1. Regulating OME Safety in UK Defence
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
Defence Board
Organisational Separation
Reports to
OPERATIONAL
Permanent Joint Headquarters
Directorate Special Forces
Defence Safety Authority
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
Defence Authority for HS&EP
Force Elements
GENERATES AND DEVELOPS
Navy Command
Army Command
Air Command
Joint Forces Command
REGULATES
ASSURES
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.
ENFORCES
INVESTIGATES

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.
MOD Regulations
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.
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).

5. Continuous Improvement
The Defence SEMS
Implementation Products & Activities
MoD Safety & Environmental Protection Management System
Step 2 - Implement Safety Programs
Step 3 – Monitor Performance & Assure Compliance
Step 4 - Conduct Management Reviews
Step 1 - Plan for Safety
Set the risk appetite
Risk mitigation & control
Continuous Improvement
Corrective Action &
Understand Effectiveness
Knowledge Management
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 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
“Do”
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
“Plan”
“Check”
Step 3 - Deliver/Undertake:
Conduct assurance 1st/2nd/3rd 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
“Act”

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

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

8. DOSR Regulatory Activity Across OME Life-Cycle Phases (LCP)
Acquisition
LCP2
Logistics
LCP3
In-Service
LCP4
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 MOD Ranges and Training Areas
Safe Place
Safe People
Safe Equipment
Safe
Practice

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
1st Party Assurance
Safety Case etc
Weapons Eng
2nd Party Assurance
OSRP/OSA
Regulator
3rd Party Assurance
Approval

13. DOSR Team Structure Adopting a proportional and risk-based approach
Defence OME Safety Regulator (DOSR) B1
Policy, Regulations & Guidance B2
Assurance & Enforcement
Analysis & Plans
2 x C1
5 x C1
1 x C1
3 x C2
6 x C2
1 x C2
1 x E1 -
Develop and maintain DOSR suite of DSRPs that ensures a blend of both goal-based 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 A&P/RAE Lead responsible for conducting sophisticated, evidence-based risk analysis.
Manage “DOME” input/output
Manage DOSR Licensing and Permissions.
DSA Environmental SME Lead (a ‘shared’ DSA resource but principally supporting the newly established MACR Competent Authority).
Output = DOSR Annual Report to DG DSA

14. Stephen Gillström McLean DOSR Assistant Team Leader Assurance
MOVING TOWARDS RISK BASED ASSURANCE TO MAXIMISE THE RETURN FROM A LIMITED RESOURCE
That’s me…..
I am Stephen Gillström McLean, one of the Assistant Team Leaders in the Defence Ordnance, Munitions Explosives (OME) Safety Regulator (DOSR) responsible for undertaking audits and inspections to provide assurance, through my DOSR-TL, to the S of S that activities involving OME are being conducted safely.
Defence Ordnance, Munitions and Explosives Safety Regulator

15. Defence Ordnance, Munitions and Explosives Safety Regulator
My Role / My Team
Our Scope
What we do now
Why Change?
New Methodology
Questions
It will cover these topics….
Defence Ordnance, Munitions and Explosives Safety Regulator

16. Defence Ordnance, Munitions and Explosives Safety Regulator
This is my team:
11 inspectors / auditors covering:
Range Safety and LASERs
Explosives Safety
Major Accident Control
Safety in Acquisition
Defence Ordnance, Munitions and Explosives Safety Regulator

17. Scope of DOSR Regulatory Activity
Lasers
500 Systems
Ranges
1651 Locations
Explosives Operations
4000 Licences over 700 locations
Major Accident Control
29 Locations
OME Acquisition
1300 items involving 29 Project Teams
This slide details the OME activity covered by DOSR that is subject to Audit and Inspection.
A large number of targets for a team of 11.
A total of approximately….

18. Defence Ordnance, Munitions and Explosives Safety Regulator
7500
Which when divided between my 11 inspectors means….
Defence Ordnance, Munitions and Explosives Safety Regulator

19. Defence Ordnance, Munitions and Explosives Safety Regulator
680
680 inspections per inspector per year.
This is obviously not possible, so we need to select where we undertake our assurance activity.
Defence Ordnance, Munitions and Explosives Safety Regulator

20. Defence Ordnance, Munitions and Explosives Safety Regulator
What do we do now?
So what do we currently do?
For historical reasons it varies across my functional areas.
Some are calendar based,
Some are rather adhoc, based primarily on consequence, specific themes and the fact we haven’t inspected for a while.
Defence Ordnance, Munitions and Explosives Safety Regulator

21. Defence Ordnance, Munitions and Explosives Safety Regulator
Ranges
Lasers
Explosives
MACR
Acquisition
Calendar based inspections,
Peer reviews of LTARs.
10% check of Dstl self-certification,
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 2nd Party Assurance function across TLBs.
Calendar based assessments, leading to MACR re-certification 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.
This table shows the differences.
Ranges – every range is inspected once every three years (1/3 of ranges completed each year) – all ranges are treated the same.
LASERs – Certified by a MOD expert, who currently sits outside the regulator, or self-certified under authority. DOSR assurance is undertaken where Self-Certification is in place.
Explosives – Selection of sites, focussing on those that are MACR qualified (what are the limits???), across the service areas (navy, army, air force, etc.) Annual programme is topped-up with themed inspections.
MAC – Calendar based assessments (every 5 years), with an interim emergency exercise witnessed.
Acquisition – 8 Operating Centres with OME responsibility (procurement or platform integration) visited on a rolling 3 year programme
Defence Ordnance, Munitions and Explosives Safety Regulator

22. Defence Ordnance, Munitions and Explosives Safety Regulator
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
It is RAE that I wish to expand upon.
Project #2 – Report / Analyse / Exploit (RAE) is aimed at:
R: Delivering a capability for our Services / MOD Organisations to report safety data in a consistent/coherent way, to share it among themselves, as well as with DSA.
This includes…….Assurance data, Incident / Accident data – DOSR has developed the DOME Tool (Database for OME)
A: Delivering DSA analysis capability.
DOSR has recently established an A&P team
E: Delivering DSA capability to make evidence-based decisions on where to focus resources.
Defence Ordnance, Munitions and Explosives Safety Regulator

23. What Evidence Do We Need?
Gathering / having access to sufficient levels of appropriate data to analyse is the key to success.
I have identified the data that should be gathered through DOME to enable the A&P team to consistently identify areas of greatest risk, and therefore inform both PRG and Assurance as to where their resource should be focussed.
This info is divided into 2 categories:
“Consequence” of an unplanned event
And
“Organisation’s / site’s HS&EP performance and probability of an event”
I have devised a scoring methodology that uses this info to plot a 2 dimensional graph.
Defence Ordnance, Munitions and Explosives Safety Regulator

24. Defence Ordnance, Munitions and Explosives Safety Regulator
Risk
Serial
Factor
High
(Score = 4)
Medium
(Score = 3)
Low
(Score = 2)
Very Low
(Score = 1)
Consequence Factors 1 HD
1.1
1.2
1.3
1.4 2
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 .
Firstly, the consequence factors
This table shows the factors that have been identified for my Explosives Assurance activity.
There could be more than these 5, but I believe data on these is available:
Describe the factors
Basically these help to identify how big the bang would be, who would be hazarded and where non-standard situations exist.
For each of these a score is awarded, where a 4 indicates highest concern.
These factors usually remain constant.
Defence Ordnance, Munitions and Explosives Safety Regulator

25. Defence Ordnance, Munitions and Explosives Safety Regulator
TLB Performance & Event Probability Factors 6
Accidents / Incidents last 5 years
Fatality
Major Injury;
Numerous major incidents
Minor Injury;
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,
No rectification work outstanding 8
Regulator Inspection History
Prohibition notices served
Improvement notices served
No enforcement notices but some non-confromances identified
Nothing worse than some minor observations have been made 9
Last DOSR Inspection
Never
Within 3 years
Within 12 months
Within 6 months 10
Self-Assurance
None undertaken
Some undertaken,
no evidence available that areas of concern identified have been addressed
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
To complete the graph I use these factors to assess the performance of the regulated and the probability of an unplanned event.
These factors can and do change and lead to an increase or decrease in concern; meaning that sites / Organisations can become of more or less interest to the regulator.
Discuss the 7 factors
Again a score is awarded.
Defence Ordnance, Munitions and Explosives Safety Regulator

26. Defence Ordnance, Munitions and Explosives Safety Regulator
The scores for each axis are calculated and plotted, with the highest risk appearing in the top right corner.
These sites would be subjected to: Increased Regulator Attention
The sites in the top right should change over time, as site performance improves, activities change, or due to more recent assurance activity from DOSR.
There are other factors we need to consider:
For example, Confidence in the information we have collected, as it gets older its validity can reduce; if we haven’t refreshed this for a considerable time we should consider doing so.
Also any Service / Organisation concerns – Risk Register - SQEP
All that remains is to gather enough data. This is a large task, and the regulator will require the help of the regulated community. I am hopeful that once it is understood that the regulator is keen to focus on areas of concern they will be keen to share their regulatory performance with us. Even where there are failings, if they are being addressed, that is positive.
We are more likely to leave the good performers alone and inspect elsewhere. Those that don’t offer this information, the lack of data may mean we need to come knocking.
Defence Ordnance, Munitions and Explosives Safety Regulator

27. DOSR
Questions ?