Date(s) of inspection:
- April 2023
Aim of inspection
The purpose of the inspection was to review compliance of the duty-holder’s arrangements for class 7 radioactive material for road and/or rail transport.
Subject(s) of inspection
- Transport (Non-nuclear) Appropriate management system – Rating: AMBER
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13 – Rating: RED
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR – Rating: RED
- Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17 – Rating: Not Rated
- Transport (Non-nuclear) Emergency arrangements – Rating: RED
- Transport (Non-nuclear) Local rules Reg 18 IRR17 – Rating: AMBER
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17 – Rating: RED
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17 – Rating: RED
- Transport (Non-nuclear) Security Plan – Rating: AMBER
- Transport (Non-nuclear) Sub contract arrangements – Rating: RED
- Transport (Non-nuclear) Training – Rating: RED
- Transport (Non-nuclear) Transport documentation – Rating: GREEN
- Transport (Non-nuclear) Vehicle Requirements Part 8 – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
The dutyholder is a consignor of radioactive materials in type A and excepted packages and is responsible for loading and unloading of these packages. It uses contracted carrier(s) for transporting these packages within the UK and worldwide.
During the inspection, I identified a significant number of non-compliances with the Ionizing Radiation Regulations 2017 and the Health and Safety at Work etc. 1974, section 2(1) and 3(1), regarding the transport of radioactive dangerous goods. This included no Radiation Risk Assessment(s), no contingency plan, uncertain adequate radiation protection advice was given and implemented, did not have appointed Dangerous Goods Safety Advisor (DGSA), unable to confirm the contracted carrier’s CDG09 Class 7 qualification, training record(s), security awareness, etc. As a result of these non-compliances, the dutyholder has been issued with a Prohibition Notice.
Based on the significant number of non-compliances against IRR17, Class 7 CDG09 and ADR IRR17 requirements, and the dutyholder failed to demonstrate its duty as an employer to ensure, so far as is reasonably practicable, the health and safety of those it employs and others who may be affected by risks arising from ionising radiation. I judge the the overall inspection rating is “Red”.
I have issued a Prohibition Notice ONR-PN-23-001 to direct the dutyholder to stop consigning Class 7 radioactive dangerous goods immediately until the said contraventions and matters have been remedied, and have raised L2 and L4 regulatory issues to monitor the development of the said non-compliances.