Executive summary
Date(s) of inspection:
March 2025
Aim of inspection
ADR / RID 1.7.3 requires a management system to be established and implemented for all transport activities within the scope of the applicable regulations. Competent authority approval is contingent on the adequacy of the management system. The primary purpose of this inspection is to ensure that the management system pertinent to the approval (i.e., transport package design) is adequate. A human factors assessment is being undertaken to support a permissioning activity (PI-01535) – during the inspection we will consider the human-based safety claims, human factors in design and the provision of information for use.
Subject(s) of inspection
- Transport - Management Systems - Rating: AMBER
- Transport - Package Design and Modification - Rating: GREEN
- Transport - Package Maintenance and Operation - Rating: GREEN
- Transport - Training and Competence - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This inspection was undertaken in support of the permissioning strategy documented in permissioning record PR-01186. The purpose of the inspection was to inspect the SFL transport management system (related to transport package design) and to provide confidence that human factors arrangements have been adequately integrated into the transport package design process.
ADR / RID 1.7.3 requires a management system to be established and implemented for all transport activities within the scope of the applicable regulations. Competent Authority approval is contingent on the adequacy of the management system. SFL have a management system in place to:
- support the production of compliant PDSRs.
- facilitate the Competent Authority transport package design approval process.
- control changes to arrangements that impact transport participants.
There is evidence that relevant good practise is generally met, and legal duties are complied with. However, it was evident that there are deficiencies in the management system that require proportionate improvements, relating to:
- quality of package design related documentation.
- arrangements for training (competencies defined for the transport package design role are not adequately established to ensure that duties can be discharged, and there is not a clear development path with adequate training arrangements to support resilience).
When considered collectively, these shortfalls have a significant impact on the parts of the transport management system relating to package design. This has been evident during the approval process for PR-01185 and PR-01186, where there have been challenges in influencing proportionate improvements to package design safety reports.
I have given an overall inspection rating of AMBER. As this is a compliance shortfall, the judgement should not impact the approval of the Uranic Materials Container Type 3516 A, B and C design variants - I expect SFL to make proportionate improvements to their arrangements to ensure that future package design applications are compliant with the relevant regulations and meet relevant good practise.
Improvements will be established and monitored via a Level 3 Regulatory Issue (RI-12586).
Conclusion
ADR / RID 1.7.3 requires a management system to be established and implemented for all transport activities. Competent authority approval is contingent on the adequacy of the management system. SFL have a management system in place to:
- support the production of compliant PDSRs.
- facilitate the Competent Authority approval process.
- control changes to arrangements that impact transport participants.
There is evidence that relevant good practice is generally met, and legal duties are complied with. However, it was evident that there are deficiencies in the management system that require proportionate improvements, relating to the:
- quality of package design related documentation.
- arrangements for training (competencies defined for the transport package design role are not adequately established to ensure that duties can be discharged, and there is not a clear development path with adequate training arrangements to support resilience).
When considered collectively, these shortfalls have a significant impact on aspects of the transport management system relating to package design. This has been evident during the approval process for PR-01185 and PR-01186, where there have been challenges in influencing improvements to the package design safety reports.
I have given an overall inspection rating of AMBER. As this is a compliance shortfall, the judgement should not impact the approval of the Uranic Materials Container Type 3516 A, B and C design variants - I expect SFL to make proportionate improvements to their arrangements to ensure that future package design applications are compliant with the relevant regulations.
Improvements will be established and monitored in a Level 3 Regulatory Issue RI-12586.