Executive summary
Date(s) of inspection
- October 2023
Aim of inspection
The purpose of the inspection was to review compliance of the dutyholder’s arrangements for class 7 radioactive material for road transport, covering consignor and consignee duties.
Subject(s) of inspection
- Transport (Non-nuclear) Appropriate management system – Rating: Amber
- Transport (Non-nuclear) Contingency plans in accordance with IRR Reg 13 – Rating: Amber
- Transport (Non-nuclear) Dangerous Goods Safety Advisor subsection 1.8.3 ADR – Rating: Amber
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements – Rating: Not rated
- Transport (Non-nuclear) Local rules Reg 18 IRR17 – Rating: Green
- Transport (Non-nuclear) Radiation Protection Adviser Reg 14 IRR17 – Rating: Amber
- Transport (Non-nuclear) Radiation Risk Assessment Reg 8 of IRR 17 – Rating: Amber
- Transport (Non-nuclear) Training – Rating: Amber
- Transport (Non-nuclear) Transport documentation – 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 Diana, Princess of Wales Hospital meeting relevant good practice in reducing risk to levels that are ALARP, including appropriate appointment of a Dangerous Goods Safety Advisor and access to Radiation Protection Advisors.
At the time of the inspection, it was identified that ONR had carried out a remote inspection in October 2022 (IR-52002 refers) which had been terminated prematurely as a key part of an ONR inspection relates to examining consignor duties and the hospital could not articulate these duties. IR-52002 had led to a Level 4 Issue (RI-11066 refers) being raised in respect to consignor roles and responsibilities. RI-11066 was closed prior to this inspection but with the requirement to re-inspect the hospital during the 2023/24 inspection year.
The inspector identified seven areas of non-compliance and discussed these during the inspection. These were associated with, Radiation Risk Assessments, Radiation Protection Advisers, Dangerous Goods Safety Advisers, Management Systems, Contingency Plans, Transport Document and Training.
Conclusion
The inspection findings were presented to Diana, Princess of Wales Hospital at the close of the inspection.
I judged an overall inspection rating of ‘Amber’ was appropriate for this inspection.
I adhered to ONR’s Enforcement Management Model, which in this instance was the issue of an enforcement letter due to non-compliances in relation to Radiation Risk Assessments, Contingency Plans, Transport Document and Training. The hospital is required to provide ONR with evidence that the identified non-compliances have been resolved or an appropriate resolution plan with timescales for completion, by 12 January 2024. The non-compliances will be tracked to completion via a level 3 Regulatory Issue.
Diana, Princess of Wales Hospital is required to provide ONR either with evidence that the other identified non-compliances ( Radiation Protection Advisers, Dangerous Goods Safety Advisers, Departmental Management Systems) have been resolved, or an appropriate resolution plan with timescales for completion, by 12 January 2024. The non-compliances will be tracked to completion via a Level 4 Regulatory Issue.