- Site:Transport Competent Authority
- IR number: 22-001
- Date: April 2022
- LC numbers: N/A
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 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 the University of Manchester’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the university’s Oxford Road premises on 6 April 2022.
Interventions Carried Out by ONR
The chosen inspection sample included:
- notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Radiation Protection Adviser – IRR17 Regulation 14;
- Dangerous Goods Safety Adviser (DGSA) Report – ADR 1.8.3;
- Transport package compliance – ADR 184.108.40.206.3;
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- A suitable and sufficient management system – ADR 1.7.3;
- Dangerous goods transport document and related information – ADR 5.4.1.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by the University of Manchester 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).
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. The dutyholder demonstrated appropriate HSE consents and registration.
The inspector identified several non-compliances and discussed these during the inspection, which included the need to ensure appropriate Radiation Protection Adviser appointments for clinical activities, produce suitable and sufficient transport RRAs to cover all consignments of excepted and Type A packages, demonstrate excepted and Type A package compliance with ADR requirements, produce appropriate emergency arrangements to cover all transport activities, test emergency arrangements, arrange for an annual DGSA report to be produced and ensure transport procedures past their review dates are reviewed and reissued within the university’s management system.
The ONR inspector requested the University of Manchester to formally write to ONR to confirm that it would not transport radioactive material until it has addressed the identified non-compliances. The University of Manchester subsequently wrote to ONR on 6 April to confirm that it had ceased transport of radioactive material and would not transport radioactive material until it had received confirmation from the ONR inspector that the actions taken to address these deficiencies were adequate.
During the inspection, the inspector also suggested an improvement to transport practices that would be prudent for the University of Manchester to consider.
Conclusion of Intervention
Based on the inspection sample, the inspector identified six areas where contraventions of administrative requirements against legislation had occurred and suggested one improvement. ONR discussed these non-compliances during the inspection and the University of Manchester gave a commitment to address them.
The University of Manchester voluntarily agreed to cease transport of radioactive material and is currently taking action to address the issues raised.
For this intervention, an overall IIS Rating of RED – Demand improvement, was given to reflect that specific legal requirements had not been met.
The inspector adhered to ONR’s Enforcement Policy Statement, taking into account the University of Manchester voluntarily agreeing to halt transport of radioactive material to inform appropriate enforcement action, which in this instance was issue of a Prohibition Notice.
ONR gave the University of Manchester until 27 May 2022 to provide ONR either with evidence that the findings of this inspection have been resolved, or an appropriate fully resourced resolution plan with timescales for completion.
The identified contraventions will be managed through ONR’s Issues Management arrangements.