- Site: Transport Competent Authority
- IR number: 20-015
- Date: September 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
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) and the Ionising Radiations Regulations 2017 (IRR17). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ADR 2019 was used during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the intervention was to review Self Powered Safety Products Limited’s (SP2) arrangements associated with the road transport of radioactive material. ONR carried out a virtual inspection via Skype on 03 September 2020.
This inspection also formed part of an ONR investigation into an incident involving the transport of radioactive materials by road, from SP2’s premises via Royal Mail to a number of consignees, without due regard for CDG.
Interventions Carried Out by ONR
The chosen inspection sample included:
- registration – IRR17 Regulation 6;
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- suitable and sufficient Contingency Planning and/or Emergency Arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Transport Documentation – ADR 5.4;
- Equipment on Board – ADR 8.1.5.2.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by SP2 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. For example SP2 had adequate written procedures for packing and transporting radioactive material, a secure store for radioactive material with limited employee access and measures to mitigate the consequences of an accident in the company vehicle whilst carrying radioactive material. ONR identified a number of non-compliances and discussed these during the inspection, which included: ONR judged that a) the RRA was not suitable and sufficient; b) the contingency plan did not fully satisfy requirements, employees were not trained and did not rehearse actions to take in the event of an emergency; c) transport documentation was not in accordance with ADR in some areas and d) equipment carried on the van did not fully satisfy requirements.
The procedures and supporting management systems relating to packaging and consigning of packages were examined to establish whether or not these may have contributed to the incident being investigated and SP2 was asked to explain the circumstances that led to the incident. ONR considered that the root cause for the incident occurring was human error and poor judgment on the part of an individual rather than any shortfalls in company procedures or management arrangements. A separate investigation report will be produced to provide the detailed findings from the investigation.
During the inspection, ONR suggested certain improvements to transport practices that would be prudent for SP2 to consider.
Conclusion of Intervention
SP2 demonstrated that for certain aspects of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspectors identified four non-compliances with relevant legislation and suggested two improvements. These were all discussed during the inspection and a commitment obtained from SP2 to address them.
SP2 was given until 9th October 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, an overall IIS Rating of GREEN is given to reflect that Legal duties were complied with, although there were minor contraventions of specific administrative requirements.
ONR will monitor the identified contraventions through its Issues Management arrangements.