- Site: Transport Competent Authority
- IR number: 21-027
- 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 Radiation Protection Services Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Radiation Protection Services Ltd’s Dunston Road premises on 28th October 2021.
The inspection team of Nicola Jaynes and Paul Butler will be referred to as ‘we’ or ‘our’ throughout the body of this report.
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;
- Local Rules and Radiation Protection Supervisors (RPS) – IRR17 Regulation 18;
- 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 5.1.5.4.2 and
- Fire-fighting equipment – ADR 8.1.4
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We sampled the arrangements deployed by Radiation Protection Services Ltd 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).
We 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 as low as reasonably practicable were identified including: appropriate HSE registration; appropriate Radiation Protection Adviser appointment, appropriate transport documentation, having a transport RRA and having a contingency plan.
We identified several non-compliances and discussed these during the inspection, which included the need to demonstrate package compliance with ADR requirements, make improvements to the RRA, make improvements to the contingency plan to cover all transport activities, test the contingency plan and have appropriate fire-fighting equipment on the transport vehicle.
Conclusion of Intervention
Radiation Protection Services Ltd demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, ONR identified four non-compliances with relevant legislation. We discussed these during the inspection and Radiation Protection Services Ltd gave a commitment to address them.
We gave Radiation Protection Services Ltd until 17th December 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 an IIS Rating of AMBER was given to reflect that there were contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.