Office for Nuclear Regulation

Minton, Treharne & Davies Ltd - 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 Minton, Treharne and Davies Ltd. (MTD) arrangements associated with the road transport of radioactive material. ONR carried out this inspection virtually on 29 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 MTD 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 an adequate management system, suitable RPA/RPS cover, appropriate dosimetry and in general a good standard of local rules and risk assessments . A number of non-compliances were identified and discussed during the inspection, which included enhancements to the radiation risk assessment and changes to layout of transport documentation.

During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for MTD to consider.

Conclusion of Intervention

 MTD demonstrated that for aspects of its 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. These were all discussed during the inspection and a commitment obtained from MTD to address them.

MTD was given until 14 May 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 GREEN is given, due to there being relatively minor, deficiencies in compliance arrangements.

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