Office for Nuclear Regulation

Medical Physics - Compliance inspection, Transport of Radioactive Materials (Class 7 dangerous goods)

Executive summary

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).

Purpose of Intervention

The purpose of the inspection was to review the University Hospitals Birmingham NHS Foundation Trust’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at the Queen Elizabeth Hospital site on 12 March 2021.

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 the University Hospitals Birmingham NHS Foundation Trust for the 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 as low as reasonably practicable were identified, including its management system arrangements, radiation protection programme, and security arrangements. The inspector identified two non-compliances during the inspection.

During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for the University Hospitals Birmingham NHS Foundation Trust to consider.

Conclusion of Intervention

 The University Hospitals Birmingham NHS Foundation Trust demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified two non-compliances with relevant legislation and suggested three improvements. The inspector discussed these during the inspection and the University Hospitals Birmingham NHS Foundation Trust gave a commitment to address them.

The inspector gave the University Hospitals Birmingham NHS Foundation Trust until 23 April 2021 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.

For this intervention, the inspector gave an IIS Rating of GREEN, due to there being evidence that relevant good practice was generally met, with only minor shortfalls identified when compared with appropriate benchmarks, that legal duties were complied with, although there may be minor contraventions of specific administrative requirements, and that no significant shortfalls were identified in the delivery of safety or security functions.

The University Hospitals Birmingham NHS Foundation Trust has already taken action to address the non-compliance(s) regarding packaging life and DGSA reporting.

ONR will monitor the identified non-compliances through its Issues Management arrangements.