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 The University of Sheffield’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at The Arts Tower, Western Bank, Sheffield on 29 September 2020.
This inspection also formed part of ONR’s preliminary enquiries into a reported incident that occurred on 9 June 2020 and 30 June 2020 where radioactive material was transported by The University of Sheffield without due regard for CDG.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by The University of Sheffield 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, information, instruction and training, its management system and contamination monitoring. A number of non-compliances were identified and discussed during the inspection, which included: the requirements for content, training and rehearsal of the transport contingency plan had not been fully met and there were some deficiencies against the requirements for transport documentation.
The inspector examined the University of Sheffield’s management system, supporting procedures relating to packaging and consigning of packages and training arrangements to establish whether or not these may have contributed to the incident being investigated. In addition, the University of Sheffield’s investigation report covering the incident was reviewed to gain assurance that it was suitable and sufficient, identified the root causes and any necessary follow-up actions. ONR considers that the company procedures and management arrangements are adequate and the shortfall that led to the incident relates to implementation of the arrangements. The investigation into the incident is currently on-going.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for The University of Sheffield to consider.
The University of Sheffield 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 four non-compliances with relevant legislation and suggested three improvements. These were all discussed during the inspection and a commitment obtained from The University of Sheffield to address them.
The University of Sheffield was given until 10 November 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 to reflect that legal duties were complied with, although there were minor contraventions of specific administrative requirements and relevant good practice is generally met.
ONR will monitor the identified contraventions through its Issues Management arrangements.