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 remote inspection was to review Expro North Sea Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection via Microsoft Teams with the Aberdeen site on 28 October 2020.
The chosen inspection sample included:
The inspector sampled the arrangements deployed by Expro North Sea 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 examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP, including measures to restrict exposure, information, instruction and training, elements of its contingency planning and its management system. The inspector identified a number of non-compliances and discussed these during the inspection, which included its radiation risk assessment.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Expro North Sea Ltd to consider.
Expro North Sea 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 three areas of non-compliance with relevant legislation and suggested one improvement. The inspector discussed these during the inspection and Expro North Sea Ltd gave a commitment to address them.
The inspector gave Expro North Sea Ltd until 9 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, the inspector gave an inspection rating of AMBER, due to there being certain legal requirements not met but without prejudice to overall safety.
ONR will monitor the identified non-compliances through its Issues Management arrangements.