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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
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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
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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).
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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”
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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
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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
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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
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The MOD Ranges Safety Management System
Safe MOD Ranges and Training Areas Safe Place Safe People Safe Equipment Safe Practice
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The Major Accident Control SMS
Prevent Control Major Accident
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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
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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
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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
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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
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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
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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
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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….
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Defence Ordnance, Munitions and Explosives Safety Regulator
7500 Which when divided between my 11 inspectors means…. Defence Ordnance, Munitions and Explosives Safety Regulator
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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
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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
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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
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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
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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
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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
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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
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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
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DOSR Questions ?
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