- Site: Transport Competent Authority
- IR number: 21-017
- 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 Leonardo Helicopters (LH) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at LH’s Yeovil premises listed above on 10th August 2021. The inspection was also attended by LH’s third party carrier, Kuehhe and Nagel (KN) who have a facility on this site and are responsible for all carriage of radioactive material.
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 LH 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) albeit prepared by KN, associated Local Rules, Security Plans, Contingency Plans, rehearsal of contingency plans.
Transport undertaken by LH is minimal and involves only a small number of excepted packages with low dose rates. Furthermore, the devices transported are now being phased out with only a few legacy devices transported on an irregular basis each year. There was sufficient evidence presented to the inspector to rate the inspection as ‘Green’ representing a good standard.
The inspector did not identify any non-compliances against mandatory requirements. During the inspection, the inspector suggested three minor improvements to transport practices that would be prudent for LH and KN to consider.
Conclusion of Intervention
LH demonstrated that for all aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector did not identify any non-compliances with relevant legislation and suggested three improvements.
For this intervention, the inspector gave an inspection rating of GREEN reflecting that legal duties were complied with.