Office for Nuclear Regulation

Ionising Radiations Regulations 2017 (IRR17) and transport of radioactive material - Frequently asked questions

This information is relevant in the nuclear and non-nuclear sectors where dutyholders transport radioactive material by road, railway, inland waterway or through a public place.

Where work with ionising radiation is carried out exclusively or primarily on nuclear premises, and is therefore not transport, please refer to ONR's main IRR17 webpages.

When does IRR17 come into effect?

IRR17 comes into effect on 1 January 2018, although there are various transitional provisions, notably around graded approach requirements, which need to be addressed on or before 5 February 2018.

Does IRR17 apply to transport?

Yes, it does. Transport is considered to be a practice in IRR17 as it was in the Ionising Radiations Regulations 1999 (IRR99).

Who enforces IRR17 for transport?

Except where transport is undertaken for defence purposes, ONR is the enforcing authority for IRR17 in relation to transport by road and railway, previously enforced under IRR99 by HSE and ORR respectively. ONR is also responsible for enforcing transport by inland waterway (although in practice transport by inland waterway happens very rarely). Transport for defence purposes remains with HSE as the enforcing authority. IRR17 transport is enforced by the Civil Aviation Authority (CAA) and Maritime and Coastguard Agency (MCA) in relation to air and sea transport respectively.

The detail of the recent change in enforcement responsibility features in amendments to the Health and Safety (Enforcing Authority) Regulations 1998 and the Health & Safety (Enforcing Authority for Railways and Other Guided Transport Systems) Regulations 2006.

For the purpose of enforcement transport includes preparation (e.g. packaging) through to unloading at the destination, including any in transit storage. 

Requirements of The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG09) will also apply throughout transport as defined in IRR17.

Do I need a notification, registration or consent for transporting radioactive material? And if so, where do I get one from?

Depending upon the amount of radioactive material you transport you will need to make a notification, apply for registration or seek consent as transport is specifically defined as a practice in IRR17 for this purpose.  In this regard transport begins with loading onto a conveyance and ends with unloading from the conveyance.

HSE is the 'appropriate authority' to which all applications in respect of transport must be made (including for dutyholders based on Nuclear Premises).  Movement of radioactive material between different locations on nuclear premises does not constitute “transport. Requests must be made to HSE via their online process, which is scheduled to be available from 3 January 2018.

There are other functions assigned to the appropriate authority in IRR17. Who would this be in the case of transport?

In relation to transport of radioactive material the 'appropriate authority' wherever it occurs in IRR17 will always be HSE. For example, where an overexposure (Regulation 26) occurs, or a spill or release, or loss or theft of material (Regulation 31), and where any of these events involve transport, then the relevant details should be reported to HSE as the appropriate authority. Notification should be sent to ONR and HSE are working together to ensure that relevant information is exchanged and inspection, investigation and enforcement of IRR17 for the practice of transport is undertaken appropriately following implementation.

Please note that a transport incident or event may also need to be notified to ONR but in line with CDG09 obligations. For details please refer our main transport webpage noting that where immediate notification is required, please telephone 0151 922 5911 (during office hours, Mon to Fri 08:30 till 17:00 excluding public holidays) and at all other times, call 0151 922 9235.