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 ONR regulated against ADR 2019 during this inspection (www.unece.org).
The purpose of the inspection was to review ‘The Courier Company’s’ arrangements associated with the road transport of radioactive material. ONR carried out this inspection of the Bletchley site remotely (via Skype and telephone) on 13 July 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by The Courier Company 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: appropriate registration and consent; having a Radiation Risk Assessment (RRA); having contingency plans for emergencies; having local rules in place and having arrangements for training.
A number of minor contraventions of specific administrative requirements against legislation were identified and discussed during the inspection, which included: i) elements of the RRA were inadequate; ii) there was insufficient evidence to demonstrate full compliance with the emergency planning requirements under CDG; iii) certain expected content of the local rules was missing; iv) there was no additional training in place for employees working with High Activity Sealed Sources (HASS).
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for The Courier Company to consider.
The Courier Company demonstrated that for aspects of its operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector identified four minor contraventions of specific administrative requirements against legislation and suggested three improvements. ONR discussed these non-compliances during the inspection and The Courier Company gave a commitment to address them.
ONR gave The Courier Company until 24th 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 overall IIS Rating of GREEN was given to reflect that legal duties are complied with, although there were minor contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.