Executive summary
Date(s) of inspection: July 2024
Aim of inspection
The purpose of the inspection was to review compliance of Ultramag Inspection Services Ltd's arrangements for class 7 radioactive material for road transport, covering consignor, carrier and consignee duties.
Subject(s) of inspection
- Transport (Non-nuclear) Appropriate management system - Rating: Amber
- 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: Green
- Transport (Non-nuclear) Emergency arrangements - Rating: Green
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements - Rating: Green
- 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: Green
- Transport (Non-nuclear) Security Plan - Rating: Green
- Transport (Non-nuclear) Sub contract arrangements - Rating: Green
- Transport (Non-nuclear) Training - Rating: Green
- Transport (Non-nuclear) Transport documentation - Rating: Amber
- Transport (Non-nuclear) Vehicle Requirements Part 8 - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The inspector reviewed a range of topics and identified a number of examples of Ultramag Inspection Sercives Ltd. ('Ultramag') meeting relevant good practice in reducing risk to levels that are as low as reasonable practicable (ALARP), including appointment of Safety Advisers and Radiation Protection Supervisors, dose records demonstrating mostly extremely low doses were received by radiation workers, adequate security arrangements and evidence of suitable training being provided.
The inspector identified seven non-compliances, however, in the opinion of the inspector, these mainly relate to adminstrative shortfalls or minor degradation of defence in depth of physical safety measures that may be readily addressed prior to any future consignment of radioactive material. These were discussed at the time of the inspection and Ultramag committed to resolve these non-compliances prior to any further consignment of radioactive material.
The inspector identified seven non-compliances, however, in the opinion of the inspector, these mainly relate to adminstrative shortfalls or minor degradation of defence in depth of physical safety measures that may be readily addressed prior to any future consignment of radioactive material. These were discussed at the time of the inspection and Ultramag committed to resolve these non-compliances prior to any further consignment of radioactive material.
Conclusion
The inspection findings were presented to Ultramag at the close of the inspection.
The inspectors judged an overall inspection rating of 'Green - no formal action' was appropriate overall for this inspection, although the six areas rated amber, due to seven specific non-compliances (two of which relate to ADR 1.7.3), will be recorded in a Level 4 Regulatory Issue.
The inspectors judged an overall inspection rating of 'Green - no formal action' was appropriate overall for this inspection, although the six areas rated amber, due to seven specific non-compliances (two of which relate to ADR 1.7.3), will be recorded in a Level 4 Regulatory Issue.
Ultramag is required to provide ONR either with evidence that the seven identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by 02 September 2024. The non-compliances will be tracked to completion via a level 4 regulatory issue.