Office for Nuclear Regulation

ACS Testing Ltd - 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 ACS Testing Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection remotely (via Microsoft Teams) on 23 February 2021.

The inspection team of Nicola Jaynes and Michelle Smith will be referred to as we or our throughout the body of this report.

Interventions Carried Out by ONR

The chosen inspection sample included:

Key Findings, Inspector's Opinions and Reasons for Judgements Made

We sampled the arrangements deployed by ACS Testing 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). 

We 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: appropriate registration; appropriate Radiation Protection Adviser and Dangerous Goods Safety Adviser appointments; having Local Rules and contingency plans for emergencies and producing a Dangerous Goods Safety Adviser annual report.

A number of contraventions of specific administrative requirements against legislation were identified and discussed during the inspection, which included having a suitable and sufficient RRA and Management System, displaying vehicle signage correctly and the need for additional RPS appointments.

During the inspection, we also suggested an improvement to transport practices that would be prudent for ACS Testing Ltd to consider.

Conclusion of Intervention

ACS Testing Ltd demonstrated that for aspects of its operations it met the requirements of CDG, ADR and IRR17.

Based on the inspection sample, ONR identified seven contraventions of administrative requirements against legislation and suggested one improvement. ONR discussed these non-compliances during the inspection and ACS Testing Ltd gave a commitment to address them.

ONR gave ACS Testing Ltd until 9 April 2021 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 overall IIS Rating of AMBER, below standard, was given to reflect that there were contraventions of specific administrative requirements. 

The identified contraventions will be managed through ONR’s Issues Management arrangements.