Executive summary
Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review compliance of the dutyholder’s arrangements for class 7 radioactive material for road and/or rail transport.
Subject(s) of inspection
- Transport (Non-nuclear) Appropriate management system - Rating: Green
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13 - Rating: Amber
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR - Rating: Amber
- Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17 - Rating: Not rated
- Transport (Non-nuclear) Emergency arrangements - Rating: Amber
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements - Rating: Not rated
- Transport (Non-nuclear) Local rules Reg 18 IRR17 - Rating: Green
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17 - Rating: Green
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17 - Rating: Amber
- Transport (Non-nuclear) Security Plan - Rating: Not rated
- Transport (Non-nuclear) Sub contract arrangements - Rating: Green
- Transport (Non-nuclear) Training - Rating: Green
- Transport (Non-nuclear) Transport documentation - Rating: Green
- Transport (Non-nuclear) Vehicle Requirements Part 8 - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspector identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including suitable IRR17 registration, notification and consent, RPA appointment letter, transport documentation, appropriate management system, appropriate training and vehicle compliance.
The inspector identified five areas of non-compliances and discussed these during the inspection. These were the radiation risk assessment, contingency plans, emergency arrangements, local rules and Dangerous Goods Safety Advisors annual safety report.
Conclusion
The inspection findings were presented to EBH at the close of the inspection.
I judged an overall inspection rating of amber was appropriate for this inspection.
EBH is required to provide ONR either with evidence that the five identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 7th July 2023. The non-compliances will be tracked to completion via a level 4 regulatory issue.