- Site: Transport Competent Authority
- IR number: 21-005
- 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) 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 Place 2 Place logistics Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at a COVID-19 secure venue near to Place 2 Place logistics Limited’s premises on 12 May 2021.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Registration and Consent – IRR17 Regulations 6 and 7;
- Radiation protection adviser – IRR17 Regulation 14;
- Safety Adviser – RID 1.8.3
- Equipment on Board – ADR 8.1.5.2;
- Orange coloured plate marking – ADR 5.3.2;
- 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;
- Local Rules and Radiation Protection Supervisors – IRR17 Regulation 18;
- Driver training – ADR 8.2;
- Unauthorised access to vehicles – CDG Regulation 8; 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 Place 2 Place Logistics Limited 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: having appropriate registration, having an RRA and emergency plan, having appropriate Radiation Protection Adviser and Dangerous Goods Safety Adviser appointments and having the correct equipment on board vehicles and vehicle markings.
A number of contraventions of specific administrative requirements against legislation were identified and discussed during the inspection, which included formal appointment of Radiation Protection Supervisors, the need to further update the RRA to address specific issues such as the safe transfer of packages between vehicles and justification for the frequency of contamination monitoring of vehicles, the need to further update the emergency plan and ensure training of personnel in the plan is undertaken and the plan is tested, the need to ensure drivers are appropriately trained before undertaking solo transport activities and the need to incorporate transport documentation within a management system.
During the inspection it was identified that a specific incident associated with failure of a vehicle door locking mechanism was required to be reported to ONR and a report of lessons learned and actions to be taken to prevent a recurrence was required to be produced.
Conclusion of Intervention
Place 2 Place Logistics Limited demonstrated that for the aspects of its transport operations inspected it broadly met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified 6 contraventions of administrative requirements against legislation and requested a specific incident be reported to ONR. ONR discussed these non-compliances and the incident report during the inspection and Place 2 Place Logistics Limited gave a commitment to address them.
During the inspection, the inspector also suggested an improvement to transport practices that would be prudent for Place 2 Place Logistics Limited to consider.
ONR gave Place 2 Place Logistics Limited until 30 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, an overall IIS Rating of AMBER was given to reflect there were contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.