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 PET NET Solutions Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection remotely via Skype at the address listed above on 9th September 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by PET NET Solutions Limited 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 PET NET Solutions had a good understanding of its legal duties, it had suitable and sufficient procedures covering transport duties underpinned by a radiation risk assessment, a suitable management framework and contingency plans for accident scenarios. During the inspection the inspector identified and discussed two non-compliances, which included not identifying whether an emergency plan is required under CDG and not undertaking regular refresher training for employees.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for PET NET Solutions to consider.
PET NET Solutions 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 two non-compliances with relevant legislation and suggested three improvements. The inspector discussed these during the inspection and a commitment was given by PET NET Solutions to address them.
PET NET Solutions was given until 7th October 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 is given to reflect that Legal duties were complied with, although there were minor contraventions of specific administrative requirements.
Non-compliances will be managed through ONR’s Issues Management arrangements.