- Site: Transport Competent Authority
- IR number: 21-008
- Date: May 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 2021 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Barts Health NHS Trust’s (BH’s) arrangements associated with the road transport of radioactive material. ONR carried out this inspection virtually using MS Teams on 25th May 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 safety advice – ADR 1.8.3 and IRR17 regulation 14;
- marking, labelling and placarding of vehicles – ADR 5.2 and 5.3
- adequate Transport Documentation – ADR 5.4;
- 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 BH 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 having the relevant registrations and consents, Radiation Risk Assessment (RRA), associated Local Rules, Contingency Plans, an appointed Radiation Protection Adviser (RPA) and Dangerous Goods Safety Adviser (DGSA). The inspector identified three non-compliances and discussed these during the inspection, which included accident scenario dose rates missing from radiation risk assessments; deficiencies in emergency arrangements and lack of a robust process to ensure package operating/maintenance requirements are implemented. The inspector identified three areas for consideration which included clarifying package certificate of conformance; contamination check records and records of carrier registration or consent.
Conclusion of Intervention
BH 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 three non-compliances with relevant legislation and three additional areas for consideration. The inspector discussed these during the inspection and BH gave a commitment to address them.
The inspector gave BH until 6 July 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 due to there being some deficiencies identified within its arrangements for compliance with legal requirements. These relate to the three areas of non-compliance identified during the inspection.
ONR will monitor the identified non-compliances through its Issues Management arrangements.