- Site: Transport Competent Authority
- IR number: 21-037
- Date: January 2022
- 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 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 2021 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Swissport GB Limited throughout the body of this report.arrangements associated with the road transport of radioactive material. ONR carried out this inspection at Swissport GB Limited World Freight Terminal at Manchester Airport on 12 January 2022.
The inspection team of Nicola Jaynes and Paul Butler will be referred to as ‘we’ or ‘our’.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- 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;
- Dangerous goods transport document and related information – ADR 5.4;
- Security Plan – ADR 1.10, and
- DGSA Report – ADR 1.8.3.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We sampled the arrangements deployed by Swissport GB Limited 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).
We 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 as low as reasonably practicable were identified including: appropriate HSE registration; appropriate Radiation Protection Adviser (RPA) appointment letter, appropriate security plan, having a transport RRA and having a contingency plan.
We identified several non-compliances and discussed these during the inspection, which included the need to make improvements to the RRA and emergency arrangements, make sure internal transport documents are completed correctly and fully and review the content of the annual DGSA report.
Conclusion of Intervention
Swissport GB Limited demonstrated that for aspects of its transport operations it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, ONR identified five non-compliances with relevant legislation and two areas for improvement. We discussed these during the inspection and Swissport GB Limited gave a commitment to address them.
We gave Swissport GB Limited until 4th March 2022 to provide ONR either with evidence that the findings had been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention an IIS Rating of AMBER was given to reflect that there were contraventions of specific administrative requirements.
The identified contraventions will be managed through ONR’s Issues Management arrangements.