Executive summary
Date(s) of inspection:
- October 2023
Aim of inspection
The purpose of the inspection was to review compliance of the duty-holder’s arrangements for class 7 radioactive material for road and/or rail transport.
Subject(s) of inspection
- Transport (Non-nuclear) – Rating: Green
- Transport (Non-nuclear) Appropriate management system – Rating: Green
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13 – Rating: Green
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR – Rating: Green
- Transport (Non-nuclear) Emergency arrangements – Rating: Amber
- Transport (Non-nuclear) Local rules Reg 18 IRR17 – Rating: Green
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17 – Rating: Green
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17 – Rating: Amber
- Transport (Non-nuclear) Training – Rating: Green
- Transport (Non-nuclear) Transport documentation – Rating: Green
- Transport (Non-nuclear) Vehicle Requirements Part 8 – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The inspector reviewed a range of topics and identified a number of examples of Alliance Medical Radiopharmacy Ltd (AMR) meeting relevant good practice in reducing risk to levels that are as low as reasonably practicable (ALARP), including appropriate appointment of safety advisors and radiation protection supervisors, having appropriate local rules and a management system and the provision of appropriate training.
The inspector identified two areas of non-compliance and discussed these during the inspection. These were associated with improvements to AMR’s transport emergency plan and radiation risk assessment.
Conclusion
The inspection findings were presented to AMR at the close of the inspection.
I judged an overall inspection rating of “Green” was appropriate for this inspection as relevant good practice was generally met when compared with appropriate benchmarks.
AMR has agreed to address the identified non-compliances by 15 January 2024. However, AMR is required to provide ONR an appropriate resolution plan with timescales for completion by 15 November 2023. The non-compliances will be tracked to completion via a level 4 regulatory issue.