10 / 2005 Instruction / CSE

NAVAL AUTHORITY NOTICE
10 REV1 / 2005
INSTRUCTION / CSE
APPLICABILITY - ALL MOD SHIPS AND NAVAL BASES
Policy and Procedures for Regulation of Explosives Risk of

Warships In Harbour
Notice to MOD Duty Holders, Duty Holders’ representatives and Contractors.
The NAN provides additional guidance to supplement the information provided in JSP430 Issue 4 Part 3, Chapter 8 and is
planned to be subsumed into it following the NAN expiry date.
NAN IMPLEMENTATION DATE : 01 July 2007 NAN EXPIRY DATE: 30 June 2009
Summary
Naval Authority Regulations (NAR) (presented as JSP430, Part 3, Issue 4, Chapter 8) and NAN 09/2005 detail
the process that is to be followed for safety management and regulation of explosives carried and used by
warships. NAR Chapter 8 addresses the new process that will result in the issue of a Certificate of Safety
Explosives (CSE) and NAN 09/2005 details the process to be utilised in the transition period to full CSE
implementation. When berthed alongside, Warships In Harbour (WIH) represent an explosives risk and
responsibilities for managing this risk cross several Duty Holder (DH) boundaries. The arrangements required
to cover these aspects have been derived from the Warships In Harbour Project as additions to the existing
regulatory processes. These are manifested in an extension to CSE requirements for Platforms and in the
introduction of a Certificate of Safety Explosives for Naval Bases (CSENB).
There is a requirement for Platform Duty Holders (PDH) and Naval Base Duty Holders (NBDH) to provide
assurance that residual risks from explosives hazards associated with Warships In Harbour have been controlled
to levels deemed to be ALARP and tolerable.
It is required that PDH and NBDH include explicit assurances for explosives risks from WIH as an element of
the submission that is presented to Naval Authority Explosives (NA EXP) when seeking a CSE or CSENB,
respectively.
The requirements for WIH management and regulation are provided in this Notice, NAN 10/2005. Recognising
the time required to produce safety cases and the dependencies between them, expectations regarding the
implementation of this system by Duty Holders and NA EXP are also outlined.
CONTENTS
List of Abbreviations
CHAPTER 1 POLICY
1.1 Introduction
1.2 The Need for Regulation
1.3 Regulator Scope and Interfaces
1.3.1 Nuclear Safety
1.4 Terms of Reference
1.4.1 Naval Authority Explosives as WIH Regulator
1.4.2 Naval Authority Explosives Advisory Sub Committee – Naval Bases and Harbours
CHAPTER 2 NAEXP REGULATORY FUNCTION FOR WIH

2.1 Policy Formulation
2.2 Provision of Guidance
2.3 Conduct of Safety Assurance Tasks
2.3.1 Assurance Processes
2.4 Liaison
CHAPTER 3 REGULATOR’S ASSESSMENT OF SAFETY CASE REPORTS

3.1 Assessment Frequency
CHAPTER 4 REGULATOR’S AUDIT OF DUTY HOLDERS

4.1 Site Safety Management Arrangements
4.2 Warship Safety Management Arrangements
4.3 Audit Frequency
4.4 Audit Findings
CHAPTER 5 IMPLEMENTATION
5.1 Introduction
5.2 Regulator Stand-Up (June 2005)
5.3 Ship Explosives Safety Case Development
5.4 Audit and Periodic Review
5.5 Implementation - Summary
ANNEX A CERTIFICATE OF SAFETY EXPLOSIVES FOR NAVAL BASES

ANNEX B INTERFACES THROUGHOUT THE LIFECYCLE OF A CONVENTIONAL
NAVAL EXPLOSIVE
ANNEX C NAVAL BASE AUTHORISATION CONDITIONS
ANNEX D PROFORMA FOR NAVAL BASE AUTHORISATION CONDITION
COMPLIANCE STATEMENTS
List of Abbreviations
AC Authorisation Condition
ACCS Authorisation Condition Compliance Statement
ALARP As Low As Reasonably Practicable
BR Book of Reference
CIE (MOD) Chief Inspector Explosives (MOD)
CINC FLEET Commander In Chief Fleet
CNNRP Chairman Naval Nuclear Regulatory Panel
COMAH Control of Major Accident Hazards
CSE Certificate of Safety Explosives
CSENB Certificate of Safety Explosives for Naval Bases
DA Design Authority
DH Duty Holder
ENEQ Effective Net Explosive Quantity
FAP Forward Action Plan
F-N Frequency-Number
GHE Generic Harbour Environment
HAZID Hazard Identification
HEAS Harbour Environment Assessment Statement
HSE Health and Safety Executive
IPT Integrated Project Team
ISA Independent Safety Advisor
JSP Joint Service Publication
LOD Lines Of Defence
MOD Ministry Of Defence
NA EXP Naval Authority Explosives
NAEAC Naval Authority Explosives Advisory Committee
NAN Naval Authority Notice
NAR Naval Authority Regulations, aka JSP 430, Part 3
NATO North Atlantic Treaty Organisation
NB Naval Base
NBDH Naval Base Duty Holder
NBH Naval Bases and Harbours
NBSSC(WIH) Naval Base Site Safety Case (Warships In Harbour)
OME Ordnance Munitions Explosives
PDH Platform Duty Holder
PIPT Platform Integrated Project Team
RRM Risk Reduction Measure
SESC Ship Explosive Safety Case
STG Sea Technology Group
UN United Nations
WHFS Warship Hazard Footprint Statement
WIH Warships in Harbour
WIHCP Warships in Harbour Consequence Protocol
WIHSG Warships in Harbour Study Group
WIHSGL Warships in Harbour Study Group Leader
CHAPTER 1 - POLICY
1.1 Introduction
The policy for Warships In Harbour (WIH) is developed to protect people, as required by the Secretary of State’s
policies on Health and Safety for ships and associated equipment, and to protect the material condition of the
warship and equipment whilst providing maximum defence capability. Current policy is that the legal
requirements of the Health and Safety at Work Act 1974, and JSP430, the Ship Safety Management System
Handbook, shall be complied with. These require that Duty Holders responsible for design, development and
supply of equipments shall be able to prove that all investigations and analyses necessary to demonstrate that the
equipment is free from risks to health and safety have been carried out and that known risks have been reduced to
levels deemed at least tolerable and As Low as Reasonably Practicable (ALARP). Similarly, Duty Holders
responsible for control, supervision, operation and development of berths and facilities in Naval Bases shall be
able to demonstrate that risks associated with their activities are understood and have been reduced to levels
deemed at least tolerable and ALARP.
When berthed alongside, Warships In Harbour represent an explosives risk and responsibilities for managing this
risk cross several Duty Holder (DH) boundaries. A safety regime has been established that, in conjunction with
HM Naval Bases, demonstrates the explosives risk presented to the Dockyard and to Society by the presence of
Warships in Harbour is at least tolerable and ALARP. A part of this regime, a Regulatory Framework has been
established that applies to warships in both civilian harbours and Naval Bases, and which includes the articulation
of the interfaces between the various duty holders, and regulation of these by NA EXP.
The regulatory arrangements required to cover these aspects have been derived through the Warships In Harbour
Study Group (WIHSG) as additions to the NA EXP Regulatory processes. These are manifested in an extension
to CSE requirements for MOD ships [1] and in the introduction of a Certificate of Safety Explosives for Naval
Bases (CSENB). A template for the CSENB is provided at Annex A.
This Naval Authority Notice (NAN) defines the requirements for WIH management and regulation that form part
of the broader NA EXP regulatory processes specified in Naval Authority Regulations (NAR), NAN 09/2005 and
associated notices and instructions.
1.2 The Need for Regulation
The general approach to regulating Health and Safety, as set out in the HSE document Reducing Risks, Protecting
People [2] is risk-based with duty holders taking responsibility for ensuring that adequate levels of safety are in
place to protect their workforce and members of the general public. However, if work activities to be undertaken
involve significant hazard or risk to the general public then the HSE stipulate the use of a ministerially agreed
permissioning regime [3].
The regulation of permissioning regimes requires three main activities: examining safety management systems;
setting standards (both technical and management) and gaining assurance that those standards are being met
without unduly compromising the ability to conduct operations. By doing this regulators provide the added level
of confidence that duty holders are discharging their responsibilities correctly so as to secure public confidence.
The risks posed by WIH necessitate some form of permissioning regime to be put in place, which in turn requires
a regulator to manage and oversee this. WIHSG has defined the tasks of a regulator and concluded that NA EXP
is the most suitable choice for WIH regulator. This NAN takes these conclusions forward and defines the
framework within which regulation will take place.
1.3 Regulator Scope and Interfaces
1
JSP 430, Part 3, Chapter 8, Issue 3, March 2005
2
Reducing Risk Protecting People – Health and Safety Executive 2001.
3
Our Approach to Permissioning Regimes – HSE Policy Statement Mar 2003.
The WIH regulator will have to interface with different internal and external regulators. These regulators include
(but not exclusively) Chief Inspector Explosives (MOD), Nuclear Weapon Regulator, Naval Nuclear Regulatory
Panel and the Health and Safety Executive.
The scope of WIH regulation is limited to the risk presented by conventional explosives in the quiescent state
onboard warships undergoing normal alongside activities such as stand downs, routine maintenance and Fleet
Time Support Periods (Assisted Maintenance). As such it does not include any of the following activities, which
are already regulated through JSP 482 and other regimes:
a. Ammunitioning;
b. Small quantity top ups;
c. Working ammunition alongside;
d. Conducting non-allowed maintenance in magazine spaces;
e. Emergency Docking;4
f. Nuclear explosives.
The regulatory framework comprises several regulators, each assigned responsibility for specified key hazards.
These regulators each provide assurance through the MOD safety management system to the Secretary of State
for Defence, that the hazards that they are regulating are being managed correctly and that the risks are ALARP.
In effect this means that all regulators are equal and within the Naval Base environment, as Duty Holder the
Naval Base Commander does have several different regulators, regulating various key hazards that exist. The
NBDH is then able to take a holistic view across all hazards based on advice received from the individual
regulators, thereby ensuring that the risks associated with activities are reduced to ALARP and that risk is not
merely transferred from one hazard area to another.
This approach aims to simplify regulator interfaces and allows a clear demarcation between inter-regulatory
responsibility. It provides duty holders with clear points of contact for each key hazard and provides clear lines of
responsibility and authority when looking at different hazards. For WIH, NA EXP regulates all aspects of the
risks posed by conventional explosives on a Warship, including the effect of these on 3rd parties. It does not
however regulate the effects of these on other key hazards, the regulator boundary representing where the output
of one key hazard’s safety case becomes an input to another.
The model shown at Annex B represents the interfaces throughout the lifecycle of a conventional Naval
explosive. The model is intended to offer clarification of regulatory and duty holder responsibilities and illustrates
the broader system within which explosives safety issues associated with Warships In Harbour are managed and
regulated.
1.3.1 Nuclear Safety
While the WIH regulatory scope does not extend to nuclear risks in NBs, there is an important interface between
the areas regulated by NAEXP and Chairman Naval Nuclear Regulatory Panel (CNNRP). The risks posed by
WIH to nuclear-implicated activities will be assessed using the same information provided by PDHs to NBDHs in
assessing the risks posed by WIH to people. Hence, in regulating the conventional explosives risks from WIH,
NAEXP provides assurance regarding ship explosives safety that CNNRP will take cognisance of in the
regulation of nuclear hazards.
4
As defined in BR862 – Naval Explosive Regulations Issue 7.
1.4 Terms Of Reference
WIHSG has put forward the following Terms of Reference for the regulator and a new advisory committee to
facilitate continued liaison between regulators and other WIH stakeholders beyond the regulator stand-up date
(June 2005). The respective Terms of Reference are presented below ahead of their incorporation into JSP 430,
Part 3, Chapter 8 and related documentation.5
1.4.1 Naval Authority Explosives (NA EXP) as Regulator of Explosives Risk from Warships In Harbour
The high level terms of reference for NA EXP, which encompass the WIH regulatory function, are as follows:
Naval Authority Explosives, through delegation from the Ship Safety Board (and ultimately the Secretary of
State for Defence) will undertake the following:
• Determine, set, promulgate and maintain MOD standards and regulations concerning the safety of
explosives including their impact on third parties and the environment, onboard all JSP430 ships,6
assuring that duty holders comply with current legislation.
• Determine, set, promulgate and maintain MOD standards and regulations concerning the explosive
safety of JSP 430 ships and their impact on third parties, specifically covering the interface between
the harbour and the vessel, assuring that duty holders on both sides of the interface comply with
current legislation.
• Provide technical advice on warship explosive issues to Other Government Departments, the MOD,
NATO, the UN and national and international organisations as required.
1.4.2 Naval Authority Explosives Advisory Sub Committee – Naval Bases and Harbours
To facilitate the development and promulgation of appropriate standards, an additional subcommittee to the
NAEAC has been formed to cover naval explosives safety issues affecting, and affected by, Naval Base and
harbour activities. This subcommittee is titled the NAEAC – Naval Bases and Harbours (NBH) and the terms of
reference are:
NAEAC – NBH. To provide advice to the Regulator and duty holders with respect to policy and regulation of
explosives safety across the interface between harbours and JSP430 ships. 7
The NAEAC-NBH provides recommendations to the regulatory bodies on the policy and regulation of explosives
safety when moving and transferring munitions to and from JSP 430 ships across the regulatory boundaries, to
provide a forum to discuss issues for all stakeholders, to confirm that a holistic approach is being taken and that
residual risks are tolerable and ALARP.
5
Based on the structure of Issue 3, these could readily be added to Section 4 of the JSP.
6
To which JSP430 – Ship Safety Management applies. Includes surface ships and submarines.
7
All vessels alongside, anchored or at buoys or moorings within harbour limits.
CHAPTER 2 – NAEXP REGULATORY FUNCTION FOR WIH
The tasks which NAEXP will need to undertake as regulator of explosives risk from WIH are derived from the
Terms of Reference above. The primary function of the regulator is authorisation of WIH-related activities.
Similar to the regulation of other key hazards for JSP 430 ships, this authorisation will be in the form of
Certification by NA EXP. The specific aspects of certification covered by the arrangements in this NAN are as
follows:
Naval Bases. NA EXP will certify each Naval Base. This will involve examination of the aspects of WIH
explosives risk management that fall within the control and responsibilities of Naval Base Duty
Holders, with particular emphasis on arrangements at berth level.8 Certification is based on
arrangements in place to manage the risk and their effectiveness in practice and will be expressed
in the form of a Certificate of Safety Explosives for Naval Base (CSENB).
Platforms. NA EXP will certify each MOD ship as part of the overarching Certificate of Safety Explosives
(CSE) process.9 This will involve examination of the aspects of WIH explosives risk management
that fall within the control and responsibilities of Platform Duty Holders. Certification is based on
arrangements in place to manage the risk and their effectiveness in practice.
The specific tasks required to enable authorisation to occur are broken down under a number of functional
headings:
a) Policy Formulation
b) Provision of Guidance
c) Conduct of Safety Assurance tasks
d) Liaison
These are described in turn below.
2.1 Policy Formulation
While the policy is currently published as an output papers from the WIHSG in the form of a NAN, where
applicable this policy will be incorporated into relevant JSPs and other standing documentation. NA EXP is
responsible for maintaining and developing WIH policy and promulgating it in the appropriate manner. The two
key areas of responsibility are:
1) Determine WIH Policy - NA EXP is responsible for determining WIH policy and ensuring that it meets the
requirements of higher level safety policy cascaded through the MOD safety management system
2) Determine WIH Tolerability criteria – NA EXP is responsible for determining and promulgating WIH
tolerability criteria.
2.2 Provision of Guidance
The provision of guidance in both the promulgation of formal policy and guidance documents and Duty Holder
assistance by appropriate skilled personnel within the NA EXP organisation will be key to the successful
management of WIH risk by relevant Duty Holders. The key areas of guidance required are:
a. Guidance on WIH regulation, the approach and methodologies adopted and how these can be applied by
Duty Holders to produce a WIH safety case.
b. Guidance on the production of the WIH aspects of the Ship Explosives Safety Case (SESC).
8
For WIH, consideration at berth level is particularly important in that this is the level at which the interfaces with ships are
managed. Hence, regulatory interest will be focused at HEAS and WHFS, as these provide the clearest evidence of how well
the interfaces (and WIH risks) are being controlled.
9
The broader CSE process, of which WIH forms part, already exists and is described in NAR Chapter 8 and NAN 09/2005.
c. Guidance on the production of the Naval Base Site Safety Case for Warship In Harbour (NBSSC(WIH)).
d. Guidance on arrangements to manage the interfaces between the SESC and the NBSSC(WIH).
e. Defining the datum parameters within the Generic Harbour Environment.
f. Defining the warship standard operating environment for a WIH to enable consistency across Ship
Explosives Safety Cases.
g. Development of the WIH tool set and associated guidance on use.
h. Maintain the WIH methodology, tools and data, including generic safety case information.
Tasks (a)-(g) build on the products from the WIHSG produced prior to the WIH regulator stand up date of June
2005 [10]. These products are useful in their delivered form but will require transfer into standing publications
and possibly the introduction of new publications as WIH transfers to normal business following regulator stand
up. This is covered by Task (h) which initially involves taking the WIHSG output and transforming it into the
correct publications, whereupon it will continue to be maintained by NA EXP. This task will take place over the
longer term as documents are updated in accordance with current review plans.
2.3 Conduct of Safety Assurance Tasks
NA EXP certification and the assurance it provides will be based on evidence presented in safety cases and
subsequent verification that safety is actively managed by Duty Holders in accordance with the safety case and
modern standards. The assurance tasks form the core of the regulatory process, the primary outputs of which are:
a. Certification of the Naval Base that the safety management system in place ensures that the risk posed by
WIH is tolerable and ALARP;
b. Certification of JSP 430 ships that the key hazard of explosives and the associated risks are tolerable and
ALARP 11;
c. Certification of departures from the standard operating regime12 of either the naval base or platform
where there is a significant affect on WIH risk;
d. Application of constraints, caveats or provisos to the certification of either the naval base or platform
where there is a significant affect on WIH risk; and
e. Periodic review and audit of safety management arrangements outwith the certification processes.
2.3.1 Assurance Processes
The processes employed by the regulator in performing these assurance functions are ‘assessment’ and ‘audit’.
While each of these is covered in subsequent chapters of this NAN, in brief they comprise:
a. Assessment of Ship Explosives Safety Case Reports submitted by Platform Duty Holders in support of a
vessel’s certification13;
b. Assessment of NBSSC(WIH) Reports submitted by Naval Bases in support of site certification;
10
Warships In Harbour Methodology Suite, DPA/STG/28/13/16. Part of the overall WIH document suite, available from
http://y4.dpa.r.mil.uk/kb/Organisati/SGs/STG/List-of-Services1/Warships-in-Harbour/index.htm
11
The certification process already exists – the WIH aspects will form an integral part of the CSE process.
12
Defined as the operations and conditions for which the respective safety case remains valid.
13
WIH aspects will form an integral part of the Ship Explosives Safety Case.
c. Assessment of safety case reports submitted in justification of proposed departures from the standard
operating regime;
d. Audit of Duty Holders to ensure compliance with the respective safety cases. In particular:
(1) Compliance of safety cases with the WIH methodology;
(2) Sites comply with the Generic Harbour Environment (GHE) and maintain the environment described
in the Harbour Environment Assessment Statement (HEAS), as produced by NBDHs;
(3) Platforms comply with the Warships In Harbour Consequence Protocol (WIHCP) and maintain the
conditions represented in the Warship Hazard Footprint Statement (WHFS), as produced by PDHs.
The processes for Assessment and Audit are described in Chapters 3 and 4, respectively.
2.4 Liaison
In addition to direct liaison with duty holders, the regulator will liase with a number of other regulatory and non
regulatory bodies. This will principally be achieved in the following manner:
a. NAEAC – NBH. This sub committee of the NAEAC will provide a forum for all WIH related
stakeholders to discuss WIH issues and policy, providing feedback to Naval Authority Explosives as
required.
b. Regulator Forum – This 2 star (Ship Safety Board) chaired meeting provides high level liaison of the
various warship related regulators.
c. WIH Study Group – The WIH Study Group was established to develop the WIH methodology and
manage the initial phases of its implementation. As WIH has transitioned to NAEXP normal business,
formal meetings of the WIHSG have ceased but may exceptionally be called if the need arises.
CHAPTER 3 – REGULATOR’S ASSESSMENT OF SAFETY CASE REPORTS
Duty Holders present evidence that risks are adequately managed in the form of safety case reports as follows:
Naval Bases. Evidence is provided in the form of a NBSSC(WIH) report. While the following list is not
exhaustive, key WIH aspects include risk assessment, safety management arrangements
(compliance with Authorisation Conditions), characterisation of threats (berth HEASs), safety
performance (against modern standards), ALARP assessment (RRMs) and Forward Action Plan
(commitment to implement RRMs etc.).
Platforms. Evidence is provided in the form of a Ship Explosives Safety Case report. While the following list
is not exhaustive, key WIH aspects include risk assessment, safety management arrangements,
characterisation of consequences (WHFS), safety performance (against modern standards), ALARP
assessment (RRMs) and Forward Action Plan (commitment to implement RRMs etc.).14
The Regulator takes the evidence presented and assesses whether it is satisfactory, applying a level of scrutiny to
each element that is proportionate to its significance (in terms of WIH explosives risk).
Changes to sites, platforms, operations or the surrounding environment will need to be addressed by Duty Holders
through the respective safety case(s). Depending on significance, the Regulator will assess the change through
evidence submitted by the Duty Holder(s) which present the implications by way of affect on the safety case. Any
constraints / caveats / provisos will be stated in the safety case and the change certified accordingly. As
appropriate, NA EXP may stipulate corresponding Conditions and Mandatory Requirements of Certification as
part of the CSE / CSENB.
3.1 Assessment Frequency
The timing of assessment activities is dependent on certification requirements, broadly characterised as ‘first
submission’, ‘periodic review’ or ‘change control’.
‘First submission’ describes the situation where the Regulator receives an application for a certificate and its
corresponding safety case report for either a new15 or legacy system. The purpose of a ‘periodic review’
submission is to realign the safety case report in line with operational experience and the aggregate effect of the
numerous minor changes since ‘first submission’. The periodicity of review should be based on the rate of change
and/or ‘risk category’.
Irrespective of ‘periodic review’, assessment should take place whenever a change is sufficiently significant to
warrant regulator involvement. The need for regulatory assessment and certification as part of the ‘change
control’ process will be determined by the ‘risk category’ for the change.
For Platforms these aspects are reflected in NAR Chapter 8 and NAN 09/2005, which require SESC reports to be
submitted to NA EXP for assessment in accordance with the PDH’s agreed CSE certification plan. ‘Periodic
review’ aligns broadly with the intervals between non-fleet upkeep periods, when the vessel is de-ammunitioned
and the CSE is removed.
For Naval Bases, intervals between ‘periodic review’ of the NBSSC(WIH) report shall be no more than five
years, commensurate with the likely rate of change in the environs.
14
In practice, the SESC will cover all lifecycle phases, not merely the WIH aspects. However, in order to produce the
WHFS, the safety case needs to deal explicitly with the WIH risk. It is proposed that the WIH aspects form a discrete annex
of the SESC.
15
In practice, this includes stage gate submissions as projects progress through the CADMID cycle. However, only the later
‘operational’ stages will have any bearing on WIH, i.e. when OME is introduced to the platform.
CHAPTER 4 – REGULATOR’S AUDIT OF DUTY HOLDERS
Duty Holders will be expected to operate and manage risk in accordance with their safety cases. The Regulator
will audit Duty Holders in order to seek assurance that:
• their safety cases continue to be valid (e.g. change is identified and controlled);
• safety performance, operations and facilities compare favourably against modern standards;
• safety management arrangements are being adhered to and are effective in practice (compliance); and
• that Forward Action Plans (including RRMs) are being implemented.
Hence, as well as providing the basis for certification, the safety case forms the basis for subsequent audit
activity. Understanding the risks and significance of control measures enables the regulator to plan audit activities
and gain assurance in the key risk areas. Based on the findings, overall audit outcomes will range from:
• supportive of the existing certificates, or
• lead to items being added to the Duty Holder’s Forward Action Plan,
• lead to additional Conditions and Mandatory Requirements to be imposed via certificates, or
• in extremis lead to suspension / withdrawal of a certificate, i.e. removal of Duty Holder’s authority to
conduct certain activities.
4.1 Site Safety Management Arrangements
While not an exhaustive list, the regulator’s expectations of the system a Naval Base should have in place to
manage the WIH risk correctly are presented at Annex C in the form of Authorisation Conditions.16 17
4.2 Warship Safety Management Arrangements
Arrangements for maintaining the material state of each vessel, for which the PDH is responsible, shall be audited
against modern safety standards and the arrangements laid down in the SESC.
As explained in NAR Chapter 8, ship’s staff are audited by FLEET to ensure naval personnel operate in
accordance with the practices laid down in JSP 862. Assurance regarding the competence of the ship’s staff is
sought by NA EXP from FLEET, e.g. as a precursor to certification. Similarly, audits by FOST, HMS
COLLINGWOOD and other organisations provide ongoing assurance on other aspects of safety management on
board warships.
4.3 Audit Frequency
Proactive audit of duty holders’ arrangements shall take place in line with a planned audit programme
administered by NA EXP. The frequency and rigour should be proportionate to the risk associated with the
subject of the audit. Irrespective of the planned programme, audit may also be carried out reactively as dictated by
incidents, concerns and / or other issues that may arise.
4.4 Audit Findings
In the interests of dissemination of safety information and promotion of best practice, NA EXP shall extract
information of common interest from audit findings and communicate them to other stakeholders as appropriate,
e.g. through the NAEAC. Similarly, NAEXP shall analyse the findings of audits, investigations, etc. and report on
general safety performance and trends, e.g. through the Ship Safety Board.
16
Authorisation Conditions are representative of ‘best practice’ in the control of major accident hazards. Hence, their
applicability extends only to the arrangements necessary to manage the explosives risk presented by Warships In Harbour.
Other (lesser) hazards are not required to be managed in this way.
17
The WIH Authorisation Conditions are analogous to those presented in JSP 518 for nuclear hazards. Hence, the various
sets of ACs that may apply at a Naval Base should be complementary, minimising the possibility of ‘duel regulation’.
CHAPTER 5 – IMPLEMENTATION
5.1 Introduction
Whilst the safety management system for controlling explosives risks from WIH is now fully mature, some
elements, in particular those relating to the generation of Platform data, are still being refined hence the re-issue
of this NAN for a further two-year period. In the absence of Ship Explosives Safety Cases, which have yet to be
written for individual vessels, the ship-berth interface process is being conducted using platform event probability
data developed by NA EXP from the Type 23 Pilot Study. This is supplemented by ENEQ data generated on a
Class basis, and is published as a series of “synthetic” Warship Hazard Footprint Statements (WHFS). These and
other implementation issues are discussed further in the WIH Close-Out Report [18].
NA EXP commenced the certification of Naval Bases in summer 2005, and full certification is expected to be
achieved for all UK sites by the end of 2007. The general expectations for remaining within certification are
described under milestone headings in the sections below. Specific commitments to making progress against these
expectations are documented in Duty Holders’ Forward Action Plans, which NA EXP monitor.
5.2 Regulator Stand-Up (June 2005)
At the time of Regulator Stand-Up in June 2005, NBSSC(WIH)s had been produced for Devonport and
Portsmouth.19 These formed the ‘first submission’ of NBSSC(WIH)s and, in the absence of data from Ship
Explosives Safety Cases, were based on conservative assumptions regarding the ENEQs and corresponding
frequencies of explosion events from individual warships, i.e. ‘synthetic’ versions of the Warship Hazard
Footprint Statements (WHFSs). Compliance Statements against the Authorisation Conditions identified areas for
further development in safety management arrangements at each Naval Base. These were recorded on the
Forward Action Plan (FAP) accompanying each NBSSC(WIH), along with other areas of the safety case which
NA EXP review concluded required verification / substantiation.
Subsequently, a greater understanding has been developed of the influence that individual factors have on levels
of WIH risk, resulting in a refinement of the WIH process. The Devonport and Portsmouth NBSSC(WIH)s have
been updated and further safety cases produced for Marchwood and Clyde incorporating the lessons learned in the
intervening period. At the same time, the Naval Bases have implemented the processes and procedures needed to
manage WIH activities, and taken full ownership of their NBSSC(WIH). Certification has been issued by NA
EXP, initially with Interim status but more recently as Full Certificates of Safety Explosive for Naval Bases
(CSENB).
The changes that have been introduced do not alter the fundamental format of the NBSSC(WIH), which continue
to contain the following key elements:20
1. HEASs for berths, building on hazard identification (HAZID) data produced by NBDHs.21 These will then be
passed to Platform Duty Holders, thereby enabling development of the WIH aspects of SESCs.
2. Analysis of the consequences arising from explosions of vessels at each of the corresponding approved
berths. This includes an understanding of the population exposed to the risk with data presented in an
appropriate format, e.g. building registers.
3. Derivation of the F-N curve for each berth, taking into account the baseline occupancy data, e.g. fraction of
time each berth is occupied by specified vessels.
18
Warships In Harbour Close-Out Report, DPA/STG/28/13/16. Part of the overall WIH document suite, available from
http://y4.dpa.r.mil.uk/kb/Organisati/SGs/STG/List-of-Services1/Warships-in-Harbour/index.htm
19
Clyde will be issued an Interim CSENB that is conditional on the respective NBSSC(WIH) being submitted for a Full
CSENB within a few months of stand-up.
20
The majority of work on the NBSSC(WIH)s is being facilitated by WIHSGL on behalf of the NBDHs.
21
It is currently assumed that data are readily available to identify and quantify harbour threats to the satisfaction of GHE
requirements. However, if this assumption is not valid then hazard identification studies may be needed in order for the
HEASs to be completed.
4. Assessment of individual and societal risks and comparison against WIH tolerability criteria [22]. This
includes identification and consideration of Risk Reduction Measures in accordance with the ALARP
principle.
5. Forward Action Plans, detailing commitments to improving safety and/or the NBSSC(WIH).
As the NBSSC(WIH)s are based on synthetic WHFSs and therefore represent a pessimistic assessment of risk,
commitments regarding RRMs on the FAP were initially ‘soft’. The option remains to incorporate more refined
(and lower) values of risk when such information becomes available, e.g. ‘real’ SESC outputs.
Each NBSSC(WIH) has been assessed against this background of expectation. For all submissions that have been
found to be sufficiently robust, NA EXP have issued a certificate to the Naval Base. Initial certificates have been
Interim in status, issued subject to making adequate progress against the FAP and any other caveats / limitations
that NA EXP deemed appropriate.
5.3 Ship Explosives Safety Case Development
As described in NAN 09/2005, Ship Explosives Safety Cases have progressed from a prescriptive basis to risk-
based safety arguments. The timescales for SESC submissions are specified in CSE Certification Plans. At the
same time, it was expected that Platform Duty Holders would become responsible for developing WIH aspects of
the next evolution of SESCs in accordance with the WIH Methodology [23]. In reality, the data derived by NA
EXP and published in the synthetic WHFS continues to be used as sensitivity analysis has shown it to be fit for
purpose as long as the ENEQ values are maintained. The aspiration to achieve greater PDH involvement remains,
and new-build vessels are taking a more active role in the generation of WHFS data. Whilst the PDH role
continues to develop, NA EXP’s expectation remains for Platform Duty Holders to:
1. utilise HEASs in the development of their SESCs as specified in the GHE, i.e. integration compliance
statements should be produced for each vessel that cover all berths that it is expected to visit.
2. develop WIH aspects of the SESC in the bowtie / LOD format, e.g. as a stand-alone addendum to the SESC.
This will include production of the Warship Hazard Footprint Statement (WHFS) in accordance with the
WIH Consequence Protocol.
As updated HEAS and WHFS are produced by the Platform Duty Holders, each Naval Base Duty Holder reviews
the corresponding assumptions in the NBSSC(WIH) against the new, definitive data and acts appropriately, e.g.
modifies the NBSSC(WIH). The updated PIPT-produced data is anticipated to be no more pessimistic than the
initial data, but if this is not the case then the difference should investigated by the respective Duty Holders. As
required, NA EXP should be notified and will facilitate the process of convergence.
NA EXP will continue to audit Naval Base Duty Holders and seek reassurance that they are managing safety and
their NBSSC(WIH)s in accordance with these expectations.
5.4 Audit and Periodic Review
Having achieved the development and issue of a full set of NBSSC(WIH)s and SESCs, NA EXP continue to
monitor Duty Holder activities to ensure that change is managed in a controlled manner. NAEXP actively seek
evidence that shows systems and activities are reflected in the corresponding safety cases, that safety is managed
accordingly, and that reasonable progress is being made against the items identified in FAPs. These will be key
aspects of the continuous audit activity, backed up by periodic review of the safety cases, i.e. update and re-
submission of safety case reports by Duty Holders, with assessment and re-certification by NA EXP.
5.5 Implementation - Summary
22
Section 3 of Warships In Harbour Methodology Suite, DPA/STG/28/13/16. Part of the overall WIH document suite,
available from http://y4.dpa.r.mil.uk/kb/Organisati/SGs/STG/List-of-Services1/Warships-in-Harbour/index.htm.
23
Section 2 of Warships In Harbour Methodology Suite, DPA/STG/28/13/16. Part of the overall WIH document suite,
available from http://y4.dpa.r.mil.uk/kb/Organisati/SGs/STG/List-of-Services1/Warships-in-Harbour/index.htm.
The expectations for the basis of WIH-related certification by NA EXP and how these will develop in time are
summarised in Table 1.
Table 1: Implementation of WIH
Aspect Output Stand-Up SESC Development Audit and Periodic Review

(June 05)
Characterisation of shore-side threats HEAS Berth aspects only Integration compliance Fully configured. Change managed
and assessment of warship withstand statements through NBSSC(WIH)s & SESCs.
Magnitude of explosion effects and WHFS ‘Synthetic’ (pessimistic WHFS for each vessel Change managed through SESC
associated event frequency assumptions)
Site safety management system ACCS Some gaps identified on N/A Arrangements to be implemented iaw
FAP FAP
Identification of risk reduction RRMs Candidates, subject to Greater objectivity in Whole picture of risk – strategic RRMs
measures and consideration iaw the SESC data. decision making & holistic view (OME/warship/NB)
ALARP principle
Management of forward actions arising FAP ‘Soft’, expressed in form Firmer – based on Demonstrate progress & commitment
from safety case of ‘Consider…’ definitive data
Safety
Cases
Maturity of NBSSC(WIH) for each NBSSC Based on synthetic Updated in line with real Change managed & communicated
Naval Base (WIH) WHFSs WHFSs through HEAS. Configured with SESCs
via WHFSs
Maturity of Ship Explosives Safety SESC None available Based on berth HEASs. Change managed & communicated
Case for each vessel WIH addendum produced through WHFS. Configured with
iaw methodology NBSSC(WIH)s via HEAS.
handbook.
Intentionally blank
N AV A L A U T H O R I T Y N O T I C E N AN 1 0 / 2 0 0 5
ANNEX A: Certificate of Safety Explosives for Naval Bases (CSENB)
NAVAL AUTHORITY EXPLOSIVES
CERTIFICATE OF SAFETY - EXPLOSIVES –

FOR NAVAL BASES (CSENB)
Issued under the provisions of Naval Authority Regulations
Name of Naval Base HMNB

Certificate Type Full / Interim
Certificate Number **** (NB Code) / ** (Issue No.)
Date Dd/mm/yyyy
THIS IS TO CERTIFY
1. That Naval Authority Explosives is satisfied with the CSENB submission and NBSSC(WIH) Report for
SOMEWHERE Naval Base, and the arrangements for the safe berthing of Warships In Harbour listed in the
Authorised Berthing Matrix attached. This certificate assures that the risks from explosives posed by warships
to personnel and members of the public are considered to be ALARP and that the residual risks are tolerable.
2. This certificate will expire on dd/mm/yyyy (Interim CSENBs Only) or Upon full de-commissioning of
Naval Base.
3. This CSENB is invalidated if:

A change occurs to the harbour environment which affects Explosives Safety for WIH.
Conditions and Mandatory Requirements of Certification are not addressed fully by the due date.
4. This CSENB supercedes CSENB xxxx/xx dated dd/mm/yyyy
Signed
delegated Naval Authority
Enclosures:
Annex A - Conditions and Mandatory Requirements of Certification.

Annex B - The Authorised Berthing Matrix
N AV A L A U T H O R I T Y N O T I C E N AN 1 0 / 2 0 0 5
ANNEX A: Certificate of Safety Explosives for Naval Bases (CSENB)
ANNEX A TO
CSE ****/1
DATED dd/mm/yyyy

CERTIFICATE OF SAFETY - EXPLOSIVES – FOR NAVAL BASES (CSENB)
HMS NONSUCH
CONDITIONS AND MANDATORY

REQUIREMENTS OF CERTIFICATION
ISSUE X, dated dd/mm/yyyy
Section 1 General
1. The Naval Base is certified as compliant with Naval Authority Regulations subject to the Naval Base
being operated and maintained in accordance with the WIH Authorisation Conditions and other safety
management requirements, as defined by the NBSSC(WIH).
2. The NBDH is responsible for the validity of the Certificate and the overall safety of the Naval Base and
its material state.
3. The certificate is issued subject to the following Conditions and Mandatory Requirements, and its
validity will lapse if any of these are not maintained.
Section 2 Specific Conditions and Mandatory Requirements
[To be included here as appropriate]

ANNEX B TO
CSE ****/1
DATED dd/mm/yyyy

CERTIFICATE OF SAFETY - EXPLOSIVES – FOR NAVAL BASES (CSENB)
HMS NONSUCH
AUTHORISED BERTHING MATRIX

ISSUE X, dated dd/mm/yyyy
Berth Class / Vessel

Type xx Type yy Type zz HMS A1 HMS A2 BB Class
Wharf a
Wharf b
Wharf c
Berth x
Berth y
Berth z
[Fields to be populated with category of berth for specified class / vessel, as deduced from NBSSC(WIH).]
Supplementary Notes to Berthing Matrix
[To be included here as appropriate]

ANNEX B – INTERFACES THROUGHOUT THE LIFECYCLE OF A CONVENTIONAL NAVAL EXPLOSIVE
REGULATIONS
JSP 482 / 445 JSP 430 JSP 430 JSP 482 JSP 430 / JSP 862 JSP 482 / 445
REGULATOR
IE (DE&S) NA EXP NA EXP IE (DE&S) NA EXP IE (DE&S)
DUTY HOLDER
DSDA NBC NBC NBC PDH NBC
(Platform Duty Holder)
NAEAC
ADVISORY ADVISORY ADVISORY ADVISORY ADVISORY ADVISORY
DMC
or
NAVAL
DMC
BASE
1 2 3 4 5 6 7
OVERALL ACTIVITY - STORAGE AND HANDLING AT DSDA LICENSED
SITE
1
ACTIVITY DUTY OF CARE REGULATOR
HOLDER
OVERALL ACTIVITY DSDA Lead - IE (DE&S)
JSP 482
JSP 445
• Material state of DSDA IE (DE&S)
transport/ lifting JSP 482
equipment. JSP 445
JSP 467
• SSOW DSDA IE (DE&S) -
ASHE / SHIM Certification
• Site/Berth License DSDA IE (DE&S)
JSP 482
• Load / Unload DSDA IE (DE&S)
stores to or from JSP 482
NAL JSP 445
OVERALL ACTIVITY - MUNITION TRANSIT

2
HOLDER
OVERALL ACTIVITY NBC (Site Safety Case) Lead - IE (DE&S)
JSP 482
• NAL/TUG/Floating Platform Duty Holder NA EXP
Crane material state (MSIBT) JSP 430
/ certification JSP 467
(including SSOW and
emergency procedures)
• Custody DSDA Lead IE (DE&S)
JSP 445
OVERALL ACTIVITY - MUNITION TRANSIT - MOORING AT BUOY

3
HOLDER
JSP 482
• NAL/TUG Platform Duty Holder NA EXP
movement and (MSIBT) JSP 430
mooring
• Site/Berth License NBC (Site Safety Case) IE (DE&S)
(includes EHJ and JSP 482
buoy)
• Custody DSDA Lead IE (DE&S)
JSP 445
OVERALL ACTIVITY - AMMUNITIONING AT BUOY/UHAF/REMOTE
4 AMMUNITION FACILITY
HOLDER
JSP 482
• Site/Berth License NBC (Site Safety Case) IE (DE&S)

(includes EHJ and JSP 482
buoy)
• DM procedures / DM IE (DE&S) -
SSOW JSP 482
• NAL/TUG/Floating Platform Duty Holder NA EXP
Crane material state (MSIBT) JSP 430
/ certification JSP 467
(including SSOW and
emergency procedures)
• Facility (eg UHAF) / NBC IE (DE&S)
Fixed Crane JSP 467
material state /
certification
• HM WARSHIP / PDH NA EXP
RFA munitions (Ship Explosive Safety JSP 430
movement onboard Case) SSOW BR 862 Vols 1 & 2
/ striking down. IMDG
OVERALL ACTIVITY - RISKS FROM MUNITIONS IN QUIESCENT STATE

5 STOWED IN WARSHIPS ALONGSIDE
HOLDER
OVERALL ACTIVITY NBC (Naval Base Site Lead
Safety Case for Prior to June 05 - IE (DE&S)
Warships In Harbour) JSP 482
From June 05 - NA EXP

JSP 430
CSE (NB)
• Platform Safety PDH NA EXP
aspects (Ship Explosive Safety JSP 430
Case)
SSOW in BR 862
OVERALL ACTIVITY - AMMUNITIONING ALONGSIDE (SMALL QUANTITY TOP-
6 UP)
ACTIVITY DUTY OF CARE HOLDER REGULATOR
OVERALL ACTIVITY NBC Site Safety Case Lead - IE (DE&S)
JSP 482
JSP 445
• Platform Safety PDH NA EXP

aspects (Ship Explosive Safety JSP 430
Case)
SSOW in BR 862
OVERALL ACTIVITY - AMMUNITIONING BY CRANE ALONGSIDE

7
HOLDER
OVERALL ACTIVITY DSDA Lead - IE (DE&S)
JSP 482
JSP 445
Material state of DSDA - DMC IE (DE&S) - Crane certification

transport / lifting NBC - Naval Base JSP 482
equipment JSP 445
JSP 467
Munitions transfer DSDA IE (DE&S)
JSP 482
SSOW DSDA IE (DE&S)
ASHE /SHIM Certification
Note – The above model is intended to offer clarification of regulatory and duty holder responsibilities.
It has been tabled at the NAEAC Naval Base and Harbours Subcommittee24 and illustrates the broader
system within which explosives safety issues associated with Warships In Harbour are managed and
regulated.
24
Minutes of the Inaugural Naval Authority Explosives Advisory Committee Naval Bases and Harbours, Abbey
Wood, 15 February 2005. STG/28/2/3.
ANNEX C – NAVAL BASE AUTHORISATION CONDITIONS
The explosives risks associated with Warships In Harbour are such that a rigorous and robust regulatory regime is required to control the hazards. MOD sites
operate to safety management systems that are proportionate to the attendant risks. In deriving a regulatory regime that is suitable and sufficient for regulating
WIH risks, authorisation conditions (AC)25 that are applied to sites engaged in the Naval Nuclear Propulsion Programme (NNPP)26 have been reviewed for
applicability to Naval Bases (NB) in the WIH context.27
The following table specifies each AC in detail, with shading applied to identify ACs that are not applicable. Alongside each AC is a statement of the
requirement, with guidance on the aims, scope and regulator’s expectations regarding compliance. This is provided to help Naval Bases in preparing
Compliance Statements for inclusion in their NBSSC(WIH)s. As part of the Regulator’s assurance function, NA EXP will then review the Compliance
Statements and their effectiveness in practice.
The guidance is also intended to assist Naval Bases in the development of safety management arrangements in circumstances where they require development
in order to meet these expectations.
AC Description (WIH Requirement28 Compliance

Context)
1 Interpretation (1) In the Conditions set out in this Schedule, N/A
unless the context otherwise requires, the
following expressions have the meanings hereby
respectively assigned to them, that is to say:
"commissioning" means the process during
which plant components and systems, having
been constructed or modified, are made
operational and verified to be in accordance with
design assumptions and to have met the
appropriate safety criteria;
"Naval Authority (Explosives)" is the Regulator
for explosives risks for WIH and applies its
authority through a certification process;
"experiment" means any test or non-routine
25
Authorisation Conditions are representative of ‘best practice’ in the control of major accident hazards. Hence, their applicability extends only to the arrangements necessary
to manage the explosives risk presented by Warships In Harbour. Other (lesser) hazards are not required to be managed in this way.
26
JSP 518
27
The WIH Authorisation Conditions are analogous to those presented in JSP 518 for nuclear hazards. Hence, the various sets of ACs that may apply at a Naval Base should
be complementary, minimising the possibility of ‘duel regulation’.
28
Compliance with all MoD Authorisation Conditions is mandatory. To aid interpretation, the following highlighting emphasises certain elements of those
Conditions: Bold: emphasises the purposes or actions which must be demonstrated to have been done to satisfy that particular Condition. Italic: emphasises
references to regulatory controls, in particular, controls which are repeated within several Conditions.
Context)
activity other than an activity carried out
pursuant to Conditions 21 and 28;
"installation" or “site” means a Naval Base,
facility or plant therein that conducts explosives
safety implicated activities on or in support of
warships in harbour;
“Duty Holder” is the responsible person within
the Naval Base (or Platform IPT) for ensuring
that activities comply with NA EXP
Regulations. This is the authorisee to whom the
NA EXP certificates are issued.
“Naval Base” means that area within the Naval
Base boundary, including the designated sea
area, which comprises the certified site to which
the CSENB applies;
“warship” means a JSP 430 ship (includes
surface ships and submarines) that is required to
have a NA EXP certificate in order to carry
explosives. Terms that include “Ship” (for
example, in Ship Explosives Safety Case) shall
be similarly construed.
"modification" means any alteration to
buildings, plant, operations, processes or safety
cases and includes any replacement,
refurbishment or repairs to existing buildings,
plants or processes and alterations to the design
of plants during the period of construction;
"operations" includes maintenance, examination,
testing and operation of the site, the passage,
movement and berthing of vessels and
"operating" and "operational" shall be construed
accordingly;
"safety" refers to the safety of persons whether
on or off the site and is strictly limited to aspects
of conventional explosives safety associated
with Warships In Harbour (WIH);
Context)
"safety case" means the document or documents
produced by Duty Holders in accordance with
Condition 14 of this Schedule;
"consent". A consent is required before a Duty
Holder can carry out any activity for which NA
EXP has so specified the need;
"approval". A Duty Holder is required to submit
its arrangements for approval if so specified by
NA EXP;
"direction". A direction requires a Duty Holder
to take a particular action;
"agreement". An agreement allows a Duty
Holder to proceed in accordance with its own
arrangements;
"notification". When so notified, a Duty Holder
is required to submit information to NA EXP;
"specification". As specified by NA EXP, a
Duty Holder is required to implement the
specified arrangements;
(2) In these Conditions except where the context
otherwise requires:
(a) any reference to the singular shall include the
plural and vice versa and any reference to the
masculine shall include the feminine;
(b) any reference to any arrangement,
agreement, approval, consent, direction,
specification, notification or any formal
communication between NA EXP and the Duty
Holder (and vice versa) shall be deemed to be a
reference to a written document;
(c) any reference to a numbered Condition is a
reference to the Condition so numbered in this
Schedule.
(3) Where in these Conditions NA EXP requires
any matter to be approved or to be carried out
only with its consent or to be carried out as it
Context)
directs, NA EXP may:
(a) from time to time modify, revise or withdraw
either wholly or in part any such approval,
direction or consent;
(b) approve either wholly or in part any
modification or revision or any proposed
modification or revision to any matter for the
time being approved.
2 Marking of the N/A – no requirement over and above existing N/A
site boundary arrangements, e.g. security, control of
explosives.
3 Restrictions on N/A – no requirement over and above existing N/A
dealing with the arrangements
site
4 Restrictions on N/A – no requirement over and above existing N/A
explosive matter arrangements
on the site
4a Berth approval (1) Without prejudice to any other requirements INTRODUCTION
of the Conditions attached to this Authorisation, 1. The purpose of this Condition is to ensure that an adequate safety case
the Duty Holder shall ensure that only berths exists for berths to be used for warships in harbour and has been approved.
approved by NA EXP are used for berthing SCOPE
JSP 430 ships. 2. This advice relates to the arrangements for gaining and maintaining
(2) Before a berth can be used, the Duty Holder approval for the location of a berth to be used for JSP 430 ships. It is
shall satisfy NA EXP that the characteristics applicable to the geographical suitability of a berth for specified warships, as
and location of the site is acceptable for defined in the berthing matrix within the NA EXP approved safety case (see
specific operations. also AC14).
(3) The Duty Holder shall ensure that a safety KEY POINTS FOR COMPLIANCE
case demonstrating the adequacy of the site is 3. The Duty Holder should produce a statement which:
approved by NA EXP. The case shall include a. identifies the person responsible for the berthing matrix,
navigational arrangements, population b. describes the arrangements for demonstrating the adequacy of the berth
distribution, and societal consequences of an with regard to navigational arrangements,
accidental explosion. c. describes the arrangements to ensure that operations remain within the
(8) The Duty Holder shall ensure that no scope of permitted activities (see also AC23).
unapproved berth is used by a JSP 430 ship. GUIDANCE
(9) The Duty Holder shall ensure that adequate 4. The justification for the activities which are to be conducted at each berth
arrangements are in place to ensure that should be covered by a safety case, using the Harbour Environment
Context)
operations comply with the berthing matrix in Assessment Statements29 (HEAS) as a significant part of the process.
the safety case. 5. Berth Assessment is the process of identifying, recording and submitting
key data for the berth which makes it possible to compare the berth with the
GHE and determine the acceptability through the NBSSC(WIH) (see AC14).
Every berth should have an associated HEAS, which is reviewed periodically.
6. For berths that are covered by a safety case, the HEAS may be integrated
within the safety case. However, all the data that is recorded in the HEAS
should still be provided in a form which enables it to be easily accessed,
compared with other berths and used as source data for emergency
arrangement purposes.
5 Consignment of N/A – no requirement over and above existing N/A
explosive matter arrangements
6 Documents, N/A – no requirement over and above existing N/A
records, arrangements
authorities and
certificates
7 Incidents on the (1) The Duty Holder shall make and implement INTRODUCTION
site adequate arrangements for the notification, 1. The purpose of this Condition is to define the arrangements for ensuring
recording, investigation and reporting of such that incidents and unusual events with explosive safety implications are
incidents occurring on the site: reported, investigated, reviewed and assessed by the Duty Holder and brought
(a) as is required by any other Condition to the attention of NA EXP when necessary.
attached to this Authorisation; SCOPE
(b) as NA EXP may specify; and 2. This advice relates to all incidents having safety significance for explosives
(c) as the Duty Holder considers necessary. on Warships In Harbour.
(2) The Duty Holder shall submit to NA EXP for 3. AC9 deals with action to be taken immediately following an incident.
approval such part or parts of the aforesaid KEY POINTS FOR COMPLIANCE
arrangements as NA EXP may specify. 4. Identify the responsible person. Outline of the responsibilities of all
(3) The Duty Holder shall ensure that once personnel relating to incident reporting, defining all interfaces and
approved no alteration or amendment is made to boundaries.
the approved arrangements unless NA EXP has 5. A description of the arrangements for reporting, investigating, reviewing
approved such alteration or amendment. and assessing incidents, including unusual events currently described as
occurrences or anomalies and deviations and ‘near misses’ which could lead
to an incident through technical or human failure.
6. A description of the arrangements for:
29
The HEAS is derived through correct application of the Generic Harbour Environment (GHE)
Context)
(i) appointing personnel to implement and supervise the arrangements,
(ii) classifying incidents, occurrences and deviations,
(iii) ensuring staff awareness of the need for reporting,
(iv) specifying the appropriate level of investigation,
(v) referring the reports to the appropriate Safety Committee or where
specified to NA EXP,
(vi) implementing recommendations,
(vii) analysing similar incidents occurring elsewhere and applying lessons
learned,
(viii) control and storage of documentation recording incidents and unusual
events.
Assessment and Reporting of Incidents
7. NA EXP considers that the reporting and assessment of incidents is an
essential aspect of the MOD Regulatory surveillance. A responsible and open
approach to incidents is required with close liaison with NA EXP in the
interests of learning lessons across all Naval Bases and fleet.
8 Warning notices N/A – no requirement over and above existing N/A
arrangements on warship
9 Instructions to The Duty Holder shall ensure that every person INTRODUCTION
persons on the authorised to be on the site receives adequate 1. The purpose of this Condition is to define the arrangements for ensuring
site instructions (to the extent that this is necessary that every person authorised to be on a Naval Base receives adequate
having regard to the circumstances of that information on safety arrangements.
person being on the site) as regards the risks SCOPE
and hazards associated with explosives on 2. This advice relates to the provision of information to employees, attached
warships, the precautions to be observed in staff, contractors and visitors who are authorised to enter the NA EXP
connection therewith and the action to be taken Certified Site for any purpose. The information provided to any person will
in the event of an accident or emergency on be selected to be appropriate and adequate for the circumstances under which
the site. the person is authorised to be present within the site.
KEY POINTS FOR COMPLIANCE
4. a. Identify the responsible person. Outline the responsibilities of all
personnel relating to the provision of instructions to persons authorised to be
within a NA EXP certified site, defining all interfaces and boundaries.
b. Describe the arrangements for authorising persons to be on an Authorised
Site or facility.
c. Describe the arrangements for ensuring that all staff are formally made
aware of the hazards and the emergency arrangements.
Context)
d. Describe the arrangements for ensuring that all staff are instructed on such
topics as fire and bomb/terrorist alerts and that the training provided is to a
level appropriate to the reason for the person being within a NA EXP
Certified Site.
e. Describe the arrangements for ensuring that contractors and visitors to a
site and ships’ staff (both UK and foreign) visiting a site are adequately
instructed on the hazards and emergency arrangements which apply to them.
f. Describe the arrangements for ensuring that records of staff training are
kept.
g. Describe the arrangements for special operations (such events as test and
trials, Navy Days or first use of procedures) which may affect the personnel
and which require a response different from the standard emergency
response.
10 Training (1) The Duty Holder shall make and implement INTRODUCTION
adequate arrangements for suitable training 1. The purpose of this Condition is to define the arrangements for ensuring
of all those on site who have responsibility for that persons associated with the Naval Base, who have responsibility for any
any operations which may affect explosives operations which may affect safety, receive suitable formal and practical
safety of Warships In Harbour. training.
(2) The Duty Holder shall submit to NA EXP for SCOPE
approval such part or parts of the aforesaid 2. This advice applies to the training requirements for persons with specific
arrangements as NA EXP may specify. safety responsibilities relating to warships, services and utilities within the
(3) The Duty Holder shall ensure that once Naval Base, including non-explosives safety where this may nevertheless
approved no alteration or amendment is made to have implications for explosives safety, e.g. operation of cranes. These
the approved arrangements unless NA EXP has persons include, among others, Duly Authorised Persons (DAP) and Suitably
approved such alteration or amendment. Qualified and Experienced Persons (SQEP). They also include those persons
with emergency responsibilities, and persons with special responsibilities for
ensuring the minimisation of WIH risk, e.g. berthing personnel.
3. Training in respect of persons having duties under the Emergency
Arrangements required by AC11 is covered by that Condition rather than
AC10.
4. AC9 covers the arrangements which ensure that all staff, contractors and
visitors receive adequate information on safety arrangements.
5. a. Identify the responsible person. Outline the responsibilities of all
personnel relating to the provision of safety training, defining all interfaces
and boundaries.
Context)
b. Describe the arrangements which ensure that a training plan is kept which
relates the qualifications required to undertake duties with the specific posts.
c. Describe how the training plan is approved by the Duty Holder and
submitted to NA EXP.
d. Describe the arrangements which ensure that records are kept in a training
register to show that current post holders have the required qualifications or
that waivers have been granted.
e. Describe the procedure for granting waivers, stating by whom they are
granted (covered also in AC12).
f. Describe the arrangements for ensuring a continuing programme of formal
and practical training, including anticipating any new training needs and
periodic refresher training.
g. Describe the arrangements which ensure that records are kept of local
training for specific tasks, showing the content of such courses and attendees.
h. Describe the arrangements for specifying, managing, recording and
reviewing on the job training.
i. Describe the arrangements for gaining assurance that subsidiary
organisations and contractors have adequate arrangements which satisfy
AC10.
j. Describe the arrangements for:
(i) establishing and specifying the training need,
(ii) planning and providing the training,
(iii) agreeing the training solution (ie courses, provider and media) for each
post,
(iv) accepting training courses against the training requirement,
(v) reviewing the effectiveness of training (both routinely and periodically).
GUIDANCE
Post Profiling
6. Where personnel have more than one role, for instance their main post and
also a role in responding to emergencies, then the training needs of both roles
should be considered jointly.
7. The process of assessing posts’ training requirements should consider the
demands of any relevant safety case and the performance, skill or knowledge
of post holders which the safety case assumes.
Competences
8. The system adopted by Duty Holders should be based on ‘competences’ or
Context)
if the Duty Holder has not yet adopted such a system clear evidence should
be provided that this is a system which is being worked towards.
Contractors and Subsidiary Organisations
9. Where additional resources within a Duty Holder’s organisation are
provided by contractors (for instance as secondees), then these staff should be
treated as if they were employed by the Duty Holder for the purposes of
AC10.
Training Courses Provision and Acceptance
10. Training providers should maintain adequate records of the courses and
their objectives and in particular should record how each course has been
accepted and what its review programme is.
11. The arrangements should not only apply to formal training courses, but
should also address the control of on the job training which forms an essential
part of the generation of competent SQEP.
12. The assessment of the performance of post holders should form part of the
process for ensuring that both the training requirement has been correctly
specified and also that the courses attended are delivering the required training.
11 Emergency (1) Without prejudice to any other requirements INTRODUCTION
arrangements of the Conditions attached to this Authorisation 1. The purpose of this Condition is to define the arrangements for ensuring an
the Duty Holder shall make and implement effective response to any accident or emergency within the NA EXP Certified
adequate arrangements for dealing with any Site.
accident or emergency arising on the site and SCOPE
their effects. 2. This advice relates to the arrangements for dealing with any accident or
(2) The Duty Holder shall submit to NA EXP for emergency arising on, or in the vicinity of, a warship which has implications
approval such part or parts of the aforesaid for explosives safety. This includes situations where no actual hazard exists
arrangements as NA EXP may specify. but where the potential for a hazard to arise is identified.
(3) The Duty Holder shall ensure that once 3. Associated ACs are:
approved no alteration or amendment is made to a. the arrangements for the notification, recording, investigation and reporting
the approved arrangements unless NA EXP has of incidents are considered under AC 7,
approved such alteration or amendment. b. the arrangements for training personnel are covered by AC10.
(4) Where any such arrangements require the KEY POINTS FOR COMPLIANCE
assistance or co-operation of, or render it 4. Key points for compliance include:
necessary or expedient to make use of the a. Identify the person responsible for emergency response planning. Outline
services of any person, local authority or other his responsibilities, defining all interfaces and boundaries.
body the Duty Holder shall ensure that each b. Describe the arrangements for drawing up the risk and hazard assessment
person, local authority or other body is that the emergency arrangements are required to address, and for reviewing
Context)
consulted in the making of such this. Identify the key conclusions of the risk and hazard assessment.
arrangements. c. Describe the arrangements for drawing up the Operating Organisation’s
(5) The Duty Holder shall ensure that such emergency plan on the basis of the risk and hazard assessment.
arrangements are rehearsed at such intervals d. Describe the arrangements for ensuring that any employee who has duties
and at such times and to such extent as NA EXP in relation to the emergency arrangements is provided with the necessary
may specify or, where NA EXP has not so instruction, training, equipment etc.
specified, as the Duty Holder considers e Describe the arrangements for ensuring that all persons on the site who may
necessary. be affected by the emergency are provided with the necessary instruction,
(6) The Duty Holder shall ensure that such training, equipment etc.
arrangements include procedures to ensure that f. Describe the arrangements for ensuring that any external agency with a part
all persons in his employ who have duties in to play in the emergency arrangements (e.g. the emergency services) is
connection with such arrangements are appropriately consulted and provided with all necessary information.
properly instructed in the performance of the g. Describe the arrangements for providing necessary information to the local
same, in the use of the equipment required authority to enable it to prepare an off site plan. Identify the key aspects of
and the precautions to be observed in the information provided.
connection therewith. h. Describe the arrangements for providing prior information to the local
community.
i. Identify the key aspects of the emergency arrangements (including the
provision of support to the off site plan) and, in each case, the response
capability or performance standard that the arrangements are intended to
achieve.
j. Describe the arrangements for assessing the adequacy of the emergency
arrangements and for ensuring that each aspect of the emergency
arrangements (including the interfaces with external agencies) is exercised at
appropriate intervals.
k. Describe how the emergency arrangements and any amendments thereto
are approved.
12 Duly authorised (1) The Duty Holder shall make and implement INTRODUCTION
and suitably adequate arrangements to ensure that only 1. The purpose of this Condition is to ensure that only Suitably Qualified and
qualified and suitably qualified and experienced persons Experienced Persons (SQEP) perform duties which may affect the explosives
experienced perform any duties which may affect persons safety of Warships In Harbour.
persons performing any duties which may affect the SCOPE
safety of operations on the site or any duties 2. This advice relates to all warships, services and utilities within the NA
assigned by or under these Conditions or any EXP Certified Site.
arrangements required under these Conditions. KEY POINTS FOR COMPLIANCE
Context)
(2) The aforesaid arrangements shall also 3. a. Describe the system in place for post profiling, to define the required
provide for the appointment, in appropriate qualification and experience of the individuals who are to fill each safety
cases, of duly authorised persons to control related post with an affect on WIH risk.
and supervise operations which may affect b. Describe the method of defining the classification of each post and the
plant safety. arrangements which apply for control of each classification.
(3) The Duty Holder shall submit to NA EXP for c. Describe the arrangements which ensure that:
approval such part or parts of the aforesaid (i) only Suitably Qualified and Experienced Persons should carry out the
arrangements as NA EXP may specify. duties of posts which may affect explosives safety of WIH,
(4) The Duty Holder shall ensure that once (ii) only Duly Authorised Persons (DAP) are appointed to posts which
approved no alteration is made to the approved provide specific control and supervision functions significantly affecting
arrangements unless NA EXP has approved explosives safety of WIH.
such alteration or amendment. d. Describe the arrangements for appointing DAPs, including the
(5) The Duty Holder shall ensure that no person circumstances under which they hold authority, what that authority is, how
continues to act as a duly authorised person if, in that authority is transferred/relinquished, and how the DAPs’ authority is
the opinion of NA EXP, he is unfit to act in that made known to other site/warship personnel.
capacity and NA EXP has notified the Duty e. Describe the ‘waiver’ arrangements for appointments, which ensure that:
Holder to that effect. (i) the lack of qualification or experience is formally recorded along with the
considerations (including any supervision by suitably qualified and
experienced personnel) which, nonetheless, permit the appointment,
(ii) all waivers, once granted are controlled, managed and regularly reviewed,
(iii) temporary waivers are only granted pending the acquisition of
appropriate qualifications and subject to suitable supervision arrangements
being identified and implemented,
(iv) an appropriate timescale is set for the duration of the waiver to remain
valid.
f. Describe how the arrangements for appointing and training personnel
ensure that waivers are only necessary in exceptional circumstances and are
not used as a palliative measure to overcome foreseeable and avoidable
shortages of SQEP.
g. Describe the arrangements which ensure that contractors have the proper
level of expertise, are qualified to perform the tasks required, or alternatively
are supervised by SQEP throughout their work.
GUIDANCE
4. AC21, 26, 28 & 36 specifically require the appointment of SQEP.
Competences
5. The system adopted by Duty Holders should be based on ‘competences’ or
Context)
if the Duty Holder has not yet adopted such a system clear evidence should
be provided that this is a system which is being worked towards.
Application to Subsidiary Organisations and Contractors
6. Contractors who may significantly affect explosives safety of WIH (e.g. as Duty
Holders, Design Authority, maintainers, plant operators) should adhere to these
arrangements under the scrutiny of their parent Duty Holder or Duty Holder.
7. Other design and procurement activities are often carried out by external
contractors who are not subject to the controls on qualifications and
experience specified here. Duty Holders should be able to provide assurance
to NA EXP that acceptable controls on appointing persons with appropriate
competence, qualifications and experience are in place in such organisations.
13 Explosive Safety N/A - no intention to create a NSC-type body N/A
Committee with external ‘independent’ membership. NA
EXP certification process should be sufficient.
14 Safety (1) Without prejudice to any other requirements INTRODUCTION
documentation of the Conditions attached to this Authorisation 1. The purpose of this Condition is to define the arrangements for ensuring
the Duty Holder shall make and implement that safety cases consisting of documentation to justify safety during the
adequate arrangements for the production design, construction, modification, commissioning, operation and
and assessment of safety cases consisting of decommissioning phases of any NA EXP Certified Site are produced and
documentation to justify safety during the assessed.
design, construction, manufacture, SCOPE
commissioning, operation and 2. This advice relates to the Safety Documentation for new and existing
decommissioning phases of the installation. facilities which have an affect on explosives safety of WIH. Explicitly this
(2) The Duty Holder shall submit to NA EXP for includes the NBSSC(WIH) and any Warship Hazard Footprint Statement
approval such part or parts of the aforesaid (WHFS), Harbour Environment Assessment Statement (HEAS) or other
arrangements as NA EXP may specify. reference document upon which the safety case is based.
(3) The Duty Holder shall ensure that once KEY POINTS FOR COMPLIANCE
approved no alteration or amendment is made to General
the approved arrangements unless NA EXP has 3. a. Identify the responsible person to oversee the production and approval of
approved such alteration or amendment. the safety documentation.
(4) The Duty Holder shall furnish to NA EXP b. Describe the arrangements to:
copies of any such documentation or any such (i) prepare, peer review and assess safety documentation pertaining to design,
category of documentation as NA EXP may construction, manufacture, commissioning, operation, maintenance and
specify. decommissioning,
(ii) show how safety documentation is categorised in accordance with its
safety significance,
Context)
(iii) have such documentation produced by Suitably Qualified and
Experienced Persons,
(iv) have such documentation checked by Suitably Qualified and
Experienced Persons,
(v) determine whether documentation which have higher categories of safety
significance should be subjected to an Independent Safety Assessor (ISA)
review by Suitably Qualified and Experienced Persons independent of the
groups responsible for the production of the safety case and for operations,
(vi) submit documents to NA EXP together with any relevant Naval Base
Safety Committee comments,
(vii) have the documents approved at the appropriate level and reviewed at
appropriate intervals.
c. Describe the requirements for safety documentation to cover procurement,
commissioning, operation, maintenance, modification and decommissioning
of equipment or systems, and supporting infrastructure if appropriate.
d. State the approval level of the safety documentation.
15 Periodic review (1) The Duty Holder shall make and implement INTRODUCTION
adequate arrangements for the periodic and 1. The purpose of this Condition is to define the arrangements for ensuring that
systematic review and reassessment of safety safety cases consisting of documentation to justify safety during the design,
cases. construction, manufacture, commissioning, operation and decommissioning
(2) The Duty Holder shall submit to NA EXP for phases of any installation are periodically reassessed.
approval such part or parts of the aforesaid SCOPE
arrangements as NA EXP may specify. 2. This advice relates to NBSSC(WIH)s and any Warship Hazard Footprint
(3) The Duty Holder shall ensure that once Statement (WHFS), Harbour Environment Assessment Statement (HEAS) or
approved no alteration or amendment is made to other reference document upon which the safety case is based.
the approved arrangements unless NA EXP has
3. a. Define two types of review: the rolling programme of reviewing and
approved such alteration or amendment.
updating safety cases and Statements of Compliance and the less frequent stand-
(4) The Duty Holder shall, if so directed by NA alone periodic review of the Safety Justification.
EXP, carry out a review and reassessment of b. Describe the arrangements for reviewing safety justifications in any situation
safety and submit a report of such review to NA when any change, planned or unplanned, alters the appreciation of the Safety
EXP at such intervals, within such a period and Case. Guidance should be given for the procedure in the unplanned situation,
for such of the matters or operations as may be especially as to whether operation may continue.
specified in the direction. c. Describe the arrangements for ensuring that results of all reviews are managed
and corrective action taken as appropriate.
d. Describe the arrangements for reviewing the safety justifications for operation
beyond the original justified period or equipment/system design life.
Context)
e. Describe the arrangements for ensuring that a total Site Safety Justification
remains valid and is reviewed at intervals agreed by NA EXP. These intervals are
likely to be five years.
GUIDANCE ON THE CONDUCT OF PERIODIC SAFETY REVIEWS
4. Safety Justifications should demonstrate that the individual risks and societal
risks associated with WIH are kept as low as reasonably practicable and that the
operations compare favourable with modern safety standards.
5. Many factors change over the life of a facility and to ensure that the safety of
assets, operations and their justifications remain adequate, they must be subjected
to a fundamental review, known as a Periodic Safety Review (or Periodic
Review), at regular intervals. The Periodic Safety Review is a comprehensive
assessment against modern standards and recent experience in a military context
to determine whether the risks from plant, facilities or operations continue to be
tolerable and ALARP and that ageing and other time related phenomena will not
render them unsafe before the next review. Where modern standards are not met,
the significance of the shortfalls should be assessed and any reasonably
practicable improvements identified and undertaken. Periodic Safety Reviews are
additional to the normal maintenance and routine review of the safety
justification.
6. If a review reveals a shortfall in the design or in the demonstration of safety,
any reasonably practicable improvements should be considered to bring the
assets towards the safety criteria and standards in force at the time of the review.
The process by which the conclusions are reached should be made visible and, in
particular, the non-adoption of potential improvements should be justified. An
ALARP study can provide a guide to the prioritisation of actions. The
improvements to be made and the implementation programme should be
documented in a Forward Action Plan and agreed with NA EXP.
ADDITIONAL CONSIDERATIONS
7. If at the time of the review a commitment has been made to dispose of or to
decommission the asset within a short period (maximum five years) then this can
be recognised in the PSR and may influence what is considered to be ALARP.
8. If, before the asset is decommissioned or replaced, changed circumstances
mean that the decision on replacement or disposal is reversed, or the
implementation time is delayed, then the asset should be re-assessed for lifetime
extension.
9. Reactive reviews may be required if a significant change occurs in the physical
Context)
condition of an asset or new technical knowledge becomes available that calls
into question the safety of operations. In these circumstances the scope of the
review will depend on the significance of the change or the new information.
Such a review should be carried out against current standards, although
acceptability may be assessed against the standards applicable at build or the last
PSR.
16 Site plans, design (1) The Duty Holder shall submit to NA EXP an INTRODUCTION
and specifications adequate plan of the site (hereinafter referred 1. The purpose of this Condition is to ensure that detailed plans and schedules of
to as the site plan) showing the location of the site buildings, facilities, utilities or plant, registers of building occupants,
boundary of the NA EXP Certified Site and berthing guides and details of the surroundings are provided and kept up to date.
every building or plant on the site which might This aids demonstration of how new developments are covered by existing
affect safety. justifications.
(2) The Duty Holder shall submit to NA EXP SCOPE
with the site plan a schedule giving particulars of 2. This advice relates to all site buildings, facilities, berths, utilities or plant,
each such building and plant thereon and the which are included within the scope of site certification.
operations associated therewith. KEY POINTS FOR COMPLIANCE
(3) If any changes are made on the site which may 3. a. Identify the person responsible for ensuring that each plan or schedule is
affect the said buildings, plant or any operations, maintained up to date and for submitting them to NA EXP when required.
the Duty Holder shall forthwith send an amended b. Describe the duty and boundary of each system, plant, service, utility or
site plan and schedule to NA EXP incorporating facility, and any associated buildings or structures, and state their design life and
these changes. the period of validity of the safety case.
(4) The Duty Holder shall furnish to NA EXP c. Describe the arrangements that verify at suitable periodicity that the plans and
such plans, designs, specifications or other schedules reflect the actual state of the subject of the plan or schedule.
information relating to such buildings, plant and d. Describe the arrangements that ensure operations of the system, plant, service,
operations as NA EXP may specify. or facility are in accordance with approved plans, designs or specifications and
that further approvals are required for any changes.
e. Describe the arrangements that ensure independent surveys of systems, plant,
services or facilities are commissioned (where appropriate) at appropriate
intervals to show fitness for purpose.
f. State the period for which plans, designs and specifications will be retained.
GUIDANCE
4. There should be arrangements to ensure that configuration management is
achieved not just within the site but also between sites and warships. This is
particularly important when:
a. specifying the facilities for berthing or docking warships, where the interface
arrangements are vital to safety,
Context)
b. site test equipment or systems are provided or made available to the warship
for maintenance, trials, emergency cover, etc..
17 Quality assurance N/A – no requirement over and above existing N/A
arrangements
18 Radiological N/A N/A
protection
Context)
19 Construction of (1) Where the Duty Holder proposes to construct INTRODUCTION
new buildings or or install or modify or carry out an experiment 1. The purpose of these Conditions is to define the arrangements for ensuring
introduction of on any plant which may affect explosives safety that all changes (i.e. construction, installation, modification and experiments)
additional of WIH the Duty Holder shall make and to new or existing facilities are adequately controlled, with appropriate
warships implement adequate arrangements to control approval. The process includes commissioning to prove that the changes can
the construction or installation or be implemented successfully, verifying the assumptions made in the design
20 Modification to modification or experiment. and safety cases before consent is granted to continue operation.
design of plant (2) The Duty Holder shall submit to NA EXP for SCOPE
under approval such part or parts of the aforesaid 2. This advice relates to:
construction arrangements as NA EXP may specify. a. the control of construction, installation, modification and experiments
(3) The Duty Holder shall ensure that once carried out on warships, facilities, plant or buildings where there is an affect
21 Commissioning approved no alteration or amendment is made to on explosives safety of WIH.
the approved arrangements unless NA EXP has b. the control of additional warships, whether they be new RN vessels or
22 Modification to approved such alteration or amendment. visiting warships.
existing buildings (4) The aforesaid arrangements shall where KEY POINTS FOR COMPLIANCE
or warships appropriate divide the construction or 3. a. Ensuring that all facilities, plant or buildings are constructed, installed,
installation or modification or experiment modified, tested and/or commissioned safely.
into stages. Where NA EXP so specifies the b. Ensuring that additional warships are introduced safely, based on the best
Duty Holder shall not commence nor information available.
thereafter proceed from one stage to the next c. Arrangements for managing, controlling and supervising the change.
of the construction or installation or d. Describe the system in place to define the required commissioning for each
modification or experiment without the change. This should clearly differentiate between the testing required to
consent of NA EXP. The arrangements shall demonstrate the project’s Design Intent and the overall commissioning
include a requirement for the provision of required to demonstrate correct functioning, fitness for purpose in the total
adequate documentation to justify the safety safety environment.
of the proposed construction or installation or 4. Outline the responsibilities of all personnel relating to the change
modification or experiment and shall where (including commissioning activities), defining all interfaces and boundaries.
appropriate provide for the submission of this 5. Describe the arrangements which ensure that Suitably Qualified and
Documentation to NA EXP. Experienced Persons are involved in the change and the commissioning
(5) The Duty Holder shall, if so directed by NA process.
EXP, halt the construction or installation or 6. Describe the arrangements, which ensure that records of tests and
modification or experiment and the Duty Holder assessment of the results are kept, and form part of the commissioning report.
shall not recommence such construction or 7. For site facilities, describe the arrangements for identifying the hazard to,
installation or modification or experiment and interaction with, the warship and any essential services.
without the consent of NA EXP.
Context)
(6) The Duty Holder shall make and implement 8. Describe the arrangements for implementing the change in stages,
adequate arrangements for the (where appropriate), with each stage needing approval before
commissioning of any plant or process which commencement.
may affect explosives safety of WIH. 9. Define the safety documentation required to justify the safety of the change
(7) The Duty Holder shall appoint a suitably and describe the level of approval required.
qualified person or persons for the purpose of 10. Describe the arrangements for local review and endorsement of the
controlling, witnessing, recording and proposal before submission for external approval.
assessing the results of any tests carried out in 11. Define the role of relevant groups or review bodies, including the
accordance with the requirements of the involvement of any Safety Committees or Design Authorities.
aforesaid commissioning arrangements. 12. Describe the arrangements for the relevant Design Authority, Operators
(8) The Duty Holder shall ensure that full and and Maintainers to report failures or abnormal responses. The arrangements
accurate records are kept of the results of should identify the Design Authority and describe the activities associated
every test and operation carried out in with the means of identification of ‘defects’ (ie non compliance with
pursuance of this Condition. specified performance) from all other failures and unspecified responses.
(9) The Duty Holder shall ensure that no plant GUIDANCE
or process which may affect explosives safety 13. For a new building, facility or utility, a design safety case will be needed.
of WIH is operated (except for the purpose of This safety case should present the justification for the construction and
commissioning) until: operation of the new facility.
(a) the appropriate stage of commissioning has 14. The staging of safety case documentation should be linked to the
been completed and a report of such anticipated stages of construction / implementation. An appropriate hold
commissioning, including any results and point strategy should be developed and agreed with NA EXP so that each
assessments of any tests as may have been stage is subject to appropriate approval.15. The Duty Holder’s arrangements
required under the commissioning arrangements should make provision for the appropriate Design Authority to be integrated
referred to in paragraph (6) of this Condition, into the control of modifications and alterations to plant and facilities and for
has been considered in accordance with those ensuring that Operating Instructions and procedures are consistent with the
arrangements; and requirements of the Safety Justification and the Design Intent.
(b) a safety case or cases as appropriate, which 16. The Duty Holder should make provision for the appropriate Design
shall include the safety implications of Authority (DA) to be integrated into the arrangements for commissioning.
modifications made since the commencement of The DA is charged with understanding the design intent with respect to
construction of the plant and those arising from explosives safety of WIH and representing this design intent at all stages of
the commissioning of the plant, and any the design, build and commissioning of the plant. NA EXP will seek
matters whereby the operation of the plant may assurance that the integrity of the design intent and appropriate configuration
be affected by such modifications or control is being maintained.
Context)
commissioning, has been considered in 17. Changes that affect the harbour environment, e.g. introduce new hazards,
accordance with the arrangements referred to in should be assessed in the context of the NBSSC(WIH) and communicated to
paragraph (6) of this Condition. Platform Duty Holders through a change to the HEAS.
(10) The Duty Holder shall, if so notified by NA 18. Changes in warships, including introduction of additional vessels, should
EXP, submit to NA EXP the safety case for be documented in the form of the Warship Hazard Footprint Statement and
the aforesaid plant or processes prepared in the implications assessed by Harbour Duty Holders in the context of the
pursuance of paragraph (7) of this Condition and NBSSC(WIH).
shall not commence operation of the relevant 19. As part of its site certification procedure, NA EXP will expect to see
plant or process without the consent of NA EXP. evidence of changes being identified and communicated through the HEAS
and WHFS, with Harbour Duty Holders maintaining the NBSSC(WIH) and
managing change accordingly.
Context)
23 Conditions and (1) The Duty Holder shall, in respect of any INTRODUCTION
limits of safe operation that may affect explosives safety of 1. The purpose of Authorisation Condition 23 (including 23a) is to ensure
operation WIH, produce an adequate safety case to that the conditions and limits of safe operation (affecting explosives safety of
demonstrate the safety of that operation and WIH) are clearly identified within each safety case, such conditions and
to identify the conditions and limits necessary limits bounding the safety case from which they arise. The conditions and
in the interests of safety. Such conditions and limits of safe operation are derived from ‘safety documentation’ (AC14) and
limits shall hereinafter be referred to as must be enforced by ‘Operating Instructions’ (AC24) and, where appropriate,
Operating Conditions and Limits. ‘Safety Mechanisms, Devices or Circuits’ (AC27).
(2) The Duty Holder, where NA EXP so SCOPE
specifies, shall refer the Operating Conditions 2. This advice relates to the interpretation of AC23 (including 23a) for all
and Limits arising from paragraph (1) of this operations that can affect the safety of explosives on WIH.
Condition to the relevant safety committee for 3. AC23 cross-refers, either directly or indirectly, to a number of other
consideration. Conditions, summarised below. NA EXP’s regulation will seek cognisance of
(3) The Duty Holder shall ensure that these links within an Authorisation Condition Compliance Statement,
operations are at all times controlled and emphasising that these links are those specifically identified within the
carried out in compliance with such Authorisation Conditions; the list is not all-inclusive and Duty Holders must
Operating Conditions and Limits. Where the identify any others necessary to make their safety management arrangements
person appointed by the Duty Holder for the effective.
purposes of Condition 26 identifies any matter a. Safety Documentation. AC23 requires Duty Holders to “produce an
indicating that the safety of any operation or adequate safety case”, so establishing a link with AC14 which requires
the safe condition of any plant may be arrangements for the “production and assessment of safety cases consisting of
affected that person shall bring that matter to documentation to justify safety during design, construction, manufacture,
the attention of the Duty Holder forthwith commissioning, operation and decommissioning”. In managing explosives
who shall take appropriate action and ensure risks associated with WIH it is essential that the NBSSC(WIH) and relevant
the matter is then notified, recorded, Ship Explosives Safety Cases are correctly interfaced at the berth level.
investigated and reported in accordance with Hence, in ensuring that a safe and suitable environment is maintained for
arrangements made under Condition 7. warships, the Harbour Duty Holder should manage its operations in
(4) The Duty Holder shall submit to NA EXP for compliance with the limits and conditions specified in the HEAS for the
approval such of the aforesaid Conditions and approved berths (AC4a).
Limits of Safe Operation as NA EXP may
specify.
Context)
(5) The Duty Holder shall ensure that once b. Conditions and Limits of Safe Operation. AC23 requires the above
approved no alteration or amendment is made to safety documentation to “identify the conditions and limits necessary in the
any approved Condition and Limit of Safe interests of safety”. These may be presented in the form of a Safe Operating
Operation unless NA EXP has approved such Envelope, derived from the NBSSC(WIH) and the supporting HEASs.
alteration or amendment. c. Operating Instructions. AC24 requires “all operations which may affect
(6) Notwithstanding the preceding provisions of safety to be carried out in accordance with written instructions”, which must
this Condition NA EXP may, if in its opinion include “any instructions necessary to ensure that any conditions and limits of
circumstances render it necessary at any time, safe operation are implemented.” Note:
agree to the temporary suspension of any (i) all conditions and limits of safe operation must be supported by written
approved Condition and Limit of Safe operating instructions,
Operation. (ii) but not all operating instructions enforce conditions and limits of safe
23a Berthing and (7) The Duty Holder shall produce an adequate operation.
movements safety case to demonstrate that explosives d. Control & Supervision of Operations. AC23 cross-refers to AC26
safety of WIH is maintained during the (Control & Supervision of Operations), requiring Duty Holders to “ensure
berthing of a warship and identify the that no operations affecting safety are carried out except under the Control
conditions and limits necessary in the and Supervision of SQEP appointed for that purpose”. This, by inference,
interests of safety. cross-refers to AC12 (SQEP & DAP), requiring Duty Holders to “make and
(8) The Duty Holder shall ensure adequate implement adequate arrangements to ensure that only SQEP perform any
arrangements are in place to control the duties which may affect safety”. Additionally, AC10 (Training) requires Duty
movements of other shipping in the vicinity, Holders to “make and implement adequate arrangements for suitable training
work on, or operation of adjacent warships and of those who have responsibility for any operations which may affect safety”.
any other operation on site which may adversely AC36 (Organisational Change) may also be implicated in these arrangements.
affect the explosives safety of a warship when e. Incidents on Site. AC23 requires “any matter indicating the safety of any
berthed. operation or safe condition of the plant” to be brought “to the attention of the
(9) The Duty Holder shall ensure that no Duty Holder forthwith who shall take appropriate action… iaw Condition 7.”
warship is permitted within the relevant f. Safety Mechanisms. AC27 requires Duty Holders to “ensure that plant is
site except in accordance with adequate not operated, inspected, maintained or tested unless suitable and sufficient
arrangements made by the Duty Holder for this safety mechanisms, devices and circuits are properly connected and in good
purpose. working order.” One purpose of such mechanisms is to prevent certain
(10) The Duty Holder shall submit to NA EXP conditions and limits of safe operation being exceeded.
for approval such part or parts of the aforesaid g. Change Control. In having a clearly defined Safe Operating Envelope,
arrangements as NA EXP may specify. proposed changes can be readily assessed for safety significance, thereby
enabling Safety Documentation to be reviewed, revised and approved as
required. Collectively, AC19 to AC22 cover physical changes and AC36
covers organisational changes.
Context)
(11) The Duty Holder shall ensure that once KEY POINTS FOR COMPLIANCE
approved no alteration or amendment is made to 4. a. Identify responsible persons.
approved arrangements unless NA EXP has b. Describe the system for ensuring that appropriate conditions and limits of
approved such alteration or amendment. safe operations are derived and approved via the appropriate clearance route,
(12) For new berths or for berths equipped with e.g. HEAS and berthing matrix.
new facilities, the Duty Holder shall ensure that c. Describe the arrangements for ensuring that amendments to conditions and
the facilities are not used for the first time limits of safe operations are approved before implementation.
without the consent of NA EXP. d. Describe the arrangements for dealing with a breach of a condition or limit
(13) The Duty Holder shall make and implement of safe operation. The reporting arrangements are covered under AC7.
adequate arrangements to ensure that only e. Describe the arrangements for categorisation to emphasise those conditions
berths, in locations currently approved by NA and limits having most explosives safety significance, e.g. Safe Operating
EXP, are used and only for the operations Envelope.
specified for that berth. GUIDANCE
(14) The Duty Holder shall ensure that, for each Conditions and Limits of Safe Operation
berth, the requirements and availability of all 5. Conditions and Limits of Safe Operation are the conditions and limits
necessary supporting facilities, equipment, necessary in the interests of safety, as distinct from the written ‘Operating
approved documentation including berth HEASs Instructions’ or ‘Safety Mechanisms, Devices or Circuits’ used to enforce
and accident contingency plans are specified. them. Conditions and limits refer to both operator controlled and external (eg
extreme weather) physical conditions and limits, and the following should be
considered when defining them:
a. calculated limits of performance,
b. limits of analysis, beyond which the performance of the system is
unknown,
c. limitations in the scope of the safety case,
d. limits and conditions derived from the Design Basis of the Naval Base
facility.
Operating Instructions
6. Operating Instructions are written instructions produced iaw AC24, that
may enforce the above conditions and limits.
Safety Mechanisms
7. Safety Mechanisms are engineered safeguards, fitted iaw AC27, not
involved in normal operation, which may prevent the above conditions and
limits from being breached.
Context)
Example
8. Each condition or limit may be enforced by a number of ‘Operating
Instructions’ or ‘Safety Mechanisms, Devices or Circuits', as outlined in the
following illustrative example:
Damage greater than justified within the safety case will be incurred if
the <defined warship(s) at defined berth(s)> is subjected to a dropped
load impact of greater than … MJ
(i) The condition or limit is derived from the HEAS where information regarding
the withstand capability of the warship is defined, thereby enabling the
environment to be managed through the NBSSC(WIH).
(ii) To enforce this condition and limit, a number of measures could be
considered, including:
(a) fitting safety mechanisms, devices or circuits which provide:
(1) alarms to alert operators to limiting loads, heights, wind speeds or
temperatures,
(2) limit switches to prevent lifts outside limiting loads, heights, wind speeds or
temperatures.
(b) written instructions (Operating Instructions):
(1) requiring all cranes and lifting gear to have been maintained and tested in
accordance with an EMIT schedule,
(2) requiring the conduct of test lifts to prove the lifting train prior to conducting
a sensitive lift,
(3) specifying the minimum SQEP for the lift operators and supervisors,
(4) prohibiting lifts over certain areas of the warship, e.g. vulnerable magazines,
(5) limiting the mass and/or height of a lift over a service,
(6) prohibiting lifts under certain environmental conditions, e.g. wind speed or
temperature.
Categorisation
9. Several conditions and limits of operation may be identified for a given
plant, such limits being necessary for various reasons including: explosives
safety, conventional health and safety, plant availability or production. This
Condition is concerned with explosives safety for WIH, and where numerous
conditions and limits are identified it will be necessary to categorise those
limits to place emphasis on those having most significance for explosives
safety for WIH.
Context)
24 Operating (1) The Duty Holder shall ensure that all INTRODUCTION
instructions operations which may affect safety are 1. The purpose of this Condition is to define the arrangements for ensuring
carried out in accordance with written that all operations that may affect safety are carried out in accordance with
instructions hereinafter referred to as Operating written Operating Instructions. This includes implementation of the
Instructions. Conditions and Limits of Safe Operation.
(2) The Duty Holder shall ensure that such SCOPE
Operating Instructions include any 2. This advice relates to operations that may affect explosives safety of WIH.
instructions necessary in the interests of The arrangements for conditions and limits of safe operation are covered by
safety and any instructions necessary to AC23.
ensure that any Conditions and Limits of Safe KEY POINTS FOR COMPLIANCE
Operation are implemented. 3. a. Identify the responsible person. Outline the responsibilities of all
(3) The Duty Holder shall, if so specified by NA personnel relating to the production, maintenance, review and
EXP, furnish to NA EXP copies of such implementation of Operating Instructions.
Operating Instructions and when any alteration b. Describe the arrangements for producing written operating instructions:
is made to the Operating Instructions furnished (i) step-by-step instructions on how to carry out an operation to ensure
to NA EXP, the Duty Holder shall ensure that that it is done in the way assumed in the safety case,
such alteration is furnished to NA EXP within (ii) instructions to ensure that the Conditions and Limits of Safe Operation
such time as may be specified. are complied with,
(4) The Duty Holder shall make and implement (iii) other instructions necessary in the interests of safety.
adequate arrangements for the preparation, c. Describe the arrangements for reviewing, amending, controlling and
review and amendment of such Operating approving the operating instructions.
Instructions. GUIDANCE
(5) The Duty Holder shall submit to NA EXP for 4. Operating Instructions should be clear and unambiguous and should be
approval such part or parts of the aforesaid consistent with the safety case and its assumptions.
arrangements as NA EXP may specify. 5. Operating Instructions should identify conditions and limits of operation
(6) The Duty Holder shall ensure that once where these exist and should clearly require operations to be undertaken in
approved no alteration or amendment is made to accordance with them and any other parameters which will control the risk
the approved arrangements unless NA EXP has from potential hazards.
approved such alteration or amendment. 6. An associated document control and distribution system should be
provided together with arrangements to bring validated and authorised
operating instructions and any changes to them into use at the appropriate
time.
7. The above comments also apply in their entirety for temporary operating
instructions.
8. A fundamental aspect of the arrangements is the means by which the
operating instructions reflect the requirements of the safety case and the
Context)
design intent of those elements of the Naval Base whose operations they
cover. This is particularly important where a facility interacts with a warship
at a berth and control in this area requires arrangements which go beyond the
scope of a single Duty Holder or single safety case, e.g. to maintain the
environment defined in a HEAS.
25 Operational (1) The Duty Holder shall ensure that INTRODUCTION
records adequate records are made of the operation, 1. The purpose of this Condition is to define the arrangements for ensuring
inspection and maintenance of any plant that adequate records are made of the operation, inspection and maintenance
which may affect explosives safety of WIH. that may affect explosives safety of WIH.
(2) The Duty Holder shall record such SCOPE
additional particulars as NA EXP may specify. 2. This advice covers only operational records - AC7 covers records of
(3) The Duty Holder shall furnish NA EXP such incidents.
copies of extracts from such records at such KEY POINTS FOR COMPLIANCE
times as NA EXP may specify. 3. a. Identify the person appointed to take charge of the records system.
b. Describe the arrangements for ensuring that records of operations are
produced, controlled and retained for any plant which may affect safety.
Operational records should, where appropriate, include records of operations
and results. Unless agreements to the contrary are made with NA EXP, the
period for retention of operating records should be 10 years.
GUIDANCE
4. The arrangements for operational records should be such as will permit the
Duty Holder to review previous operations so as to:
a. establish an operational baseline for a plant or facility,
b. confirm that a facility or plant’s performance is maintained through life,
c. confirm the continuing validity of the safety case,
d. establish that assumptions regarding operations made in the safety case are
realistic,
e. support justification of continued operation in the case of abnormal events,
defects etc,
f. allow analysis to support improvements in design or operation (AC14),
g. support the berth assessment process (AC4a),
h. support the periodic safety review process (AC15).
5. A systematic approach should be taken to identify what records should be
kept and the reasons for retaining each type of record. The sorts of records
which it may be appropriate to keep include such items as plant operating
logs, records of maintenance activities, records of specific trials, etc.
Context)
26 Control and The Duty Holder shall ensure that no INTRODUCTION
supervision of operations are carried out which may affect 1. The purpose of this Condition is to define the arrangements for ensuring
operations safety except under the control and that all operations which affect explosives safety of WIH are carried out
supervision of suitably qualified and under the control and supervision of qualified personnel appointed for that
experienced persons appointed for that purpose purpose.
by the Duty Holder. SCOPE
2. The appointment of Duly Authorised and Suitably Qualified and
Experienced Personnel (SQEP) to specific posts with control and supervision
functions affecting safety, and approving their terms of reference is discussed
in AC12.
3. a. Describe the arrangements for delegating management authority to
supervisors, ensuring that personnel have the correct qualifications and
expertise.
b. Describe the arrangements for ensuring that copies of the Operating
Instructions and Conditions and Limits of Safe Operation are made available
to operating personnel.
c. Describe the arrangements through which the Site Duty Holder gains
assurance that personnel working on safety significant tasks on the NA EXP
Certified Site who are not part of the Duty Holder’s organisation are SQEP
and properly appointed for the purpose.
GUIDANCE
4. The personnel referred to in c. above applies particularly to contractors
working on the NA EXP Certified Site.
5. Duty Holders arrangements should cover not only the appointment of
SQEP staff but should ensure that there are adequate staffing levels to meet
the requirements of the safety case, especially with regard to contingency
arrangements, e.g. sufficient provision for fire fighting.
27 Safety The Duty Holder shall ensure that a plant is INTRODUCTION
mechanisms, not operated, inspected, maintained or tested 1. The purpose of this Condition is to define the arrangements for ensuring
devices and unless suitable and sufficient safety that Naval Base plant and facilities, (for which the safety case has identified
circuits mechanisms, devices and circuits are the need for a Safety Mechanism, Device or Circuit (SMDC)), are not
properly connected and in good working operated, inspected, maintained or tested unless these safety systems are
order. properly connected and in good working order as required by the safety case.
SCOPE
2. This advice relates to plant and facilities in which the safety case
Context)
has identified the need for safety mechanisms, devices or circuits.
3. Associated ACs include:
a. AC23 Conditions and Limits of Safe Operation,
b. AC28 EMIT.
4. a. Identify the persons responsible for:
(i) the safety of the design of new or modified facilities and for providing
instructions which ensure safe operation and maintenance,
(ii) the safe operation of Naval Base plant and facilities.
b. Outline the responsibilities of all personnel relating to Naval Base SMDC,
defining all interfaces and boundaries.
c. Describe the system for ensuring that SMDC are derived from the safety
case, incorporated into operating documentation and approved via the
appropriate clearance route (see AC24).
d. Describe the arrangements for ensuring that Naval Base plant or facility
significantly affecting safety is protected by SMDC.
e. Describe the actions to be taken following the operation of those SMDC
essential for safety.
f. Describe the arrangements for ensuring that a system of permits to work is
implemented, that the safety system is maintained, tested and set up
according to specified procedures, and that safety-related trip or alarm levels
are not changed without Authorisation.
GUIDANCE
Safety Mechanisms Devices and Circuits (SMDCs)
5. SMDCs are any engineered safeguards that are not invoked in normal
operation, which prevent a safe limit of operation being breached. SMDCs
include active and passive safety equipment. The omission or failure of a SM
would either lead to a significant increase in risk or fail to prevent the
transgression of the design basis envelope. The safety functions of a SMDC
would not usually be invoked during normal operation and therefore their
correct functioning is not demanded or tested during this phase. The function
of SMDCs is to limit transients or fault sequences to within safety limits,
prevent the transgression of the Conditions and Limits of Safe Operation or
mitigate the consequences of an accident. Such safety systems should ideally
be independent of the plant’s normal control systems.
6. There should be clear evidence that safety mechanisms, devices and
Context)
circuits have been derived from safety cases and that these have been
effectively incorporated into operational documentation.
7. At all times there should be sufficient safety systems operational to ensure
that the plant is not operated outside the ‘safe operating envelope’ defined in
its safety case. Any failure to comply with this or any failure of a SMDC
discovered for instance during testing should invoke incident reporting
arrangements made under AC7. Similarly, should a demand be placed on any
SMDC for any reason, then the circumstances should also be reported as an
incident.
Context)
28 Examination, (1) The Duty Holder shall make and implement INTRODUCTION
maintenance, adequate arrangements for the regular and 1. The purpose of this Condition is to define the arrangements for ensuring that the
inspection and systematic examination, maintenance, inspection plant performance required in the safety case is sustained and that any defects which
testing and testing of all plant which may affect safety. may affect that performance are detected and addressed at an early stage, or at a time
(2) The Duty Holder shall submit to NA EXP for specified by NA EXP.
approval such part or parts of the aforesaid SCOPE
29 Duty to carry out arrangements as NA EXP may specify. 2. The advice given here is to ensure that plant and equipment which may affect
tests, inspections (3) The Duty Holder shall ensure that once approved safety should be subject to adequate surveillance and included in a maintenance
and examinations no alteration or amendment is made to the approved schedule.
arrangements unless NA EXP has approved such 3. The Condition requires that EMIT schedules are carried out on time unless specific
alteration or amendment. permission is given by NA EXP. It is therefore in the interests of the Duty Holder to:
(4) The aforesaid arrangements shall provide for a. identify those parts of the EMIT schedule derived from the safety case which must
the preparation of a plant maintenance schedule be done,
for each plant. The Duty Holder shall submit to NA b. identify, and agree with NA EXP, the limiting safe periodicity for EMIT items,
EXP for its approval such part or parts of any plant c. identify a periodicity for EMIT, within the limit agreed above, which will give
maintenance schedule as NA EXP may specify. flexibility to suit operational needs.
(5) The Duty Holder shall ensure that once approved 4. AC30, Periodic Shutdown, requires maintenance schedules to be adhered to, even
no alteration or amendment is made to any approved if the plant has to be shut down to carry out EMIT.
part of any plant maintenance schedule unless NA 5. This Condition also covers the examination, inspection and maintenance of Naval
EXP has approved such alteration or amendment. Base plant during build, repair or refit.
(6) The Duty Holder shall ensure in the interests of KEY POINTS FOR COMPLIANCE
safety that every examination, inspection, 6. a. Producing and controlling the EMIT schedule for all safety related Naval Base
maintenance and test of a plant or any part assets.
thereof is carried out: b. Ensuring that a safety related Naval Base asset is satisfactorily maintained,
(a) by suitably qualified and experienced persons, inspected or tested and is in a safe condition to operate.
(b) in accordance with schemes laid down in c. Ensuring that the level of experience and qualifications of personnel carrying out
writing, the examination, maintenance, inspection and testing work satisfies the requirements
(c) within the intervals specified in the plant (see AC12).
maintenance schedule, and 7. Describe the arrangements for producing an EMIT Schedule of safety related
(d) under the control and supervision of a assets for each system, including how it is derived from the safety case, describing
suitably qualified and experienced person the operations and periodicity of maintenance, examinations and tests.
appointed by, or with the endorsement of, the 8. Describe the arrangements for:
Duty Holder for that purpose. a. allowing suspension or delay in carrying out particular examinations,
(7) Notwithstanding the above paragraphs of this inspections, maintenance and testing, specifying the levels at which such delays can
Condition NA EXP may agree to an extension be authorised,
of any interval specified in the plant maintenance b. ensuring that appropriate action is taken in the event of failure under testing,
schedule. examination and the requirements for any special reports in these circumstances.
Context)
(8) When any examination, inspection, 9. Describe the arrangements for ensuring that maintenance programmes for shore
maintenance or test of any part of a plant reveals facilities are linked to warship operating safety requirements and that differing
any matter indicating that the safe operation or requirements can be de-conflicted.
safe condition of that plant may be affected, the GUIDANCE
suitably qualified and experienced person 10. The Safety Justification should link EMIT with all Naval Base assets which may
appointed to control and supervise any such affect safety of explosives on WIH. This will enable EMIT schedules to be drawn up
examination, inspection, maintenance or test shall and prioritised.
bring it to the attention of the Duty Holder
forthwith who shall take appropriate action and
ensure that the matter is then notified, recorded,
investigated and reported in accordance with the
arrangements made under Condition 7.
(9) The Duty Holder shall ensure that a full and
accurate report of every examination, inspection,
maintenance or test of any part of a plant indicating
the date thereof and signed by the suitably qualified
and experienced person appointed by the Duty
Holder to control and supervise such examination,
inspection, maintenance or test is made to the Duty
Holder forthwith upon completion of the said
examination, inspection, maintenance or
test.
(10) The Duty Holder shall carry out such tests,
inspections and examinations in connection with
any plant as NA EXP may, after
consultation with the Duty Holder, specify.
(11) The Duty Holder shall furnish the results of any
such tests, inspections and examinations carried out
in accordance with paragraph (10) of this Condition
to NA EXP as soon as practicable.
Context)
30 Periodic N/A – concept of ‘shutdown’ does not apply to N/A
shutdown WIH quiescent state
31 Shutdown of
specified
operations
32 Accumulation of N/A – no explosives wastes arise through N/A
explosive waste quiescent state
33 Disposal of
explosive waste
34 Leakage and
escape of
explosive material
and explosive
waste
35 Decommissioning N/A – WIH does not extend to decommissioning N/A
36 Control of (1) The Duty Holder shall make and implement INTRODUCTION
organisational adequate arrangements to control any 1. Authorisation Condition 36 enables the regulation of changes to a Duty
change changes to its organisational structure or Holder’s organisational structure or resources, such change ranging from high
resources which may affect safety. level change, e.g. management board reorganisations or agency mergers, to
(2) The Duty Holder shall submit to NA EXP for low level changes, including reduction of manpower in response to savings
approval such part or parts of the aforesaid measures or the increased use of contractors.
arrangements as NA EXP may specify. 2. AC36 mirrors AC22 (Modification of Existing Plant), requiring Duty
(3) The Duty Holder shall ensure that once Holders to manage organisational change as a modification to an extant
approved no alteration or amendment is made to organisation. Organisations may use their compliance arrangements for AC22
the approved arrangements unless NA EXP has as a framework.
approved such alteration or amendment. KEY POINTS FOR COMPLIANCE
(4) The aforesaid arrangements shall provide for Adequate Arrangements
the classification of changes to the 3. The Duty Holder must demonstrate that he has made and implemented
organisational structure or resources according adequate arrangements to control any changes to his organisational structure
to their safety significance. The arrangements or resources. Such arrangements must include a description of the Duty
shall include a requirement for the provision of Holder’s:
adequate documentation to justify the safety a. Datum Organisation,
of any proposed change and shall where b. Procedures for Organisational Change.
appropriate provide for the submission of any Datum Organisation
such documentation to NA EXP. 4. The Datum Organisation must be documented, ideally as an Organisation
Context)
(5) The Duty Holder shall if so directed by NA Management Safety Report, and that documentation should identify all safety
EXP halt the changes to its organisational significant aspects of the organisation, including:
Structure or resources and the Duty Holder a. the purpose of the organisation,
shall not recommence such change without the b. senior management and their responsibilities,
consent of NA EXP. c. lines of accountability from the workforce to senior management,
d. description of the staff comprising the organisation, including:
(i) numbers of staff required,
(ii) identification of posts with special safety responsibilities, in particular
those with safety responsibilities to the Duty Holder but not part of his
organisation, requiring the post holders to be Suitably Qualified and
Experienced Persons (SQEP),
(iii) identification of managerial posts with critical safety responsibilities,
requiring the post holders to be Duly Authorised Persons (DAP),
(iv) Terms of Reference and Job Descriptions,
(v) Training, Qualification and Experience Requirements Plan,
e. arrangements for the employment of contractors.
Procedures for Organisational Change
5. a. Role of Senior Management. A statement of senior management
commitment should be produced, including: acceptance of their
responsibility; recognition that the management of safety is a key business
objective; and a description of control of their organisation.
b. Project Management. The arrangements for proactive management of the
change should be described, including the means by which proposed changes
are to be planned, developed, assessed and subsequently implemented.
c. Review and Assessment. The arrangements for independent review and
assessment, depending upon categorisation, should be described, including
any arrangements for independent peer review.
d. Audit and Feedback. The arrangements for audit of an organisation post
implementation of change should be described, to provide assurance that the
change has been correctly implemented, and that the arrangements are robust
on completion.
Classification
6. As with equipment modifications, changes to the organisational structure
or resources are to be classified according to their safety significance. This is
to enable the application of a degree of scrutiny and review commensurate to
the impact of the proposed change. This in turn must be based upon an
Context)
assessment of the consequences of a management failure due to the
organisational changes and the subsequent loss of control of a safety
significant activity.
Documentation
7. The arrangements should provide for adequate documentation to justify
any proposed change. This should include:
a. recognition of the safety implicated aspects of the Datum Arrangements,
b. consideration of options,
c. principles for change,
d. demonstration of how the revised organisation is to function, highlighting
the effect of change from the datum.
Submission
8. The Duty Holder’s arrangements shall include the submission of any
documentation called for review by NA EXP.
Approval of Specified Arrangements
9. Regulatory review. The Duty Holder must recognise the need for NA
EXP to review any proposed changes and be prepared to stop its change or
operational programme if NA EXP is not satisfied with the safety
implications.
ANNEX D – PROFORMA FOR NAVAL BASE AUTHORISATION CONDITION COMPLIANCE STATEMENTS
The following table is provided as a pro-forma for use by each NB in demonstrating compliance with each applicable AC. Shading has been applied to
identify ACs that are not applicable, such that the NB need only describe their arrangements in the blank fields. The completed version of this table will go
much of the way to demonstrating that modern safety management standards are being applied in controlling the major accident hazard of WIH and will be a
key part of that particular NBSSC(WIH).30 As part of the assessment process, NA EXP will review these arrangements for compliance against the
expectations laid out in Annex C and will seek evidence of their effectiveness in practice.
AC Description Authorisation Condition Compliance Statement

1 Interpretation N/A
2 Marking of the site boundary N/A – no requirement over and above existing arrangements
3 Restrictions on dealing with the site N/A – no requirement over and above existing arrangements
4 Restrictions on explosive matter on the site N/A – no requirement over and above existing arrangements
4a Berth approval
5 Consignment of explosive matter N/A – no requirement over and above existing arrangements
6 Documents, records, authorities and certificates N/A – no requirement over and above existing arrangements
7 Incidents on the site
8 Warning notices N/A – no requirement over and above existing arrangements on warship
9 Instructions to persons on the site
10 Training
11 Emergency arrangements
12 Duly authorised and suitably qualified and experienced persons
13 Explosive Safety Committee N/A - no intention to create a NSC-type body. NA EXP certification is
sufficient.
14 Safety documentation
15 Periodic review
16 Site plans, design and specifications
17 Quality assurance N/A – no requirement over and above existing arrangements
18 Radiological protection N/A
19 Construction of new buildings or introduction of additional
warships
20 Modification to design of plant under construction
21 Commissioning
22 Modification to existing buildings or warships
30
An electronic version of this template is available from NA EXP
AC Description Authorisation Condition Compliance Statement
23 Conditions and limits of safe operation
23a Berthing and movements
24 Operating instructions
25 Operational records
26 Control and supervision of operations
27 Safety mechanisms, devices and circuits
28 Examination, maintenance, inspection and testing
29 Duty to carry out tests, inspections and examinations
30 Periodic shutdown N/A – concept of ‘shutdown’ does not apply to WIH quiescent state
31 Shutdown of specified operations
32 Accumulation of explosive waste N/A – no explosives wastes arise through quiescent state
33 Disposal of explosive waste
34 Leakage and escape of explosive material and explosive waste
35 Decommissioning N/A – WIH does not extend to decommissioning
36 Control of organisational change

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NAVAL AUTHORITY NOTICE

APPLICABILITY - ALL MOD SHIPS AND NAVAL BASES

Policy and Procedures for Regulation of Explosives Risk of

CHAPTER 2 NAEXP REGULATORY FUNCTION FOR WIH

CHAPTER 3 REGULATOR’S ASSESSMENT OF SAFETY CASE REPORTS

CHAPTER 4 REGULATOR’S AUDIT OF DUTY HOLDERS

ANNEX A CERTIFICATE OF SAFETY EXPLOSIVES FOR NAVAL BASES

1.2 The Need for Regulation

1.3 Regulator Scope and Interfaces

1.3.1 Nuclear Safety

These are described in turn below.

2.1 Policy Formulation

2.2 Provision of Guidance

e. Defining the datum parameters within the Generic Harbour Environment.

g. Development of the WIH tool set and associated guidance on use.

2.3 Conduct of Safety Assurance Tasks

2.3.1 Assurance Processes

b. Assessment of NBSSC(WIH) Reports submitted by Naval Bases in support of site certification;

(1) Compliance of safety cases with the WIH methodology;

3.1 Assessment Frequency

4.1 Site Safety Management Arrangements

4.2 Warship Safety Management Arrangements

4.3 Audit Frequency

4.4 Audit Findings

5.2 Regulator Stand-Up (June 2005)

5.3 Ship Explosives Safety Case Development

5.4 Audit and Periodic Review

5.5 Implementation - Summary

Aspect Output Stand-Up SESC Development Audit and Periodic Review

ANNEX A: Certificate of Safety Explosives for Naval Bases (CSENB)

NAVAL AUTHORITY EXPLOSIVES

CERTIFICATE OF SAFETY - EXPLOSIVES –

Name of Naval Base HMNB

3. This CSENB is invalidated if:

4. This CSENB supercedes CSENB xxxx/xx dated dd/mm/yyyy

delegated Naval Authority

Annex A - Conditions and Mandatory Requirements of Certification.

ANNEX A: Certificate of Safety Explosives for Naval Bases (CSENB)

NAVAL AUTHORITY EXPLOSIVES

CONDITIONS AND MANDATORY

Section 2 Specific Conditions and Mandatory Requirements

[To be included here as appropriate]

NAVAL AUTHORITY EXPLOSIVES

AUTHORISED BERTHING MATRIX

Berth Class / Vessel

Supplementary Notes to Berthing Matrix

[To be included here as appropriate]

OVERALL ACTIVITY - MUNITION TRANSIT

OVERALL ACTIVITY - MUNITION TRANSIT - MOORING AT BUOY

• Site/Berth License NBC (Site Safety Case) IE (DE&S)

OVERALL ACTIVITY - RISKS FROM MUNITIONS IN QUIESCENT STATE

From June 05 - NA EXP

• Platform Safety PDH NA EXP

OVERALL ACTIVITY - AMMUNITIONING BY CRANE ALONGSIDE

Material state of DSDA - DMC IE (DE&S) - Crane certification

AC Description (WIH Requirement28 Compliance

AC Description Authorisation Condition Compliance Statement

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