- Site: Transport Competent Authority
- IR number: 22-013
- 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 Celtest’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the above premises on 24th August 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;
- 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 220.127.116.11; 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 Celtest 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. A number of examples were identified were the duty holder met relevant good practice in reducing risk to levels that are ALARP, including: having a comprehensive set of procedures and arrangements covering all aspects of transport; having a comprehensive radiation risk assessment, emergency procedures, testing emergency arrangements regularly and ensuring that adequate contamination monitoring of packages takes place. I identified three non compliances because Celtest were unable to articulate whether or not an emergency plan is required in accordance with CDG regulations, current instructions in writing were not carried in the vehicle and a current DGSA annual report was not available. These were all discussed in detail during the inspection.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Celtest to consider.
Conclusion of intervention
Celtest demonstrated that for most aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified three non-compliances with relevant legislation and suggested two improvements. The inspector discussed these during the inspection and a commitment was obtained from Celtest to address the non-compliance.
Celtest was given until 28th October 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, an overall IIS Rating of GREEN is given to reflect that Legal duties were generally complied with, although there was some minor contraventions of specific administrative requirements.
The non-compliances will be managed through ONR’s Issues Management arrangements.