Office for Nuclear Regulation

East & North Hertfordshire NHS Trust - Transport compliance inspection

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 East and North Hertfordshire NHS Trust’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at remotely via MS Teams on 10 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 East and North Hertfordshire NHS Trust 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 suitable local rules, sufficient general management arrangements, dosimetry and security arrangements. A number of non-compliances were identified and discussed during the inspection, which included the lack of a suitable and sufficient radiation risk assessment (with an associated lack of understanding of whether emergency arrangements are required).

During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for East and North Hertfordshire NHS Trust to consider.

Conclusion of Intervention

East and North Hertfordshire NHS Trust demonstrated that for aspects of its operations it met the requirements of CDG, ADR and IRR17.

Based on the inspection sample, the inspector identified one non-compliances with relevant legislation and suggested three improvements. These were all discussed during the inspection and a commitment obtained from East and North Hertfordshire NHS Trust to address them.

East and North Hertfordshire NHS Trust was given until 23 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 IIS Rating of AMBER is given, due to there being a significant shortfall against an identified relevant good practice when compared with appropriate benchmarks.

All Non-compliances will be managed through ONR’s Issues Management arrangements.