- Site: Transport Competent Authority
- IR number: 21-002
- Date: April 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) 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 used ADR 2019 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Compass Contract Services UK Limited’s (Compass) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Whiston Hospital site on 22 April 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, 1.10.2, 8.2 and 8.5;
- adequate safety advice – ADR 1.8.3 and IRR17 regulation 14;
- adequate transport documentation – ADR 5.4;
- marking, labelling and placarding of vehicles – ADR 5.2 and 5.3
- 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 Compass 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 a number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP, including a suitable contingency plan as required by IRR17 regulation 13, dose monitoring and training of employees, appropriate appointment of and advice from safety advisors (RPA and DGSA), suitable equipment on board the vehicle and adequate security arrangements. The inspector identified a number of non-compliances and discussed these during the inspection, which included not having an appropriate registration under IRR17, not having a suitable and sufficient RRA, no appointment of radiation protection supervisors, deficiencies in the content of local rules and transport documents, not displaying vehicle signage (orange-coloured plates) correctly.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Compass to consider.
Conclusion of Intervention
Compass 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 one improvement. The inspector discussed these during the inspection and Compass gave a commitment to address them.
The inspector gave Compass until 4 June 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 AMBER to reflect that there were contraventions of specific administrative requirements.
Company Name has already taken action to address the non-compliance(s) regarding registration covering its transport operations and has now obtained the correct registration from The Health and Safety Executive (HSE).
ONR will monitor the identified non-compliances through its Issues Management arrangements.