- Site: Transport Competent Authority
- IR number: 22-012
- Date: August 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 Bradford Teaching Hospitals NHS Foundation Trust arrangements associated with the road transport of radioactive material. ONR carried out this inspection virtually on 3 August 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;
- Restriction of Exposure – IRR17 Regulation 9;
- 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;
- Dangerous Goods Safety Adviser (DGSA) Report – ADR 1.8.3:
- Transport Package Certificate of Compliance – ADR 18.104.22.168.3;
- Packaging and labelling – ADR 5.2 and
- 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 implemented by Bradford Teaching Hospitals NHS Foundation Trust 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 HSE notification, registration & consent, suitable DGSA report and adequate: management systems, Local Rules, Contingency plans, transport documentation, package, labelling and certificates.
The inspector identified a non-compliance and discussed this during the inspection, which related to a need to make improvements to the Radiation Risk Assessment.
Conclusion of Intervention
Bradford Teaching Hospitals NHS Foundation Trust 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 one area of non-compliance with relevant legislation. The inspector discussed this during the inspection and Bradford Teaching Hospitals NHS Foundation Trust gave a commitment to address this.
The inspector gave Bradford Teaching Hospitals NHS Foundation Trust until 16 September 2022 to provide ONR either with evidence that the finding 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.