latest from ONR Transport
On the non-nuclear transport front, inspections, stakeholder engagement and policy work in support of BEIS as BSSD implementation draws closer have all been matters occupying the Transport Inspection and Enforcement Team recently. Here are the headlines from the last few months.
BNMS members may wish to note that there is information on the ONR Transport webpages providing a steer on aspects of the changes that the 2017 European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR17) introduces. This can be found at:-
ONR has analysed the differences between ADR15 and ADR17 in relation to Class 7 dangerous goods, and summarised the key changes between the two versions. The changes highlighted do not form an exhaustive list, so transport dutyholders are reminded to seek competent advice as appropriate when looking to meet their duties under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG).
The transitional period ended in June 2017, so ADR17 is now in force.
A number of medical sector transport inspections have taken place in the first half of 2017. The content of emergency arrangements and their testing was a common theme requiring further consideration and action by a number of dutyholders.
How would you, as consignor, respond to a radiological emergency involving your packages in transit? And if the driver is incapacitated and a call comes in to your Department from attending emergency services, what practical steps would you take to assist in the intervention? Who has the competency and kit to assess the condition of the package? If the response resides in-house, do you know what you would take and is it ready to go or can you get it together readily? You will need to be mindful of personal safety (including manual handling and reliable telecomms) alongside the potential for elevated dose rates or radioactive contamination. Do you need to take a replacement transport package? Is there an alternative vehicle available if required? And if theft or loss is suspected, what happens then?
If you haven’t already done it, please do take the time to think through the detail of your transport emergency arrangements so that you and others involved know what to do if that call ever comes in, and do challenge your arrangements by testing them periodically. Learning from testing can be invaluable. [CDG Regulation 24, Schedule 2, (4), (5) and (6) refer as does ONR guidance, the link for which is :- http://www.onr.org.uk/transport/emergency-arrangements-guidance.pdf]
On another matter, an inspector has recently commented:-
‘security staff, who escort drivers delivering radioactive materials overnight, had not received any training in regards to their role in the transport of such materials or on radiation protection matters.’
Deliveries do happen out of hours, and arrangements for these deliveries and collections of radioactive material do require advance planning (between carrier and consignor/consignee) and a robust system of ensuring they happen in an appropriate way. Arrangements can include security staff accompanying drivers to the delivery point. ADR 1.3 requires those whose duties concern the carriage of dangerous goods to be trained in the requirements governing the carriage of such goods appropriate to their responsibilities and duties and ADR184.108.40.206 requires that workers shall be appropriately trained in radiation protection including the precautions to be observed in order to restrict their occupational exposure and the exposure of other persons who might be affected by their actions. Transport dutyholders are required to ensure appropriate training is provided to these staff commensurate with duties. Refresher training should be delivered periodically thereafter (ADR 220.127.116.11) with all training records being kept (ADR 1.3.3 refers.) Note: ADR 1.10.2 also discusses requirements for security awareness training.
Sources of information
Last time around I provided a link to ADR17 but it may be of assistance to have links to CDG and the Approved Derogations etc so here they are :-
CDG (2009, and amendments in 2011)
The Carriage of Dangerous Goods: Approved Derogations and Transitional Provisions
ONR Transport guidance
ONR is carrying out a review of transport guidance material written for the non-nuclear sector to highlight legal requirements in certain key areas, and ONR expectations. It is now around two years since this material started being published on our web-pages, the first topic being transport emergency arrangements. ONR will be re-visiting this material shortly and adding a little more detail where recent inspection experience has shown there to be difficulties in interpretation, or a lack of awareness. If you have any comments on the current content, or have some thoughts on future content, then please do let me know. Comments by the end of August 2017 would be appreciated in relation to emergency arrangements guidance in particular http://www.onr.org.uk/ Constructive comments are always welcome in relation to all the ONR Transport guidance we produce to help the non-nuclear sector to achieve compliance.
Getting in touch with ONR
Unfortunately there has been a need for a further change to the contact details for ONR Transport as described below. Please accept my apologies for the inconvenience that having to update this information in your transport documentation (again) causes. For those of you with a keen eye, you will note it is the daytime incident number that has changed. You should be aware that the current number will continue to be transferred to this new number for the foreseeable future but it would be prudent to update this contact information now.
In the event of a transport incident, contact ONR by phone Mon to Fri between 8am and 5pm on 0151 922 5911, or at other times on 0151 922 9235.
Also, the email address previously advised, the Class 7 account, is no longer the one to use for general enquiries. The advice now is as follows:-
In the case of general queries relating to the transport of radioactive materials, advice should be sought in the first instance from a DGSA.
If this does not resolve the matter ONRenquiries@onr.gov.uk can be used to contact ONR.
By Lindsey Cairns, 4 July 2017