- Site: Transport Competent Authority
- IR number: 21-019
- 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).
Interventions Carried Out by ONR
The purpose of the inspection was to review the University of Nottingham’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection virtually via Microsoft Teams on 11 August 2021.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Radiation Protection Adviser – IRR17 Regulation 14;
- Transport package compliance – ADR 5.1.5.2.3;
- 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;
- Dangerous goods transport document and related information – ADR 5.4.1;
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by the University of Nottingham for the 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 dutyholder meeting relevant good practice in reducing risk to levels that are ALARP were identified including: appropriate Health and Safety Executive (HSE) consents and registration; appropriate Radiation Protection Adviser appointments, obtaining support, training, and guidance from a Dangerous Goods Safety Adviser and having a transport RRA.
The inspector identified several non-compliances and discussed these during the inspection, which included the need to demonstrate package compliance with ADR requirements, make improvements to its RRA, produce contingency plans which cover all transport activities, test contingency plans and record consignor and consignee details on transport documentation.
Conclusion of Intervention
The University of Nottingham demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified five non-compliances with relevant legislation. The inspector discussed these during the inspection and the University of Nottingham gave a commitment to address them.
The inspector gave the University of Nottingham until 30 September 2021 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, the inspector gave an IIS Rating of GREEN to reflect that legal duties are complied with, although there were minor contraventions of specific administrative requirements.
ONR will monitor the identified non-compliances through its Issues Management arrangements.