- Site: Transport Competent Authority
- IR number: 21-042
- 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 One Stop Testing Equipment Ltd.’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Hemel Hempstead site on 22 February 2022.
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
- 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; 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 One Stop Testing Equipment Ltd. 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 duty-holder meeting relevant good practice in reducing risk to levels that are ALARP, including adequate security arrangements and measures to reduce exposure to radiation. The inspector identified a number of non-compliances and discussed these during the inspection, which included timely provision of training and professional advice and adequacy of contingency plans.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for One Stop Testing Equipment Ltd. to consider.
Conclusion of Intervention
One Stop Testing Equipment Ltd. demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR, IRR17 and REPPIR19. Based on the inspection sample, the inspector identified four non-compliances with relevant legislation and suggested two improvements. The inspector discussed these during the inspection and One Stop Testing Equipment Ltd. gave a commitment to address them.
The inspector gave One Stop Testing Equipment Ltd. until 05 April 2022 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, the inspector assigned an inspection rating of GREEN, due to the legal duties being complied with, although there were minor contraventions of specific administrative requirements.
ONR will monitor the identified non-compliances through its Issues Management arrangements.