Date(s) of inspection:
Aim of inspection
The purpose of the inspection was to review North Lincolnshire and Goole NHS Foundation Trust’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at North Lincolnshire and Goole NHS Foundation Trust (site) on 06/10/2022.
Subject(s) of inspection
The chosen inspection sample included:
- Transport (Non-nuclear) Appropriate management system
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17
Key findings, inspector’s opinions and reasons for judgements made
The inspector sampled the arrangements deployed by NLAG 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. A number of examples were identified were the duty holder met relevant good practice in reducing risk to levels that are ALARP, including: having a Radiation Risk Assessment, Contingency plans for packaging and testing emergency arrangements. I identified a significant non compliance in so far as NLAG were unable to articulate who took responsibility as consignor of the packages as required in accordance with CDG regulations. This was discussed in detail during the inspection.
The inspection was curtailed as some of the detail surrounding consignor duties could not be examined.
Conclusion of intervention
NLAG demonstrated that for some aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified a significant non-compliance with relevant legislation. The inspector discussed this non-compliance during the inspection and a commitment was obtained from NLAG to address the non-compliance.
NLAG was given until 10th November 2022 to provide ONR either with evidence that the finding has been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an overall IIS Rating of Amber is given to reflect that Legal duties were complied with, although there were contraventions of specific administrative requirements.
The non-compliances will be managed through ONR’s Issues Management arrangements.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for North Lincolnshire and Goole NHS Foundation Trust to consider.