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), the Ionising Radiations Regulations 2017 (IRR17) and the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR used ADR 2019 during this inspection (www.unece.org).
The purpose of the inspection was to review Radi-Tech Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this remote inspection via Skype for Business on 14 October 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by Radi-Tech Ltd 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. The inspector identified a number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP, including its radiation risk assessment, contingency planning, information, instruction and training, security arrangements and management system. The inspector identified a non-compliance and discussed this during the inspection, which related to Radi-Tech Ltd’s requirement for an emergency plan under CDG.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Radi-Tech Ltd to consider.
Radi-Tech Ltd 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 areas for improvement. The inspector discussed these during the inspection and Radi-Tech Ltd gave a commitment to address them.
The inspector gave Radi-Tech Ltd until 25 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, the inspector gave an inspection rating of GREEN, due to relevant good practice being generally met.
ONR will monitor the identified non-compliance through its Issues Management arrangements.