- Site: Transport Competent Authority
- IR number: 21-025
- Date: September 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 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 2021 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Cardiff University PETIC’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the University Hospital Wales, Cardiff site on 28 September 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;
- 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 Cardiff University PETIC 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 several examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including suitable and sufficient radiation risk assessments and emergency arrangements. Training and general radiation awareness was well managed and the use of the organisations QPulse system for document control and review met ONRs expectations.
During the inspection, the inspector also suggested certain minor improvements to transport practices that would be prudent for Cardiff University PETIC to consider.
Conclusion of Intervention
Cardiff University PETIC 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 but suggested four improvements. The inspector discussed these during the inspection and Cardiff University PETIC gave a commitment to address them.
For this intervention, the inspector assigned an inspection rating of GREEN, due to relevant good practice being generally met when compared with appropriate benchmarks and legal duties complied with.