- Site: Transport Competent Authority
- IR number: 21-030
- Date: October 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 Nottingham University Hospitals NHS Trust (NUH) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Queens Medical Centre Campus site on 29 October 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
- 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 NUH 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 dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including appropriate Health and Safety Executive (HSE) consents and registration; obtaining support, training, and guidance from a Dangerous Goods Safety Adviser and having a transport RRA. The inspector identified six non-compliances and discussed these during the inspection, which included the need to make improvements to the Radiation Risk Assessment (RRA), produce an Emergency Plan (if the RRA identifies the need); test contingency plans and if necessary, emergency plans; ensure that any lessons from transport related incidents are learned and absorbed into relevant documentation.
Conclusion of Intervention
NUH demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR19, IRR17 and REPPIR19. Based on the inspection sample, the inspector identified six non-compliances with relevant legislation. The inspector discussed these during the inspection and NUH gave a commitment to address them.
The inspector gave NUH until 29th November 2021 to provide ONR with an appropriate resolution plan with timescales for completion.
For this intervention, the inspector assigned an inspection rating of AMBER, due to there being significant shortfall against an identified relevant good practice when compared with appropriate benchmarks.
ONR will monitor the identified non-compliances through its Issues Management arrangements.