health & Safety Executive. This is a good opportunity to share experiences and I hope it will have some positive, practical outcomes. 

That is what we want to see at HSE. We operate across Great Britain as a regulator in all sectors. Our role is to provide strategic direction and to lead improvement in the health and safety system.

And my goal as Chair of the HSE is to make sure we focus on the real risks. Contrary to what you may have read, we're not interested in stopping kids playing conkers. We are interested in addressing the most urgent and significant risks in British workplaces, among which are the challenges faced by the nuclear and construction industries.

Our activity includes assessments, inspections, investigations, enforcement and research. However it's important to stress that the responsibility for managing risks lies with those who create them - those we call 'duty-holders' or, as is the case in the nuclear sector, licensees.

In this context, the duty holders are those who will design and build new power stations, while the operator of nuclear facilities is the licensee but that is not to say that the licensee does not have duties in relation to nuclear design and construction. But, irrespective of title, our approach is to work with you to make sure everyone builds health and safety into every stage of every project.

In the nuclear industry, of all industries, you cannot retrofit health and safety.

Slide 2: The HSE's role

The HSE includes the Nuclear Directorate - ND - which in turn includes the Nuclear Installations Inspectorate. The role of ND and HSE is to oversee a robust, independent, technically expert regulatory system which will secure the safe operation of the nuclear industry through ensuring effective management by industry, and a culture of continuous improvement and sustained operational excellence.

ND was a key contributor to the strategy for health and safety in Great Britain that we published last year. And it's worth mentioning some of the themes that are particularly relevant.

Slide 3: The HSE's strategy

First, the Strategy highlights co-operation and accountability. The most effective system is one where organisations work well together - with total clarity about who does what. In the nuclear industry, one way in which this is being effected is by the Regulator Nuclear Interface Protocol (RNIP) signed by all the CEOs of the UK nuclear industry. The Strategy emphasises the need for leadership - the need for people at the top of organisations to take ownership.

And it also stresses the need for competence. Health and safety is a discipline of its own with specific risk management skills.

Accountability, leadership and competence are high on the agenda as we look towards a new programme of nuclear plant construction in the UK.

The UK has a long history in nuclear. Indeed this year marks the 50th anniversary of the NII. It's a controversial industry and public opinion is divided, but our job is not to get involved in the policy debate. Our job is to ensure that if nuclear plants are built, then they are built and operated to the highest standards of health safety and security. And our record for securing this over the last half century has been of the highest order, and in doing so earning trust and confidence.

My aspiration is that we should be a world-leader. If we're going to do it, let's be the best.

Slide 4 : a world-leading nuclear regulatory system

So what does a world-leading nuclear regulatory system look like? I think there are three major elements.

First - a robust regime. In the UK, we have created a strong framework of assessment, inspection and enforcement. It is underpinned by a site licensing regime which places the responsibility for nuclear safety firmly on the operator or licensee. We also see our contribution as one of influence because our role is much more constructive if we work with operators to resolve issues through our combined expertise.

Second - transparency. The whole system needs to be open to public scrutiny, if government, industry and regulators are to earn people's trust. Some would argue that we have a good track record in the past but we live in an ever changing world where events which happen beyond our shores, public expectations and trust in experts has changed. Our communication and our transparency needs to become more proactive rather than responding to questions when asked - but more on this in a moment.

Third - a continuous improvement culture based on an outward-looking attitude. We actively seek to test ourselves, listen and learn lessons from others. This means actively engaging with - among others - the International Atomic Energy Authority, OECD, and regulators in the US, France and Finland, to allow us to learn for others experiences and get on the front foot.

And the evidence shows that Britain is both learning and leading in this respect. We have now had two very positive reports from IAEA reviews. The first, in 2006, said that the UK had a mature, transparent, expert regulatory system which had many areas of good practice.

Then in October last year, an IAEA team visited the UK and reported that we had made further significant progress1. This is an important strength for the UK in a world where nuclear power is resurgent, with around 50 countries with no previous experience of a nuclear power programme having approached the IAEA for assistance in building capability.

Slide 5: New nuclear - designing in health and safety

We need to maintain this progress now that Britain is well into the planning stages of the programme under discussion today. The programme may include as many as 10 or 12 new reactors, each of which will be significantly larger than any of the existing reactors in this country.

Our approach to this programme has been to build health and safety excellence into the process from the start. Nothing can be allowed to go through on the understanding that it will be fixed later.

A large element of the preparatory work has been the Generic Design Assessment, or GDA, process, that we are delivering in close partnership with the Environment Agency.

The GDA process is an important innovation because it enables the generic design of a type of reactor to be considered independently from site-specific issues It means that the regulator and potential operator can focus together on the generic design - in Britain's case the Westinghouse AP1000 and the AREVA EPR models, although other designs may follow.

It also means we can look at health and safety issues in a constructive way that helps prospective operators resolve potential problems at an early stage.

For companies, it means that they have tested their designs against demanding criteria that are widely respected internationally and this helps in marketing them elsewhere.

From our perspective, we have early sight of the design factors and can raise and resolve issues when necessary and whilst the design is still in the development phase, rather than under construction. And the whole process is also very transparent. The public can see detailed information online - for example on HSE's website - and can comment on it.

Indeed regulatory issues have been raised, most recently asking for more information on the capability of the Westinghouse AP1000's concrete filled steel structural modules to fulfil their safety functions for major physical impacts and other incidents.  

With the EPR, the main issue raised was the independence of the reactor protection systems from the control systems that are used for the plant under normal conditions. This was an issue over which the UK, French and Finnish regulators acted in concert to ask for improvements to the initial design. It was also a good example of how regulators can work together to share knowledge and promote a harmonised approach.

Slide 6: When building begins

Looking to the future, the GDA's methodology is providing a good template for regulating the construction phase. But in this phase, the challenge will be to also ensure that the supply chain works together to manage construction related health and safety risks - such as falls from height, workplace transport and health related issues. We know that strong client led projects can deliver innovative solutions which not only add value to the construction process but also deliver world class health and safety performance.

We must not forget the key contribution that design has in relation to the safe maintenance and long lifespan of operation. Whilst rightly the focus is currently on GDA, maintenance and ongoing operation should not be considered as an after thought but rather an integral part of design. Failure to address them can be costly not only in health and safety terms but also financially.

The time pressures that are likely to be felt throughout construction work must not be and will not be an excuse for cutting any safety corners in any aspect of nuclear new build.

The scale and profile of the nuclear programme is such that we are continually building the capability of the Nuclear Directorate to ensure it is fully equipped for its function. Part of that process is the planned transition to the status of a Statutory Corporation under the auspices of HSE.

Industry has a clear responsibility for managing its risks and this goes beyond the details of the design process. It includes wider questions such as gaining public trust and building the capability to carry out a safe, efficient construction phase.

The fact that we have a rigorous design assessment which clearly flags up any issues helps to allay people's concerns, but there is also a job for industry to do in building its authority and earning confidence among stakeholders.

Incidentally one simple way of doing that is to sign HSE's pledge which commits organisations to support the national strategy and play their part in reducing work-related deaths, injuries and ill health. Already over 1,000 employers have signed up, including AREVA and Westinghouse2.

Ahead of construction there are also questions to resolve about the quality and reliability of the nuclear supply chain. Once we get into the actual project, will every component that is delivered on-site be fit for purpose? Will every contractor's employee be professionally competent? Will every welder, for example, have the specific skills needed for the job?

The construction of the new reactor in Finland has highlighted the issues that can arise as you transition from the design stage to a project involving over 4000 contractors working on a shift basis. Our fact-finding mission to Olkiluoto [Oak-U-Loo-Two] clearly demonstrated the need for advanced planning including a well defined safety programme.

In terms of procurement, it highlighted the need for the operator to be what we call an "intelligent customer", responsible for anything it contracts out to others, and who anticipates challenges and puts in place measures to address them, so that sufficient resources, including materials and labour with suitable competencies and expertise, are available.

It has been many years since a nuclear build programme of this magnitude was built in Britain and the sector skills council, Cogent, has recognised that there is an acute skills shortage in the industry3. This is now being addressed, particularly through the National Skills Academy for Nuclear and the Nuclear Technology Education Consortium. The question for the industry is whether there is more it could and should be doing to achieve strategic co-ordination and leadership on the skills issue.

New build must not rely on the regulator to ensure the quality of supply and build. The prime responsibility for high quality equipment and well-qualified staff lies with operators.

In nuclear projects, as in all major projects, our experience is that high standards in commercial and operational performance go hand in hand with high standards of health and safety. Health and safety is a leading indicator of overall quality. And what that says to me is that leadership matters. Good leaders get everything right, with excellence in health and safety coming first.

Slide 7: The Olympic Delivery Authority - a useful role model

I'm a strong advocate of learning from others and looking outside of your sector for solutions and smarter ways of doing things.

One example is the Olympic Delivery Authority for the London 2012 games. The ODA is an excellent example of how a large time-bound project can be successfully managed from an HSE perspective. The ODA has an explicit commitment to being a health and safety leader. It has clear aims and performance objectives. It audits suppliers to ensure they meet its standards. Contractors have to participate in a leadership forum. Workers are engaged through toolbox talks, briefings, near miss reporting, surveys and awards. And the ODA has also appointed an external delivery partner to monitor progress and ensure its standard is met.

In my view, those are all leadership actions and I would be very encouraged if the new-build nuclear projects adopted similar processes.

Slide 8: Title slide

We are on a journey together - the UK's nuclear industry and its regulator. We have made a lot of progress and we have been recognised as giving a lead internationally. But that has been at the design stage.

Procurement and construction changes the picture. It will mean a new phase of the journey with its own challenges. But I hope you agree with me that we have now created a good model for working with each other.

Key features of that model are openness, quality and reliability. Above all the pattern is one of anticipation, being prepared, dealing with issues proactively when they arise and not putting anything off.

So far that model has worked well. It has been a productive relationship and I look forward to continuing to work with you in the months and years to come to deliver a healthy, safe, secure nuclear industry for Britain.

Thank you.

Footnotes

  1. Press release - HSE welcomes IAEA report
  2. A - Z of organisations signed up to the pledge - [N]
  3. National Skills Academy for Nuclear
Updated 2016-02-16