Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review NHS Greater Glasgow and Clyde’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at NHS Greater Glasgow and Clyde (Site) on 16/11/2022.
Subject(s) of inspection
The chosen inspection sample included:
- Transport (Non-nuclear)
- Transport (Non-nuclear) Local rules Reg 18 IRR17
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17
- Transport (Non-nuclear) Training
- Transport (Non-nuclear) Vehicle Requirements Part 8
- Transport (Non-nuclear) Appropriate management system
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR
- Transport (Non-nuclear) Emergency arrangements
- Overall Inspection Rating
Key findings, inspector’s opinions and reasons for judgements made
The inspector sampled the arrangements deployed by NHS Greater Glasgow and Clyde 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, RPA appointment letter and a comprehensive set of procedures and arrangements covering all aspects of transport. The inspector identified non-compliances relating to the radiation risk assessment, contingency plans and emergency arrangements which were discussed during the inspection.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for NHS Greater Glasgow and Clyde to consider.
Conclusion of intervention
The inspector gave NHS Greater Glasgow and Clyde until 31st January 2023 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.