Office for Nuclear Regulation

Bluelimit Surveys Limited compliance inspection

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 inspection was to review Bluelimit Survey Limited (Bluelimit) arrangements associated with the road transport of radioactive material. ONR carried out this inspection via skype on 15th September 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 Bluelimit 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 training of drivers, consent gained from HSE and suitable dosimetry.

A number of non-compliances were identified and discussed during the inspection, which included lack of a dangerous goods safety advisor (DGSA), inadequate radiation risk assessment, no consideration of sources potentially being high consequence dangerous goods and incorrect transport documentation. Due to the non-compliances identified there was no security plan for transport of high consequence dangerous goods and no emergency plan for transport incidents.

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

Conclusion of Intervention

 Bluelimit demonstrated that for some of its operations it met the requirements of CDG, ADR and IRR17.

Based on the inspection sample, the inspector identified five non-compliances with relevant legislation and suggested one improvement. These were all discussed during the inspection and a commitment obtained from Bluelimit to address them.

Bluelimit was given until 16th November 2020 to provide ONR either with evidence that the findings have been resolved, or an appropriate resolution plan with timescales for completion. As the lack of a DGSA is considered to be the underlying cause of the other issues ONR has required (Ref. 2020/281189) Bluelimit to provide evidence that a DGSA has been appointed by 30th September 2020.

For this intervention, an IIS Rating of AMBER is given, due to there being significant or systematic failure to implement or meet compliance arrangements.

Non-compliances will be managed through ONR’s Issues Management arrangements.