The purpose of these interventions is:
The duty holders are selected for inspection based on an assessment of their potential risk to the public. As the duty holders in the non-nuclear sector are inspected on an infrequent basis, typically 3-5 yearly, ONR samples key aspects of the arrangements for the transport of radioactive materials in order to determine the level of compliance with the requirements of the relevant regulations, CDG and ADR 2017.
In general duty holders' radiation protection programmes demonstrated compliance with the requirements of ADR. Evidence was seen of systematic arrangements to monitor worker doses or provide appropriate justifications where it has been determined that worker doses will be less than 1mSv per year. Arrangements were also in place to undertake radiation and contamination of packages and vehicles. In cases where duty holders had not currently documented the methodology and the frequency of undertaking this monitoring, ONR suggested that they should consider doing so, and keep this under review in case of changes in the workload or the numbers of staff involved in undertaking this work. 1.11 Management Systems and Procedures were deemed adequate for many duty holders, demonstrating compliance with this requirement of the regulations governing the transport of radioactive material. These management systems seen ranged from formally accredited systems to local arrangements. 1.12 The arrangements implemented for the delivery, and collection, of radioactive materials to, and from, duty holders were found to demonstrate compliance with the security requirements described in ADR and in particular good control, secure storage of these materials, adherence to procedures by delivery drivers and security staff, and the control of radiation dose to the security staff escorting the drivers within companies.
The main non-compliances identified for non-nuclear duty holders continue to be in relation to the adequacy and testing of emergency arrangements. ONR has prepared and published guidance on this topic as an aide to duty holders to help them to understand their duties in the preparation and testing of emergency plans. This guidance has been published on the ONR Transport website and continues to be provided to individual duty holders, in advance of inspections, and promoted via stakeholder interactions at meetings, conferences and articles in newsletters. ONR is now planning to review and update this guidance as a result of feedback from stakeholders and inspection experience.
Shortfalls were also found, specifically with the lower risk duty holders, in the provision of general awareness training. In discussion with duty holders it has been recognised that this shortfall can be addressed via toolbox talks or enhancing current training presentations to include transport specific awareness topics.
During Q2 there were no failures in compliance significant enough for ONR to take formal enforcement action. The duty holders sampled, demonstrated an improved level of awareness of Transport regulations and positive feedback was received in respect of recent ONR guidance on, for example, radiation and contamination monitoring requirements and emergency arrangements. ONR has continued to engage with both individual duty holders and stakeholder groups in the sector during this quarter to promote compliance through advice and influence.