Office for Nuclear Regulation

University of Bristol, Compliance inspection Transport of Radioactive Materials (Class 7 dangerous goods)

Executive summary

Purpose of Intervention

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).

Purpose of Intervention

The purpose of the remote inspection was to review the University of Bristol’s arrangements associated with the road transport of radioactive material. ONR carried out this remote inspection via Skype on 18 August 2020, as part of its preliminary enquiries into a reported incident that occurred on 8 June 2020.

Interventions Carried Out by ONR

The chosen inspection sample included:

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The inspector sampled the arrangements deployed by the University of Bristol 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 radiation risk assessment, restriction of exposure, training, transport documentation and its management system. One non-compliance was identified and discussed during the inspection concerning contingency planning.

During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for the University of Bristol to consider.

In addition, the inspector also gained adequate assurance that the University of Bristol’s investigation into the incident had been suitable and sufficient and the root causes identified.

 Conclusion of Intervention

 The University of Bristol demonstrated that for certain 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 the University of Bristol to address them.

The University of Bristol was given until 29 September 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 legal duties are complied with although there were minor contraventions of specific administrative requirements identified and relevant good practice is generally met.

The non-compliance will be managed through ONR’s Issues Management arrangements.