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Circle Express Limited, Transport compliance inspection

  • Site: Transport Competent Authority
  • IR number: 21-020
  • Date: August 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 Circle Express Ltd’s arrangements associated with the road transport of radioactive material. This was a follow up inspection to discuss updates to the company’s radiation risk assessment as required by ONR’s previous inspection on 24 Feb 2021 (ONR-TD-IR-20-050).

ONR carried out this inspection at the Heathrow site on 16 August 2021.

Interventions Carried Out by ONR

The chosen inspection sample included:

  • 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;

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The inspector concentrated on the radiation risk assessment produced by Circle Express 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 that the radiation risk assessment was still not suitable and sufficient and was lacking key information and appropriate evidence. A range of specific points were identified and discussed in detail with the dutyholder and their RPA specialist.

During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Circle Express Ltd. to consider.

Conclusion of Intervention

 Circle Express Ltd. 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 one non-compliance with relevant legislation and suggested two improvements. The inspector discussed these during the inspection and Circle Express Ltd. gave a commitment to address them.

The inspector gave Circle Express Ltd. until 20 Sept 2021 to provide ONR either with evidence that the findings have been resolved, as this was a follow up inspection the dutyholder was informed that this date was fixed and would not be extended without good reason.

For this intervention, the inspector assigned an inspection rating of AMBER, due to there being a significant shortfall against an identified relevant good practice when compared with appropriate benchmarks.

ONR will monitor the identified contraventions / non-compliances through its Issues Management arrangements.