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 County Durham and Darlington NHS Foundation Trust’s (CDDFT) arrangements associated with the road transport of radioactive material. ONR carried out this inspection of CDDFT remotely (via Microsoft Teams) on 20 October 2020.
The sites included within the scope of the inspection were the University Hospital of North Durham and Darlington Memorial Hospital.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by CDDFT 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 CDDFT’s radiation risk assessment, restriction of exposure and local rules. A number of non-compliances were identified and discussed during the inspection, which included missing elements of the contingency plan, designation of areas around the transport packages, training provision and adequacy of the management system.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for CDDFT to consider.
CDDFT 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 two improvements. These were all discussed during the inspection and a commitment obtained from CDDFT to address them.
CDDFT was given until 1 December 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, due to there being some minor contraventions of administrative requirements.
Non-compliances will be managed through ONR’s Issues Management arrangements.