Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review CROFT’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at CROFT (Site) on 20/09/2022.
Subject(s) of inspection
The chosen inspection sample included:
- Transport (Nuclear) 2 Arrangements for Package Design
- Transport (Nuclear) 1 Management Systems
- Transport (Nuclear) 10 Training and Competence
- Transport (Nuclear) 3 Package Manufacture and Supply Chain
- Transport (Nuclear) 4 Package Modification Control
- Transport (Nuclear) 8 Management and Control of Transport Interfaces
Key findings, inspector’s opinions and reasons for judgements made
During the inspection of Croft’s arrangements against the six scope areas, we found evidence that the arrangements for, and implementation of, (a) package design, (b) package manufacture and supply chain, (c) package modification control, and (d) control of transport interfaces were appropriate and rated these thematic areas Green (no formal enforcement).
Relating to management systems, we inspected Croft’s Management System and found it to be a logically organised process-based system, with guidance detailing how activities are undertaken. During discussions, individuals demonstrated their knowledge and skill at using and applying the management system.
However, when compared to the expectations identified in ADR and RID, we found several shortfalls, which we considered to be significant, relating to management systems. These included: governance of the management system; incorporation of good practice or lessons learnt into management system processes; and oversight and peer checking arrangements.
Relating to training and competence, Croft was able to show evidence of the high-level competencies required and that they were tracking the competence of individuals using a matrix. We discussed competence with a senior member of the design staff and gained confidence that the individual was competent for the role they deliver.
However, we found deficiencies in the training and competence management process, which we considered to be significant. This included the: identification / analysis of competence requirements; assignment of proficiency; and identification of refresher training.
These two thematic areas (management systems, and training and competence) were rated Amber (Seek Improvement) and Regulatory Issues (RI) 11050 and 11051 have been raised to track and manage resolution of the identified shortfalls.
Conclusion of intervention
The inspection found that Croft is compliant against several aspects of ADR/RID and therefore CDG. However, we found deficiencies in Croft’s management system and training arrangements and are seeking improvement in these areas.
The inspector gave Croft until 25 November 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.
For this intervention, the inspectors gave an overall inspection rating of Amber (Seek Improvement) due to the findings from the inspection of the management system, and the management of training and competence.