Executive summary
Date(s) of inspection: July 2024
Aim of inspection
The purpose of the inspection is to review compliance of the dutyholder's arrangements for class 7 radioactive material, covering consignor and consignee duties.
Subject(s) of inspection
- Transport (Non-nuclear) Appropriate management system - Rating: Not Rated
- 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: GREEN
- Transport (Non-nuclear) Designation of Controlled or supervised areas Reg 17 IRR17 - Rating: Not Rated
- Transport (Non-nuclear) Emergency arrangements - Rating: GREEN
- Transport (Non-nuclear) IRR17 Regulation 19 additional requirements - Rating: Not Rated
- Transport (Non-nuclear) Local rules Reg 18 IRR17 - Rating: Not Rated
- 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) Security Plan - Rating: Not Rated
- Transport (Non-nuclear) Sub contract arrangements - Rating: Not Rated
- Transport (Non-nuclear) Training - Rating: Not Rated
- Transport (Non-nuclear) Transport documentation - Rating: Not Rated
- Transport (Non-nuclear) Vehicle Requirements Part 8 - Rating: Not Rated
Key findings, inspector's opinions and reasons for judgement made
The inspector identified that the two companies, Pentagon Transport Limited and Pentagon Freight Services PLC - which are discrete legal entities but have overlapping systems and processes - have been carriers/forwarders for dangerous goods for a number of years. Both companies were represented at the site inspection. Arranging the compliance inspection made the companies aware that they were failing to meet a number of requirements of CDG09 and IRR 17. They have now employed an external DGSA/RPA to help them to achieve compliance. They deal with type A and excepted packages.
There were a number of examples of the duty holders meeting relevant good practice, but equally, where further work was needed. These included appropriate local rules and work instructions, focussed radiation risk assessments, training and plans for maintaining competence; arrangements for receipt of packages and their carriage to consignee. A further inspection at the PFS site in Aberdeen is required for an objective rating.
Conclusion
The inspection findings were presented to the companies at the close of the inspection. A plan of action was agreed to prepare for a targeted inspection in six months time at their Aberdeen site. There was no evidence to suggest their current processes and practices were creating risk from the carriage of class 7 dangerous goods. However there were a number of significant regulatory shortfalls that require action. Both the companies and their DGSA appear fully committed to improvement. They wish to participate in sharing their learning with the wider carrier industry.
The following actions were required:
- Companies to provide an organogram to show the inter-relationships within Pentagon Holdings Ltd, and the activities the individual companies are involved in. This is to allow understanding of the Group's structure.
- Companies to provide any previous DGSA report for carriage of class 7 dangerous goods.
- DGSA to provide a retrospective annual report.
- Information provided previously by Grampian Continental Ltd on their class 7 dangerous goods carriages to be forwarded to the inspector.
- Local rules, procedures, and contingency plans relevant to to current activities to be produced vis high level documents.
- Evidence of training records to be provided.
Regulatory Issue raised and Enforcement letter sent (see RI-12176, also ONR-EL-24-14). Companies and also Grampian Continental Ltd to be visited at the Aberdeen site in March 2025.