Date(s) of inspection:
- January 2023
Aim of inspection
The purpose of the inspection was to review dnata Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at dnata Limited on 18/01/2023.
Subject(s) of inspection
The chosen inspection sample included:
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR
- Transport (Non-nuclear) Emergency arrangements
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17
- Transport (Non-nuclear) Security Plan
- Transport (Non-nuclear) Training
- Transport (Non-nuclear) Vehicle Requirements Part 8
- Transport (Non-nuclear) Local rules Reg 18 IRR17
Key findings, inspector’s opinions and reasons for judgement made
The inspector sampled the arrangements deployed by dnata 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 inspectors identified a number of examples of the dutyholder meeting relevant good practice in reducing risk to levels that are ALARP, including appropriate appointment of a Dangerous Goods Safety Adviser, training of Radiation Protection Supervisors, vehicles, equipment on board vehicles, vehicle signage and markings, a security plan and a Dangerous Goods Safety Advisers annual report.
The inspectors identified five areas of non-compliances and discussed these during the inspection; the need to formally appoint a Radiation Protection Adviser and obtain appropriate advice, formally appoint Radiation Protection Supervisors, produce suitable and sufficient transport Radiation Risk Assessments for all Dnata Ltd transport activities, produce emergency arrangements for all Dnata Ltd transport activities and make an assessment of whether the Radiation (Emergency Preparedness and Public Information) Regulations 2019 applies to Dnata Ltd’s in-transit store at its Stanwell site and ensure compliance with these regulations if appropriate.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for dnata Limited to consider.
The inspectors adhered to ONR’s Enforcement Policy Statement to inform appropriate enforcement action, which in this instance was:
- Issue of an Improvement Notice which requires dnata Limited to produce suitable and sufficient transport Radiation Risk Assessments; and
- Raising a level 3 Regulatory Issue to track the four other non-compliances identified in this report.
The inspectors gave dnata Limited until 28 April 2023 to comply with the Improvement Notice and provide ONR either with evidence that the other non-compliances have been resolved, or an appropriate resolution plan with timescales for completion.
ONR will monitor the identified non-compliances through its Issues Management arrangements.