- Site:Transport Competent Authority
- IR number: 22-004
- Date: May 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 Dermal Technology Laboratory Limited arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Dermal Technology Laboratory Limited facility in Keele on 24 May 2022.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Suitable and sufficient Radiation Risk Assessment (RRA) – IRR17 Regulation 8;
- Suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- Radiation Protection Adviser – IRR17 Regulation 14;
- Local Rules and Radiation Protection Supervisor (RPS) – IRR17 Regulation 18;
- Management System – ADR 1.7.3;
- Transport Marking and Labelling – ADR 184.108.40.206.1, and
- Dangerous goods transport document and related information – ADR 220.127.116.11.2.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Dermal Technology Laboratory Limited 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. A number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are as low as reasonably practicable were identified including: appropriate local rules, appropriate management system arrangements, appropriate transport documentation and appropriate packaging and labelling.
The inspector identified several non-compliances and discussed these during the inspection, which included the need to make improvements to the IRR17 registration, notification & consent, Radiological Risk Assessment, Radiation Protection Adviser appointment in writing as well as emergency arrangements and contingency plans.
Conclusion of Intervention
Dermal Technology Laboratory Limited demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified four areas of non-compliances with relevant legislation. The inspector discussed these during the inspection and Dermal Technology Laboratory Limited gave a commitment to address them.
The inspector gave Dermal Technology Laboratory Limited until 22 July 2022 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention an IIS Rating of Amber was given to reflect that there were contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.