- Site: Transport Competent Authority
- IR number: 21-028
- 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 University Hospitals of Leicester NHS Trust’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Leicester Royal Infirmary site on 23rd Nov 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; and
- 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 University Hospitals of Leicester NHS Trust 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 a suitable radiation risk assessment and associated contingency plans. The security and training of personal with regards to transport operations were appropriate. The trust has an electronic document management system that is acceptable. The inspector identified a possible non-compliance with a derogation which will be followed up with the supplier for the item in question in the first instance.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for University Hospitals of Leicester NHS Trust to consider.
Conclusion of Intervention
University Hospitals of Leicester NHS Trust demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified no non-compliances with relevant legislation and suggested five improvements. The inspector discussed these during the inspection and University Hospitals of Leicester NHS Trust gave a commitment to address them.
For this intervention, the inspector assigned an inspection rating of GREEN, due to there being only relatively minor, deficiencies in compliance arrangements.