Office for Nuclear Regulation

AXIS NDT Ltd (site) Transport – Inspection ID: 52832

Executive summary

Date(s) of inspection:

  • October 2023

Aim of inspection

The purpose of the inspection was to review compliance of the dutyholder’s arrangements for class 7 radioactive material for road transport, covering consignor and carrier duties.

Subject(s) of inspection

  • Transport (Non-nuclear) – Rating: Amber
  • Transport (Non-nuclear) Appropriate management system – Rating: Amber
  • Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13 – Rating: Green
  • Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR – Rating: Green
  • Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17 – Rating: Green
  • Transport (Non-nuclear) Emergency arrangements – Rating: Not rated
  • Transport (Non-nuclear) IRR17 Regulation 19 additional requirements – Rating: Green
  • Transport (Non-nuclear) Local rules Reg 18 IRR17 – Rating: Green
  • Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17 – Rating: Green
  • Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17 – Rating: Amber
  • Transport (Non-nuclear) Security Plan – Rating: Green
  • Transport (Non-nuclear) Sub contract arrangements – Rating: Not rated
  • Transport (Non-nuclear) Training – Rating: Green
  • 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 inspectors reviewed a range of topics and identified a number of examples of AXIS NDT meeting relevant good practice in reducing risk to levels that are ALARP, including appropriate appointment of Radiation Protection Advisers/Dangerous Goods Safety Advisers (RPA/DGSA), procedures supporting carriage, vehicle signage and equipment, transport documentation, and training.

The inspectors identified several areas of non-compliance and discussed these during the inspection. These were associated with the Radiation Risk Assessment, Transport Management System and Package Labelling.

Conclusion

The inspection findings were presented to Axis.

We judged an overall rating of Green was appropriate for this inspection as there was evidence of legal duties complied with, although there were minor contraventions identified.

Axis is required to inform ONR that the finding associated with the package markings is resolved prior to its next transport of the package.

Axis is required to provide ONR with evidence that the non-compliances related to the RRA have been resolved by the 31 October 2023.

Axis is also required to provide ONR either with evidence that the remaining non-compliances have been resolved, or provide an appropriate resolution plan with timescales for completion, by the 21 December 2023.

The non-compliances will be tracked to completion via a Level 4 regulatory issue.