- Site: Transport Competent Authority
- IR number: 21-045
- Date: March 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 Betsi Cadwaladr University Health Board arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Glan Clwyd Hospital on 3rd March 2022.
The inspection team 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;
- 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;
- Dangerous Goods Safety Adviser (DGSA Report) – ADR 1.8.3:
- Transport Package Certificate of Compliance – ADR 5.1.5.2.3;
- Training – ADR 5.2;
- Orange-coloured plate marking – ADR 5.3.2;
- Dangerous goods transport document and related information – ADR 5.4;
- Equipment on Board – ADR 8.1.5.2; and
- Fire-fighting equipment – ADR 8.4.1.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We sampled the arrangements deployed by Betsi Cadwaladr University Health Board 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 & consent; appropriate RRA, appropriate Local Rules, appropriate management system arrangements, appropriate training 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 contingency plans, transport compliance certificates as well as transport documentation.
Conclusion of Intervention
Betsi Cadwaladr University Health Board demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, ONR identified five areas of non-compliances with relevant legislation and three areas for improvement. We discussed these during the inspection and Betsi Cadwaladr University Health Board gave a commitment to address them.
We gave Betsi Cadwaladr University Health Board until 22nd 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 Green was given to reflect that there were minor contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.