- Site: Transport Competent Authority
- IR number: 20-016
- Date: September 2020
- LC numbers: N/A
Executive summary
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 ADR 2019 was used during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Scot-Test Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection of the Paisley site remotely (via Skype ) on 16 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;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1 and 8.2;
- adequate Security arrangements – ADR 1.10;
- a suitable and sufficient Management System – ADR 1.7.3.
- type A package design compliance – ADR 5.1.5.2.3
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Scot-Test 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 such as security awareness for the vehicle and load including high consequence dangerous goods thresholds, restriction of exposure including arrangements for monitoring dose to staff and contamination monitoring as well as elements of the radiation risk assessment. A number of non-compliances were identified and discussed during the inspection, which included emergency plan which was not in full compliance with the requirements of CDG and insufficient training in relation to work with high-activity sealed sources (HASS). While there were a number of non-compliances identified, the safety significance is considered to be nominal on the basis of the low frequency of consignments (no more than once per month), the types of packages used are of lower consequence (special form in Type A packages/ excepted packages) and the arrangements were not entirely absent, but rather did not meet current relevant good practice when compared against appropriate benchmarks.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Scot-Test Ltd to consider.
Conclusion of Intervention
Scot-Test Ltd demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified five non-compliances with relevant legislation and suggested four improvements. These were all discussed during the inspection and a commitment obtained from Scot-Test Ltd to address them.
Scot-Test Ltd was given until 28 October 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 IIS Rating of GREEN is given to reflect that legal duties were complied with, although there were minor contraventions of specific administrative requirements.
All non-compliances will be managed through ONR’s Issues Management arrangements.