- Site: Transport Competent Authority
- Inspection ID: 51956
- 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 United Kingdom Health Security Agency arrangements associated with the road transport of radioactive material. ONR carried out this inspection at United Kingdom Health Security Agency facility in Leeds on 24 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;
- Management System – ADR 1.7.3;
- Transport Marking and Labelling – ADR 220.127.116.11.1;
- Dangerous goods transport document and related information – ADR 18.104.22.168.2;
- Handling and Storage – ADR 7.5.7;
- Document to be carried on the transport unit – ADR 8.1.2;
- Fire- fighting equipment – ADR 8.1.4; and
- Training – ADR 8.2.3.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by United Kingdom Health Security Agency 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 ALARP were identified including: a suitable radiation risk assessment, a comprehensive set of procedures and arrangements covering all aspects of transport; having a radiological protection advisor, a contingency plan in accordance with IRR17 including a programme of regular testing of this plan. The inspector did not identify any non-compliances during the inspection.
During the inspection, the inspector suggested three improvements to transport practices that would be prudent for United Kingdom Health Security Agency to consider.
Conclusion of Intervention
United Kingdom Health Security Agency demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector did not identify any non-compliances with relevant legislation and suggested three improvements.
For this intervention an IIS Rating of Green was given to reflect that Legal duties were complied with.