- Site: Transport Competent Authority
- IR number: 22-007
- Date: July 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 Medway NHS Foundation Trust’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Gillingham, Kent site on 15 July 2022.
Interventions Carried Out by ONR
The chosen inspection sample included:
- notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- 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;
- suitable and sufficient emergency planning in accordance with REPPIR19
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Transport Documentation – ADR 5.4;
- adequate Security arrangements – ADR 1.10;
- Equipment on Board – ADR 126.96.36.199; and
- a suitable and sufficient Management System – ADR 1.7.3.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Medway NHS Foundation Trust for the safe 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 inspector identified two examples of the duty-holder meeting relevant good practice in reducing risk to levels that are ALARP, including deployment of continuous radiation monitoring in receipt/ storage areas, and testing/ rehearsing contingency plans. The inspector identified two non-compliances and discussed these during the inspection, which included inadequate evidence of required training being delivered, and evidence of packagings being used outside of their required maintenance intervals.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Medway NHS Foundation Trust to consider.
Conclusion of Intervention
Medway NHS Foundation Trust demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR, IRR17 and REPPIR19. Based on the inspection sample, the inspector identified two non-compliances with relevant legislation and suggested three improvements. The inspector discussed these during the inspection and Medway NHS Foundation Trust gave a commitment to address them.
The inspector gave Medway NHS Foundation Trust until 26 August 2022 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, the inspector assigned an inspection rating of AMBER, as the apparent absence of adequate training being delivered is considered by the inspector to be a significant shortfall against an identified relevant good practice when compared with appropriate benchmarks, and a systematic failure to comply with administrative legal requirements.
ONR will monitor the identified non-compliances through its Regulatory Issues Management arrangements.