- Site: Transport Competent Authority
- IR number: 22-006
- Date: June 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 Lubbers UK Limited arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Lubbers UK Limited facility in Cramlington on 7th June 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;
- Local Rules and Radiation Protection Supervisor (RPS) – IRR17 Regulation 18;
- Management system – ADR 1.7.3;
- Dangerous Goods Safety Adviser (DGSA) report – ADR 1.8.3;
- Security plan – ADR 18.104.22.168;
- Placarding and orange-coloured plate marking – ADR 5.3;
- Dangerous goods transport document and related information – ADR 5.4.1;
- Handling and storage – ADR 7.5.7;
- Equipment on board – ADR 22.214.171.124; and
- Driver training – ADR 8.2.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Lubbers UK 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: IRR17 registration, notification & consent, appropriate local rules, appropriate management system arrangements, DGSA report, security plan, appropriate placarding of vehicles, appropriate transport documentation, driver training, handling and storage and appropriate vehicle equipment.
The inspector identified several non-compliances and discussed these during the inspection, which included the need to make improvements to the Radiological Risk Assessment as well as emergency arrangements.
Conclusion of Intervention
Lubbers UK 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 two areas of non-compliances with relevant legislation. The inspector discussed these during the inspection and Lubbers UK Limited gave a commitment to address them.
The inspector gave Lubbers UK Limited until 29th 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 Green was given to reflect that there were minor contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.