- Site: Transport Competent Authority
- IR number: 21-021
- Date: August 2021
- LC numbers: N/A
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 Format NDT Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Format NDT Ltd’s Brindley Road premises on 18 August 2021.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Radiation Protection Adviser – IRR17 Regulation 14;
- Safety Adviser – ADR 1.8.3;
- Certificates issued by the Competent Authority – ADR 5.1.5.2;
- Suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- Local Rues and Radiation Protection Supervisors (RPS) – IRR17 Regulation 18;
- Suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- Suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- Adequate Security arrangements – ADR 1.10;
- Dangerous goods transport document and related information – ADR 5.4.1;
- Equipment on Board – ADR 8.1.5.2; and
- Orange coloured plate marking – ADR 5.3.2
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by Format NDT Ltd 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 dutyholder meeting relevant good practice in reducing risk to levels that are ALARP were identified including: appropriate IRR17 consent, appropriate Radiation Protection Adviser and Dangerous Goods Safety Adviser appointments, having an RRA, Local Rules, contingency plans for emergencies and appropriate equipment on vehicles.
The inspector identified several non-compliances and discussed these during the inspection, which included: demonstrating the transport packages used are compliant with ADR requirements and are appropriately maintained, revising its radiation risk assessment, refresher training RPS’s, revising its emergency arrangements and testing of the arrangements, ensuring maximum source activities permitted to be held are documented, revising its security plan and providing refresher security training, ensuring transport documentation meets ADR requirements and is appropriately completed for each transport, recording test dates of fire extinguishers and ensuring vehicle signage meets ADR size specifications.
Format NDT Ltd voluntarily agreed to formally write to ONR to confirm that they would not transport radioactive material until they have addressed the above non-compliances. Format NDT Ltd subsequently wrote to ONR on 19 August to confirm that they had ceased transport of radioactive material and would not transport radioactive material until they had received confirmation from the ONR inspector that the actions they have taken to address the non-compliances were adequate.
During the inspection, the inspector also suggested an improvement to transport practices that would be prudent for Format NDT Ltd to consider.
Conclusion of Intervention
Format NDT Ltd 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 twelve non-compliances with relevant legislation and suggested one improvement. The inspector discussed these during the inspection and Format NDT Ltd gave a commitment to address them.
The inspector gave Format NDT Ltd until 8 October 2021 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.
Format NDT Ltd voluntarily agreed to cease transport of radioactive material and is currently taking action to address the non-compliances identified.
For this intervention, an overall IIS Rating of AMBER, below standard, was given to reflect that specific legal requirements had not been met.
ONR will monitor the identified non-compliances through its Issues Management arrangements.