Executive summary
- Date(s) of inspection: February 2024
Aim of inspection
The purpose of the inspection was to review compliance of the NDT Group Ltd’s arrangements for class 7 dangerous goods (radioactive material) for road transport, covering consignor, consignee and carrier duties.
Subject(s) of inspection
- Transport (Non-nuclear) - Rating: AMBER
- 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) Designation of Controlled or supervised areas Reg 17 IRR17 - Rating: GREEN
- Transport (Non-nuclear) Emergency arrangements - Rating: GREEN
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements - Rating: GREEN
- 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: GREEN
- Transport (Non-nuclear) Training - Rating: GREEN
- Transport (Non-nuclear) Transport documentation - Rating: AMBER
- 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 NDT Group Ltd meeting relevant good practice in reducing risk to levels that are as low as is reasonably practicable (ALARP), including appropriate appointment of Safety Advisers (Dangerous Goods Safety Advisers and Radiation Protection Advisers), Safety Adviser reports, appointment and training of Radiation Protection Supervisors, Local Rules, training and refresher training of drivers and other staff involved in the transport of radioactive material and appropriate equipment on board vehicles.
The inspector identified four areas of non-compliance and discussed these during the inspection. These were associated with:
- Marking and labelling of packages and overpacks
- Demonstration of package compliance
- Package Maintenance and Certification
- Transport Documentation
Conclusion
The inspection findings were presented to NDT at the close of the inspection.
I judged an overall inspection rating of green was appropriate for this inspection as there were no significant shortfalls identified in the delivery of safety.
NDT is required to provide ONR either with evidence that the four identified non-compliances have been resolved, or an appropriate resolution plan with timescales for completion, by the 5th April 2024. The non-compliances will be tracked to completion via a level 4 regulatory issue.