- Site: Transport Competent Authority
- IR number: 20-041
- Date: January 2021
- 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 the North Tees and Hartlepool NHS Foundation Trust’s arrangements associated with the road transport of radioactive material. ONR carried out this remote inspection via Microsoft Teams on 26 January 2021.
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;
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by North Tees and Hartlepool NHS Foundation Trust 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. The inspector identified that the duty holder’s arrangements predominantly met relevant good practice in reducing risk to levels that are ALARP, including the majority of its radiation risk assessment, its local rules for designated areas, contingency plans and DGSA reporting and management of findings. The inspector identified a minor non-compliance and discussed this during the inspection, which concerned an element of its radiation risk assessment and subsequent arrangements.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for North Tees and Hartlepool NHS Foundation Trust to consider.
Conclusion of Intervention
North Tees and Hartlepool NHS Foundation Trust demonstrated that for most aspects of its operations that were sampled it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified one finding consisting of a minor non-compliance with relevant legislation and suggested four improvements. The inspector discussed these during the inspection and North Tees and Hartlepool NHS Foundation Trust gave a commitment to address the non-compliance and consider the improvements.
The inspector gave North Tees and Hartlepool NHS Foundation Trust until 9 March 2021 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, the inspector gave an inspection rating of GREEN, due to there being only a relatively minor deficiency found in its compliance arrangements.
ONR will monitor the identified non-compliance through its Issues Management arrangements.