- Site: Transport Competent Authority
- IR number: 21-015
- Date: July 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 Dangerous Goods International UK Ltd.’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Heathrow site on 29 July 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;
- suitable and sufficient emergency planning in accordance with REPPIR19
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Transport Documentation – ADR 5.4;
- 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 Dangerous Goods International UK Ltd. 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 dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including conducting desktop exercises of contingency plans and seeking and responding to Dangerous Goods Safety and Radiological Protection Advice. The inspector identified no non-compliances during the inspection.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Dangerous Goods International UK Ltd. to consider.
Conclusion of Intervention
Dangerous Goods International UK Ltd. demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR, IRR17 and REPPIR19. Based on the inspection sample, the inspector identified no non-compliances with relevant legislation and suggested six improvements. The inspector discussed these during the inspection and Dangerous Goods International UK Ltd. gave a commitment to address them.
For this intervention, the inspector assigned an inspection rating of GREEN, as Dangerous Goods International UK Ltd. was found to be compliant with legal duties, although there were minor contraventions of specific administrative requirements. No significant shortfalls were identified in the delivery of safety or security functions, and there were only relatively minor, deficiencies in compliance.
Dangerous Goods International UK Ltd. has committed to consider and act upon the regulatory advice provided.
No regulatory issues were raised during this inspection.