- Site: Transport Competent Authority
- IR number: 21-022
- Date: September 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation is the Great Britain Competent Authority for the civil inland surface transport of Class 7 (radioactive material) dangerous goods. This statutory duty is given to ONR through the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations. ONR also acts on behalf of other civilian United Kingdom Competent Authorities in cases where Competent Authority approval of a package of material design is required by sea and air.
Applied Sterilisation Technologies have applied to ONR for approval of the new transport package design ‘DPR-200’ for road, rail, sea and air. A new package is required to transport the sources and Applied Sterilisation Technologies have designed, manufactured and mechanically tested a prototype package. The packages will be manufactured by Stainless Metalcraft Ltd.
ADR/RID § 1.7.3 requires duty holders to establish a Management System that is acceptable to the Competent Authority. The purpose of this inspection is to confirm Stainless Metalcraft Ltd.’s management arrangements in relation to the manufacture of packages.
Interventions Carried Out by ONR
On September 7th 2021, ONR inspectors carried out a planned inspection of Stainless Metalcraft Ltd. The inspection focused on the manufacturer’s management arrangements.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection; therefore, no judgement has been made to the adequacy of safety systems.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Four thematic areas were considered in relation to SML’s transport arrangements: Management Systems, Package Manufacture & Supply Chain, Management & Control of Transport Interfaces, and Training & Competence.
Stainless Metalcraft Ltd.’s management system is in a paper-based format. Based on a sample of documents and discussions with the Stainless Metalcraft Ltd. project lead, ONR Inspectors are satisfied that the management system is being adequately implemented.
Stainless Metalcraft Ltd. stated that they use a select number of subcontractors who have previously completed work for Stainless Metalcraft Ltd. and are familiar with the requirements and processes. A ‘Graded Approach’ is used for further selection of subcontractors who have not previously completed work for Stainless Metalcraft Ltd. ONR inspectors are content that Stainless Metalcraft Ltd. have adequate processes for managing the supply chain.
A sample of the Lifetime Quality Management system and generic Lifetime Quality Records were taken, and it was noted that the records were clearly signed and approved in accordance with Stainless Metalcraft Ltd. processes. ONR inspectors are content that Stainless Metalcraft Ltd. are adhering to their management system practices and audit control.
Stainless Metalcraft Ltd. provided an overview of their training procedures and apprentice training scheme. A Non-Destructive Testing Operator Skills Matrix was sampled which clearly indicated who was qualified in which inspection method, to what level, and when the training was valid until. ONR inspectors are satisfied that Stainless Metalcraft Ltd. have adequate training arrangements.
Conclusion of Intervention
Based on evidence sampled, it is judged that Stainless Metalcraft Ltd. has an adequate management system for the transport of radioactive material as defined in the applicable transport regulations.
There were no significant matters identified that might adversely impact nuclear safety and the inspection rating was GREEN (no formal action required).