- Site: Transport Competent Authority
- IR number: 20-021
- Date: October 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 ADR 2019 was used during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Terra Tek Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection of Terra Tek’s Airdrie site remotely (via Skype) on 6 October 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 IRR17 Regulation 13;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate local rules – IRR17 Regulation 18
- adequate safety advice – ADR 1.8.3
- adequate marking and labelling – ADR 5.2
- adequate transport documentation – ADR 5.4;
- adequate security arrangements – ADR 1.10;
- equipment on board – ADR 8.1.5.2; and
- a suitable and sufficient management system – ADR 1.7.3.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Terra Tek 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 many its radiation risk assessment, restriction of exposure, local rules, and contingency plans. A number of non-compliances were identified and discussed during the inspection, which included inadequate instruction and training of staff, rehearsal of contingency plans, frequency of dangerous goods safety adviser’s annual report and actions to address issues identified and incorporation of key documentation within the company management system.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Terra Tek Ltd to consider.
Conclusion of Intervention
Terra Tek 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 seven non-compliances with relevant legislation and suggested two improvements. These were all discussed during the inspection and a commitment obtained from Terra Tek Ltd to address them.
Terra Tek Ltd was given until 17 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 IIS Rating of GREEN is given, due to there being some minor contraventions of administrative requirements.
Non-compliances will be managed through ONR’s Issues Management arrangements.