ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG) and the Ionising Radiations Regulations 2017 (IRR17). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ADR 2019 was used during this inspection (www.unece.org).
The purpose of the inspection was to review Pharmaron UK’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection remotely via Skype on 7 July 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by Pharmaron UK 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. A number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP were identified, including staff training, contingency plans and DGSA annual report/incident reviews. One non-compliance was identified and discussed during the inspection, relating to the suitable recording of the transport radiation risk assessment.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Pharmaron UK to consider.
Pharmaron UK demonstrated that for aspects of its operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified one non-compliance with relevant legislation and suggested two improvements. These were all discussed during the inspection and a commitment obtained from Pharmaron UK to address them.
Pharmaron UK was given until 28 August 2020 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an IIS Rating of GREEN is given, as although the inspector judged there to be deficient arrangements for compliance with legal requirements, he considered them to be minor and primarily related to traceability within the documentation set.
Non-compliances will be managed through ONR’s Issues Management arrangements.