- Site: Transport Competent Authority
- IR number: 20-031
- Date: November 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), the Ionising Radiations Regulations 2017 (IRR17) and the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR used ADR 2019 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Inspection Consultants Ltd’s (INCONS’s) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at INCON’s Ellesmere Port facility on 3 November 2020.
A Health and Safety Executive (HSE) Inspector carried out a non transport IRR17 inspection in parallel to the transport inspection.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Radiation protection adviser – IRR17 Regulation 14;
- Safety Adviser – RID 1.8.3
- Transport package certificate of compliance – ADR 5.1.5.2.3
- A suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- Suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- Suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- Suitable and sufficient Local Rules – IRR17 Regulation 18;
- Transport documentation – ADR 5.4;
- Security arrangements – ADR 1.10;
- Equipment on board – ADR 8.1.5.2;
- Orange coloured plate marking – ADR 5.3.2 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 INCON 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 and consent; appropriate Radiation Protection Adviser and Dangerous Goods Safety Adviser appointments; appropriate Radiation Protection Supervisor training, having Local Rules and appropriate equipment on vehicles.
A number of contraventions of specific administrative requirements against legislation were identified and discussed during the inspection, which included not having a suitable and sufficient RRA, contingency arrangements being inadequate, inconsistences on transport documents and incorrect vehicle signage.
The ONR inspector requested INCON to formally write to ONR to confirm that they would not transport radioactive material until they have produced a suitable and sufficient RRA and appropriate emergency arrangements and that relevant personnel had been suitably trained. INCON subsequently wrote to ONR on 3 November to confirm that they had ceased transport of radioactive material and would not transport radioactive material until they had received confirmation from the ONR inspector that the actions they have taken to address these deficiencies were adequate.
During the inspection, the inspector also suggested an improvement to transport practices that would be prudent for INCON to consider.
Conclusion of Intervention
INCON demonstrated that for some aspects of its operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified nine contraventions of administrative requirements against legislation and suggested one improvement. ONR discussed these non-compliances during the inspection and INCON gave a commitment to address them.
INCON voluntarily agreed to cease transport of radioactive material and is currently taking action to address the issues raised.
For this intervention, an overall IIS Rating of AMBER, below standard, was given to reflect that specific legal requirements had not been met.
The inspector used the ONR Enforcement Management Model, taking into account INCON voluntarily agreeing to halt transport of radioactive material, which for these circumstances has resulted in an enforcement letter being issued.
ONR gave INCON until 11 December 2020 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
The identified contraventions will be managed through ONR’s Issues Management arrangements.