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).
Purpose of Intervention
The purpose of the inspection was to review High Technology Sources Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at High Technology Sources Limited (Barrow Site) on 11/10/2022.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Transport (Non-nuclear) Appropriate management system
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13
- Transport (Non-nuclear) Emergency arrangements
- Transport (Non-nuclear) Local rules Reg 18 IRR17
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by High Technology Sources Limited 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.
The inspector identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including Radiation Risk Assessment, Local Rules, Radiation Awareness Training, Security plans and Transport Documentation. The inspector identified a number of non-compliances and discussed these during the inspection, which included updates to DGSA appointment recording, issuing of certificates to drivers for in house training and use of magnetic orange plates.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for High Technology Sources Limited to consider.
Conclusion of Intervention
The inspector gave High Technology Sources Limited until 25/11/2022 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
ONR will monitor the identified non-compliances through its Issues Management arrangements.