- Site: Transport Competent Authority
- IR number: 21-013
- 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 Frazer Nash NDT’s (FN) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at FN’s Manchester premises listed above on 5th 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;
- 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 FN 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 a suitable and sufficient Transport Radiation Risk Assessment (RRA), associated Local Rules, Security Plans, Contingency Plans, rehearsal of contingency plans and consideration of an emergency plan in accordance with CDG09. This was sufficient evidence for the inspector to rate the inspection as ‘Green’ representing a good standard.
The inspector identified two administrative non-compliances whereby FN did not have a current contract with an RPA and a DGSA. FN indicated that it had deliberately allowed these contracts to expire during COVID restrictions and has plans to renew them before it commences transporting radioactive material once more.
During the inspection, the inspector also suggested minor improvements to transport practices that would be prudent for FN to consider.
Conclusion of Intervention
FN 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 two administrative non-compliances with relevant legislation and suggested four improvements. The inspector discussed these during the inspection and FN gave a commitment to address them before it starts to transport radioactive material once more. FN where unsure when it would transport radioactive material once again so ONR has not imposed a deadline for FN to renew its contract with its RPA and DGSA.
For this intervention, the inspector gave an inspection rating of GREEN reflecting that legal duties were complied with, although there were minor contraventions of specific administrative requirements.
The inspector gave FN until 30th July to provide ONR with a statement confirming that no transport activity will take place until both an RPA and DGSA have been formally appointed.
ONR will monitor the identified contraventions / non-compliances through its Issues Management arrangements.