Safety concessions Clyde Submarine Base

The request was successful.

Dear Ministry of Defence,

Could you please provide me information about the number of concessions granted against nuclear safety regulations by year since 2000 at the Clyde Submarine Base.

Yours faithfully,

Fred WP Dawson

DES SEC-PolSecSubs1 (Shikrakar, Gina Mrs), Ministry of Defence

1 Attachment

Dear Mr Dawson

Please find attached a letter in relation to your request for information
under the Freedom of Information Act.

Regards,

DE&S Policy Secretariat (Submarines)

Dear DES SEC-PolSecSubs1 (Shikrakar, Gina Mrs),

“From our preliminary assessment, it is clear that we will not be able to answer your
request without further clarification; the Defence Nuclear Safety Regulator (DNSR) and
Her Majesty’s Naval Base (HMNB) Clyde do not recognise the use of the word
‘concession’. To assist you in clarifying this request, it may be helpful if I explain that
safety requirements for activities at HMNB Clyde are defined in Authorisation Conditions.
These are the Defence equivalent to the Licence Conditions that would apply to a nuclear
site that was licensed under the Nuclear Installations Act. DNSR regulates activities at
HMNB Clyde and may identify and agree ‘findings’ or ‘observations’ of non-compliance
with Authorisation Conditions. Findings relate to areas where improvements are required;
observations relate to areas where improvements may be realised and are for
consideration by the Authorisee. Both findings and observations are recorded formally
and tracked, but only findings require formal closeout by DNSR.”

To clarify “concession” this relates a situations where there is relaxation of a safety standard which agreed between the operator and the regulator. eg time allowed to reach a particular standard and mitigating measures taken to reduce hazard and/or risk.
In MOD a precedent for safety concessions can be found in JSP520 “UK MOD’s ORDNANCE, MUNITIONS AND EXPLOSIVES SAFETY MANAGEMENT SYSTEM “

http://www.mod.uk/NR/rdonlyres/61D5DC2F-...

Yours sincerely,

Fred WP Dawson

DES SEC-PolSecSubs1 (Shikrakar, Gina Mrs), Ministry of Defence

1 Attachment

Dear Mr Dawson,

Please find attached an update to your request for information under the
Freedom of Information Act.

Regards,

DES Secretariat

DES SEC-PolSecShips and Subs (MULTIUSER), Ministry of Defence

1 Attachment

Dear Mr Dawson

Please find attached the response to your request for information under
the Freedom of Information Act.

Regards,

DES Secretariat

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