This FOI was submitted to the MOD following concerns raised about poor record keeping by the MOD relating to contaminated land and the MOD saying that it had in place a “robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment”
“I note from a recent BBC news report into radioactive contamination concerns at RAF Kinloss MOD is quoted as saying "The MoD is committed to assessing land quality across the entire defence estate. This robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment.”
"I note that MOD is a member of “Safegrounds” which has produced best practice guidance for the management of radioactive contaminated land.
Could you please provide me with the audit and compliance reports that demonstrate that the MOD meets this “ industry best practice”
Also you could please provide me with me with the audit and compliance reports that demonstrate that the MOD meets “SAFEGROUNDS Good practice guidance for land quality records management for nuclear-licensed and defence sites””
The MOD replied
“I can confirm that the MOD holds no information that falls within the scope of your request. I am advised that there are no requirements for the MOD to have audit and compliance reports in relation to the management of radioactive contaminated land.”
“There is no requirement for the MOD to follow the Safegrounds guidance for land quality records management, therefore no audit and compliance reports exist”
The reply clearly shows that the MOD can provide no evidence to support it's statement saying that the MOD meets “best practice” and this by implication means there are no audit or compliance systems to demonstrate that it is meeting its own policy and standards for managing radioactive contaminated land let alone discharge its legal duty of care to protect man and the environment.
It is also interesting to note the MOD in JSP375 Volume 4 the MOD Safety Health and Environment Audit manual lays down the requirement for audits to provide assurance that health safety and environmental standards are being met. The reply to the FOI suggests that this requirement in so far as the management of contaminated land and “best practice” is concerned that the MOD is ignoring its own requirements for audit and assurance.
Safegrounds Good Practice Guidance for the Management of Contaminated land on Nuclear-licensed and Defence Sites; version 2
Safegounds Good Practcie Guidance for Land Quality Records Management for Nuclear-licensed and Defence Sites