- Site: Transport Competent Authority
- IR number: 20-020
- Date: September 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG) and the Ionising Radiations Regulations 2017 (IRR17). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR regulated against ADR 2019 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Biocair International Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection of Biocair’s Sawston, Edinburgh and London sites and Warrington Satellite drivers remotely (via telephone) on 29 September 2020.
Interventions Carried Out by ONR
The chosen inspection sample included:
- notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- Suitable and sufficient Local Rules – IRR17 Regulation 18;
- Radiation protection adviser – IRR17 Regulation 14;
- Safety Adviser – RID 1.8.3
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Biocair International Ltd for the safe transport of radioactive materials, including the associated arrangements for protecting workers against the effects of ionising radiations and reducing risks as low as reasonably practicable (ALARP).
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. A number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP were identified including: appropriate registration; appropriate Radiation Protection Adviser and Dangerous Goods Safety Adviser appointments; having RRA’s, Local Rules and contingency plans for emergencies and producing a Dangerous Goods Safety Adviser annual report.
A number of minor contraventions of specific administrative requirements against legislation were identified and discussed during the inspection, which included the requirement to obtain an appropriate certificate of compliance for Biocair’s infrequently used Type A transport package, elements of the RRAs being inadequate and the need to consolidate multiple emergency plans and emergency instructions and demonstrate that such documents are in full compliance with the emergency planning requirements under CDG.
During the inspection, the inspector also suggested an improvement to transport practices that would be prudent for Biocair International Ltd to consider.
Conclusion of Intervention
Biocair International Ltd demonstrated that for aspects of its operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified four minor contraventions of administrative requirements against legislation and suggested one improvement. ONR discussed these non-compliances during the inspection and Biocair International Ltd gave a commitment to address them.
ONR gave Biocair International Ltd until 6 November 2020 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an overall IIS Rating of GREEN was given to reflect that legal duties are complied with, although there were minor contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.