- Site: Transport Competent Authority
- IR number: 20-032
- Date: November 2020
- LC numbers: N/A
Executive summary
Purpose of Intervention
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) and the Ionising Radiations Regulations 2017 (IRR17). CDG refers to the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and ONR regulated against ADR 2019 during this inspection (www.unece.org).
Purpose of Intervention
The purpose of the inspection was to review NDT Group Ltd’s arrangements associated with the road transport of radioactive material. ONR carried out this inspection at NDT Group Ltd’s Deeside facility on 4 November 2020.
A Health and Safety Executive (HSE) Inspector carried out a non transport IRR17 inspection in parallel to the transport inspection.
Interventions Carried Out by ONR
The chosen inspection sample included:
- Notification, registration or consent – IRR17 Regulation 5, 6 or 7;
- Radiation protection adviser – IRR17 Regulation 14;
- Safety Adviser – RID 1.8.3
- Transport package certificate of compliance – ADR 5.1.5.2.3
- A suitable and sufficient radiation risk assessment (RRA) – IRR17 Regulation 8;
- Suitable and sufficient contingency planning and/or emergency arrangements – IRR17 Regulation 13 and CDG 2009 Regulation 24 & Schedule 2;
- Suitable and sufficient measures to restrict exposure – IRR17 Regulation 9;
- Suitable and sufficient Local Rules – IRR17 Regulation 18;
- Transport documentation – ADR 5.4;
- Equipment on board – ADR 8.1.5.2; and
- Orange coloured plate marking – ADR 5.3.2
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The inspector sampled the arrangements deployed by NDT Group Ltd 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. A number of examples of the duty holder meeting relevant good practice in reducing risk to levels that are ALARP were identified including: appropriate consent; appropriate Radiation Protection Adviser, Dangerous Goods Safety Adviser and Radiation Protection Supervisor appointments; a suitable and sufficient RRA, having Local Rules and contingency arrangements and appropriate equipment and marking on vehicles.
During the inspection, the inspector suggested two improvements to transport practices that would be prudent for NDT Group Ltd to consider; minor updates to the RRA and the need to confirm ONR contact details included in contingency arrangements are correct.
Conclusion of Intervention
NDT Group Ltd demonstrated that for the aspects of its transport operations inspected it met the requirements of CDG, ADR and IRR17.
Based on the inspection sample, the inspector suggested two improvements to transport practices that would be prudent for NDT Group Ltd to consider and NDT Group Ltd gave a commitment to address them.
For this intervention, an overall IIS Rating of GREEN, No formal action, was given to reflect that legal requirements were being met.