Executive summary
Date(s) of inspection
- November 2023
Aim of inspection
The purpose of the inspection was to review compliance of the dutyholder’s arrangements for class 7 radioactive material for road 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: Green
- Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17 – Rating: Not rated
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements – Rating: Not rated
- Transport (Non-nuclear) Local rules Reg 18 IRR17 – Rating: Not rated
- 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) 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 reviewed a range of topics and identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including Radiation Awareness and ADR Training, appointment of Safety Advisers, Transport Documentation, Procedures Supporting Carriage, Vehicle Signage and Equipment, Transport Management System, and Training.
The inspector identified two areas of non-compliance and discussed these during the inspection. These were associated with the Radiation Risk Assessment and Contingency Plans.
Conclusion
The inspection findings were presented to Stericycle.
The inspector judged an overall rating of Green was appropriate for this inspection as legal duties were complied with, though there were minor contraventions of specific administrative requirements.
By the 17 January 2024, Stericycle is required to provide ONR either with either evidence that the remaining non-compliances have been resolved, or that an appropriate resolution plan with timescales for completion has been developed.
Resolution of the non-compliances will be tracked via a Level 4 regulatory issue.