- Site: Transport Competent Authority
- IR number: 21-044
- Date: February 2022
- 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 2021 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Isospeed 7 Limited arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Isospeed 7 Limited head office in Coventry on 24th February 2022.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Suitable and sufficient Radiation Risk Assessment (RRA) – IRR17 Regulation 8;
- Suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- Local Rules and Radiation Protection Supervisor (RPS) – IRR17 Regulation 18;
- Management System – ADR 1.7.3;
- DGSA Report – ADR 1.8.3; and
- Vehicle Placards and Equipment – ADR 8.1.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We sampled the arrangements deployed by Isospeed 7 Limited 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 Local Rules, appropriate emergency arrangements, as well as appropriate equipment within vehicles.
We identified several non-compliances and discussed these during the inspection, which included the need to make improvements to the RRA, training of RPS as well as update management system.
Conclusion of Intervention
Isospeed 7 Limited demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, ONR identified two non-compliance with relevant legislation and three areas for improvement. We discussed these during the inspection and Isospeed 7 Limited gave a commitment to address them.
We gave Isospeed 7 Limited until 15th April 2022 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.