Executive summary
Date(s) of inspection:
July 2025
Aim of inspection
We conducted preliminary enquiries with EnerMech Limited on 28 January 2025 (see IR-53763) following notification to ONR from Direct Rail Services Limited (DRS) that EnerMech Limited were not compliant with IRR17 (see INF-4597). We identified that EnerMech Limited were a subcontractor to DRS for the loading/unloading of Class 7 dangerous goods at DRS railheads. We concluded that from contract award in 2021 to November 2024, EnerMech Limited operated in contravention of IRR17 Regulations 6, 8, 14, 15 & 16 and the requirements of ADR/RID 1.3, 1.8.3 and 1.7.2, i.e. in contravention of CDG09 Regulation 5.
Following our enquiries, I:
- served, in accordance with the Enforcement Management Model and Enforcement Policy Statement, an enforcement letter (ONR-EL-24-46) to EnerMech Limited; and
- raised a Level 3 regulatory issue (RI-12431) to track and monitor the dutyholder's progress towards compliance.
This inspection aims to ensure that the dutyholder had completed by 30 June 2025 the necessary actions to ensure compliance with the relevant legislation, as stipulated in the enforcement letter. This will allow the enforcement letter and the regulatory issue to be formally closed.
Subject(s) of inspection
- Transport - Dangerous Goods Safety Advice - Rating: GREEN
- Transport - Incidents, Events and Reporting processes - Rating: GREEN
- Transport - Management Systems - Rating: GREEN
- Transport - Radiation Protection Advisor - Rating: GREEN
- Transport - Radiation Protection Programme - Rating: GREEN
- Transport - Training and Competence - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The inspectors completed a targeted inspection of the dutyholder's progress in reviewing and revising where necessary their management system for the transport of Class 7 dangerous goods to ensure compliance with the requirements of IRR17 and ADR/RID (and hence CDG09), as required by enforcement letter ONR-EL-24-46.
The inspectors identified examples of the dutyholder meeting relevant good practice in the review/revision of their transport management system, training and competence programme and cooperation with other transport dutyholders in the sharing of relevant information.
The inspectors concluded that the dutyholder had implemented improved arrangements within its transport management system as required by enforcement letter ONR-EL-24-46 and that, subject to receipt of the dutyholder's updated management procedure for Class 7 dangerous goods transport (ENM-EUR-GBR-CAL-PRO-0011), the enforcement letter and the associated Level 3 regulatory issue RI-12431 should be closed.
Conclusion
The inspectors presented their findings to the dutyholder at the close of the inspection.
We rated all of the thematic areas as GREEN and we judged that an overall inspection rating of GREEN was appropriate in accordance with our guidance in ONR-INSP-GD-064 Issue 6.1.
The inspectors judged that the dutyholder had reviewed and revised its management system to ensure that it was adequate to ensure compliance with ADR/RID, as required by ADR/RID 1.7.3. The inspectors concluded that the dutyholder had complied with the requirements of our enforcement letter ONR-EL-24-46 and hence the enforcement action and associated Level 3 regulatory issue (RI-12431) could be closed.