Date(s) of inspection:
- May 2023
Aim of inspection
The aim of this inspection is to review the dutyholders compliance of Class 7 transport against the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG) 2009.
Subject(s) of inspection
- Transport (Nuclear) 1 Management Systems – Rating: Amber
- Transport (Nuclear) 10 Training and Competence – Rating: Amber
- Transport (Nuclear) 14 Incidents, Events and Compliance History – Rating: Green
- Transport (Nuclear) 5 Package Maintenance and Operation – Rating: Not rated
- Transport (Nuclear) 6 Package Preparation for Consignment – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
The inspectors reviewed a range of thematic areas in accordance with ONR transport inspection guidance and identified a number of examples of Sellafield Ltd reducing risks associated with the transport of Class 7 material and meeting the relevant regulatory requirements. Sellafield Ltd have structured, documented and established Class 7 management arrangements. A number of shortfalls were identified and a regulatory issue was raised to monitor Sellafield Ltd’s progress to address the regulatory findings.
On the basis of the evidence sampled during the compliance inspection related to ONR’s nuclear transport purpose, and in accordance with ONR-INSP-GD-069, Sellafield Ltd have demonstrated that they have documented arrangements to meet the requirements of The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009. The evidence indicates that the adequacy and implementation of the arrangements requires improvement. The ONR inspection rating is amber.
- Management System – There are governance issues with respect to the Class 7 managements arrangements. The structure of, and within, documentation in the transport management system reviewed under Topic Area 2.07 is difficult to follow and there is a lack of clarity. There is a plethora of procedures, forms, guides, etc. supporting compliance with different sets of legislation. It is not easy to observe how these coalesce to form clear management arrangements to support complaint Class 7 transport. SL should review and revise the Class 7 management system to ensure that there are clear arrangements that support compliance with ADR 1.7.3 and TS-G-1.4. This includes, but is not restricted to: SLC 2.07.01, SLC 2.07.03, SLP 2.07.01, CS SP 001. The CT should ensure that the Class 7 management system has adequate oversight and can be implemented. It may be prudent for the CT to liaise with the SEMS team to ensure that changes made to the current system enable a smooth transition to SEMS.
- Management System – The OCA are not fulfilling the Terms of Reference (e.g., adequate resource, establishing a transport strategy) to enable the CT to discharge its transport duties.
SL should review the functionality of the OCA and ensure that the Terms of Reference are met, or revised if required.
- Resource – The CT cannot fulfil their duties in accordance with TS-G-1.4 and their own transport managements arrangements due to a lack of resource. In particular, the CT are not following RFI05 Task 5 by implementing an effective assurance programme and developing procedures / practices. Sellafield Ltd should review the organisational capability required to deliver Class 7 duties and ensure that adequate SQEP resource (or if not SQEP, with direct supervision in accordance with ADR 1.3.1) is available.
- Management System/Package Preparation for Consignment – FHP are able to operate with a level of independence from the CT if assurance is provided through implementation of CS SP 003. There is a lack of evidence demonstrating a) how the CT are following CS SP 003 to ensure that FHP consign compliantly and b) that FHP are following a documented process to consign packages. CT should implement an assurance review of FHP as required by CS SP 003.
- Incidents, Events and Compliance History – A number of Class 7 incidents were sampled and inconsistencies were observed with respect to the level of information provided and the internal follow-up. Sellafield Ltd should ensure that all INF-1 forms are submitted in a clear and consistent manner, have the appropriate amount of information and have consistent internal follow-up (investigations, FURs, etc.) according to the incident severity and ONR incident reporting guidance.
- Management System / Training and Competence – SL do not have clearly defined roles and responsibilities for Class 7 operations that link to the legally defined Class 7 participants. There are inconsistencies with respect to how Class 7 participants achieve SQEP status. Class 7 participants who sit within business unites (e.g., packers) have not undertaken general awareness and function specific training in accordance with ADR 22.214.171.124 and 126.96.36.199.
The management arrangements should be reviewed and revised to ensure that there is a clear, consistent and controlled structure for Class 7 roles, responsibilities, training and SQEP status, regardless of where the participant resides (CT or business unit). There should be a clear link between roles and responsibilities to:
- a controlled training matrix (function specific and general awareness training, with respect to requirements of the regulations, commensurate with duties) and the SQEP process.
regulatory requirements stipulated in the mandatory standard compliance matrix.
- to demonstrate that those with a Class 7 responsibility are discharging their roles adequately.
SL should ensure that Class 7 participants have the appropriate general awareness and function specific training in accordance with ADR 188.8.131.52 and 184.108.40.206, commensurate with their duties.
One Regulatory Issue (RI-11629) has been raised to monitor Sellafield Ltd’s progress to address the regulatory findings. The response is required by 31 October 2023.