- Site: Transport Competent Authority
- Inspection ID: 51783
- Date: September 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 Place 2 Place Logistics Limited arrangements associated with the road transport of radioactive material. ONR carried out this inspection on 9th September 2022 at their facility.
The inspection team will be referred to as ‘we’ or ‘our’ throughout the body of this report.
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;
- Security Training – ADR 1.10.2;
- Placarding – ADR 5.2
- Dangerous goods transport document and related information – ADR 5.4.1;
- Handling and storage – ADR 7.5.7;
- Fire-fighting equipment – ADR 8.1.4;
- Equipment on Board – ADR 184.108.40.206, and
- Driver Training – ADR 8.2.
Key Findings, inspector’s opinions and reasons for judgements made
We sampled the arrangements deployed by Place 2 Place Logistics Limited 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).
We 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: suitable IRR17 registration, notification and consent, appropriate local rules and a comprehensive set of procedures and arrangements covering all aspects of transport.
We identified several non-compliances and discussed these during the inspection, which included the need to make improvements to the Radiation Risk Assessment, Restriction of Exposure as well as an adequate Emergency Plan.
Conclusion of intervention
Place 2 Place Logistics Limited demonstrated that for aspects of its transport operations it met the requirements of ADR and IRR17.
Based on the inspection sample, we identified three areas of non-compliances with relevant legislation as well as three areas for improvement. We discussed these during the inspection and Place 2 Place Logistics Limited gave a commitment to address them.
We gave Place 2 Place Logistics Limited until 28th October 2022 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention an IIS Rating of Red – demand improvement was given to reflect that specific legal requirements had not been met.
We adhered to ONR’s Enforcement Policy Statement, which in this instance was issue of an Improvement Notice for the lack of an Emergency plan, as required by Schedule 2, paragraph 3 of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.
The identified contraventions will be managed through ONR’s Issues Management arrangements.