- Site: Transport Competent Authority
- Inspection ID: 51834
- 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 chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Radiation Protection Adviser – IRR17 Regulation 14;
- Dangerous Goods Safety Adviser – ADR 1.8.3;
- Radiation Protection Supervisors – IRR17 Regulation 18;
- Transport package certificate of compliance – ADR 220.127.116.11.3;
- 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;
- Dangerous Goods Safety Adviser (DGSA) Report – ADR 18.104.22.168;
- Suitable and sufficient Local Rules – IRR17 Regulation 18;
- Transport documentation – ADR 5.4;
- Equipment on board – ADR 22.214.171.124;
- Orange coloured plate marking – ADR 5.3.2; and
- A suitable and sufficient management system – ADR 1.7.3.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspectors sampled the arrangements deployed by STH for the transport of radioactive material, including the associated arrangements for protecting workers against the effects of ionising radiations and reducing risks as low as reasonably practicable (ALARP).
The inspectors 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; having appropriate HSE consents and registration, Radiation Protection Adviser, Dangerous Goods Safety Adviser and Radiation Protection Supervisor appointments, transport contingency plans, Local Rules, vehicle equipment and signage, transport documents and a management system.
The inspectors identified three non-compliances and discussed these during the inspection; the need to revise the transport RRA, carry out contingency plan rehearsals and to confirm modifications made to an approved type A package to allow it to transport lead pots.
During the inspection, the inspectors also suggested certain improvements to transport practices that would be prudent for STH to consider.
Conclusion of Intervention
STH demonstrated that for most aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspectors identified three non-compliances with relevant legislation and suggested four improvements. The inspectors discussed these during the inspection and STH gave a commitment to address them.
The inspectors gave STH until 7 October 2022 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.
ONR will monitor the identified non-compliances through its Issues Management arrangements.
For this intervention, the inspectors gave an overall IIS Rating of GREEN to reflect that legal duties are generally complied with, although there were contraventions of specific administrative requirements.