- Site: Transport Competent Authority
- IR number: 20-044
- Date: February 2021
- LC numbers: N/A
Executive summary
ONR regulates the civil transport of radioactive material by road, rail and inland waterway in Great Britain (GB). The ONR Transport Competent Authority (TCA) is responsible for delivering non-nuclear transport inspection and enforcement activities. This particular inspection forms part of that delivery function with reference to Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG), the Ionising Radiations Regulations 2017 (IRR17) and the Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR used ADR 2019 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review Tracerco Limited’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection remotely using MS Teams on 3rd February 2021.
Interventions Carried Out by ONR
The chosen inspection sample included:
- notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- a suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- suitable and sufficient Contingency Planning and/or Emergency Arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- adequate information, instruction and training – IRR17 Regulation 15 and ADR 1.3.1;
- adequate Security arrangements – ADR 1.10;
- a suitable and sufficient Management System – ADR 1.7.3.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements implemented by Tracerco Limited for the safe transport of radioactive materials, including the associated arrangements for protecting workers against the effects of ionising radiations and reducing risks as low as reasonably practicable (ALARP).
The inspector compared relevant statutory requirements with both prescribed arrangements and actual practice. The inspector identified a number of good examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP, including having a good knowledge of current legislation, having a satisfactory Radiation Risk Assessment, having emergency procedures in accordance with CDG amendment regulations, having suitable employee training programmes and having suitable security arrangements. The inspector identified one non-compliance relating to restriction of exposure to its third-party drivers. This issue was discussed during the inspection.
During the inspection, the inspector also suggested certain improvements to transport practices that would be prudent for Tracerco Limited to consider.
Conclusion of Intervention
Tracerco Limited demonstrated that for the majority of its operations it met the requirements of CDG, ADR and IRR17. Based on the inspection sample, the inspector identified a non-compliance with relevant legislation and suggested three minor improvements. The inspector discussed this during the inspection and Tracerco Limited gave a commitment to address it.
The inspector gave Tracerco Limited until 12 March 2021 to provide ONR either with evidence that the finding has been resolved, or an appropriate resolution plan with timescales for completion.
For this intervention, an overall IIS Rating of GREEN was given to reflect that legal duties are complied with, although there was a minor contravention of a specific administrative requirement.
ONR will monitor the identified non-compliance through its Issues Management arrangements.