- Site: Transport Competent Authority
- IR number: 21-003
- 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 South Tees Hospitals NHS Foundation Trust’s (ST) arrangements associated with the road transport of radioactive material. ONR carried out this inspection virtually using MS Teams on 27th 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;
- adequate Security arrangements – ADR 1.10;
- 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 ST for the safe transport of radioactive materials, including the associated arrangements for protecting workers against the effects of ionising radiation 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 having a Radiation Risk Assessment (RRA), associated Local Rules, Contingency Plans, an appointed RPA and DGSA and adequate training.
The inspector did not identify any non-compliances.
During the inspection, the inspector suggested certain improvements to transport practices that would be prudent for ST to consider.
Conclusion of Intervention
ST demonstrated that its operations met the requirements of CDG, ADR, IRR17 and REPPIR19. Based on the inspection sample, the inspector identified zero non-compliances against the relevant legislation and suggested six improvements. The inspector discussed these during the inspection.
For this intervention, the inspector gave an inspection rating of GREEN, to reflect that legal duties were complied with, although there are minor improvements that could be made to specific administrative requirements.