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: Green
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR - Rating: Green
- Transport (Non-nuclear) Emergency arrangements - Rating: Amber
- Transport (Non-nuclear) Local rules Reg 18 IRR17 - Rating: Amber
- 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: 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 inspectors 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 & consent, Radiation Protection Adviser (RPA) appointment letter, contingency plan and a comprehensive set of procedures and arrangements covering all aspects of transport.
The inspectors identified areas of non-compliance which were radiation emergency plan, local rules and security plan, these were discussed during the inspection. The inspectors also identified a non-compliance in relation to radiation risk assessment, whereby an enforcement letter has been issued.
Conclusion
The inspection findings were presented to Applied Inspection Ltd at the close of the inspection.
We judged an overall inspection rating of amber was appropriate for this inspection.
We adhered to ONR’s Enforcement Management Model, which in this instance was issue of an enforcement letter due to non-compliance in relation to radiation risk assessment. Applied Inspection Ltd are required to provide to ONR evidence that the identified non-compliance has been resolved by the 27 October 2023. The non-compliance will be tracked to completion via a level 3 Regulatory Issue.
Applied Inspection Ltd is required to provide to ONR either with evidence that the other identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 27 October 2023. These non-compliance will be tracked to completion via a level 4 Regulatory Issue.