Executive summary
Date(s) of inspection
- November 2025
Aim of inspection
The aim of the inspection is to review the arrangements of Eckert & Ziegler Environmental Services Ltd (EZE) with respect to the safe transport of radioactive materials (in accordance with SSR-6 paragraph 104) to support Operation Fieldfare - a cross government programme of activities led by The Home Office, which aims to reduce the threat to the UK by replacing caesium-137 irradiators used in biological and biomedical research facilities and dispose of these radioactive sources, where a viable alternative technology or solution exists.
Subject(s) of inspection
- Transport - Consignor Duties - Rating: GREEN
- Transport - Emergency/Contingency Planning and Testing - Rating: Cancelled
- Transport - Incidents, Events and Reporting processes - Rating: Cancelled
- Transport - Management Systems - Rating: GREEN
- Transport - Package Maintenance and Operation - Rating: GREEN
- Transport - Package Manufacture and Supply Chain - Rating: Cancelled
- Transport - Radiation Protection Advisor - Rating: GREEN
- Transport - Radiation Risk Assessment - Rating: GREEN
- Transport - Security - Rating: Cancelled
Key findings, inspector's opinions and reasons for judgement made
We undertook a compliance inspection of Eckert & Ziegler Environmental Services Ltd (EZE) to inspect its management system arrangements and capability to deliver the pilot phase (Phase 2+) of Operation Fieldfare (a cross government programme of activities led by The Home Office, which aims to reduce the threat to the UK by replacing caesium-137 irradiators used in biological and biomedical research facilities and dispose of these radioactive sources, where a viable alternative technology or solution exists) as contracted by the Nuclear Decommissioning Authority (NDA).
The inspection focused on three key areas:
- The use of the PO-09 transport package;
- Compliance with aspects of the Ionising Radiations Regulations 2017 (IRR17); and,
- Supply chain management.
We identified that EZE has an integrated management system to support safe and compliant transport of radioactive material, and that it is broadly complaint with the relevant regulations. EZE has identified risks with respect to the use of the PO-09 transport package and is effectively managing the risks. We sampled several documents and some shortfalls were identified in relation to the EZE management system - ONR will track the development and implementation of improvements by raising a regulatory issue.
Conclusion
EZE has an integrated management system to support safe and compliant transport of RAM. Legal duties are generally complied with and there are no significant shortfalls identified in the delivery of safety. We noted several areas where relevant good practice is met.
Some shortfalls identified when compared with appropriate benchmarks include:
- EZE recognised that the management system would benefit from alignment with TS-G-1.4, and in particular: a matrix that maps the management processes to higher level requirements to ensure that legal duties are discharged; clearer articulated roles and responsibilities aligned to participant duties; clear processes and procedures relating to radioactive material transport; and, a better structured and accessible management system that reflects the business needs.
- EZE did not have a contract with their carrier GSR and had not undertaken assurance activities of GSR as a carrier. EZE explained that this was because GSR is part of the same parent company, Eckert & Ziegler Group. We explained that GSR is a separate legal entity to EZE and therefore EZE should have arrangements for the selection, assurance and oversight of suitable contractors, including GSR, in accordance with TS-G-1.4. We did not consider this to be a safety risk because:
- EZE have a close working relationship with GSR;
- Both organisations routinely transport irradiators and HASS in the UK and abroad;
- On ONR's request, EZE provided evidence that GSR are compliant with various domestic legal requirements (in particular, IRR17); and,
- Following the inspection and prior to the production of this report, EZE and GSR entered into a contract requiring GSR to undertake carrier activities to support Operations Fieldfare.
EZE has identified risks with respect to the use of the PO-09 transport package and is effectively managing the risks through the RRA and documentation (including a local operating instruction EZE-OP-WI-024 for the PO-09) that flows out of the RRA. It was identified that improvements are required to the RRA and contingency plan – these improvements were made immediately after the inspection.
The overall inspection rating is GREEN. To address the shortfalls identified above I have raised a level 4 regulatory issue (RI-12849) to monitor proportionate improvements I expect EZE to make to its management system, including supply chain management arrangements.