- Inspection date(s): 2/11/2022
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 Siemens Healthcare Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at PETNET (Nottingham Site) on 2/11/2022.
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) Transport documentation
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR
- Transport (Non-nuclear) Emergency arrangements
- Transport (Non-nuclear) Local rules Reg 18 IRR17
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17
- Transport (Non-nuclear)
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17
- Transport (Non-nuclear) Training
The inspector sampled the arrangements deployed by Siemens Healthcare 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 suitable IRR17 registration, notification & consent, appropriate local rules, contingency and emergency plans and a comprehensive set of procedures and arrangements covering all aspects of transport. The inspector identified a number of non-compliances and discussed these during the inspection, which included the Radiation Risk Assessment, DGSA report and Transport package compliance certificate.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Siemens Healthcare Limited to consider.
The inspector gave Siemens Healthcare Limited until 30th December 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.