- Site: Transport Competent Authority
- IR number: 21-034
- Date: November 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 Sunderland Royal Hospital’s (SRH) arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the hospital on 17th November 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;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Transport Documentation – ADR 5.4;
- adequate Security arrangements – ADR 1.10;
- Equipment on Board – ADR 8.1.5.2;
- 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 SRH 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. A number of examples were identified were the duty holder met relevant good practice in reducing risk to levels that are ALARP, including: a suitable radiation risk assessment, good knowledge sharing with other trusts, a comprehensive set of procedures and arrangements covering all aspects of transport; a number of in-house Radiological Protection Advisors (RPA); a clear contingency plan in accordance with IRR17 including a programme of regular testing of this plan. The inspector identified two non-compliances and these were discussed during the inspection.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for SRH to consider.
Conclusion of Intervention
SRH demonstrated that for most aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified two non-compliances with relevant legislation and suggested five improvements. The inspector discussed the non compliances during the inspection and SRH gave a commitment to address the issues.
The inspector gave SRH until 17th December to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an overall IIS Rating of GREEN is given to reflect that Legal duties were complied with, although there were minor contraventions of specific administrative requirements.
ONR will monitor the identified contraventions through its Issues Management arrangements.