RISK BASED MODEL FOR COMPLIANCE ASSURANCE INSPECTIONS FOR THE NON-NUCLEAR SECTOR - Presentation

In 2002 The UK was appraised by an IAEA team (TranSAS-3). Three recommendations were made. Recommendation 3 was ‘... the DfT should evaluate the adequacy of its inspection programme ... minor consignors and consignors of mobile sources should be more fully integrated into this programme. Priorities should continue to be risk based...’ Within the UK it’s a legal requirement for organisations holding RAM to be licensed. The database of holders is approximately 3000. Potentially, all these organisations transport RAM. DfT has 3 inspectors ensuring compliance in this sector. The team will audit approximately 120 organisations annually. Nominally, organisations are inspected every 3 years. We would inspect 360 organisations or 12% of our duty holders. It is essential that prioritisation is established. In 2008 DfT sent a questionnaire to its duty holders. Answers were used to create a risk model that used the following parameters: number of RAM items held; amount of activity (relative to package type); number of movements made annually; if the organisations QA system is registered; if the QA system covers RAM transport ; and if the organisation’s aware of security requirements. For each parameter a ‘normal amount’ was established and a ‘normal’ risk total proposed. A value above that total indicated an organisation worth visiting. It was recognised that some organisations below the cut-off should also be inspected to confirm the thresholds appropriateness. A spreadsheet recorded information from the questionnaire and risks were calculated. Nil returns were given a default value that exceeded the ‘safe’ threshold. Inspectors then targeted the higher risk organisations The inspection’s output was a list of non-compliances. To validate the risk model we assigned an actual ‘risk’ to each inspected organisation. A numerical value was agreed at a team meeting and assigned to each category of non-compliance. We now had a hypothetical and objective risk value for each organisation. The risk model was then amended accordingly and continues to be used to guide the inspection programme and also to inform where education and dissemination of information is required.