ONR’s expectations of adequate Emergency Arrangements

Background:The carriage of dangerous goods by land in Great Britain is governed by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG), which includes requirements for radiological emergencies. ONR’s experience is that some duty-holders would benefit from further guidance to discharge these duties.Factors to consider when writing a plan:The plan should provide clear instructions to the driver, carrier and consignor. Typically the driver will initiate emergency plans; however there should be contingency arrangements in case the driver is unable to take appropriate action.The plan should address the following:-• immediate notifications to be made• actions to protect the driver• prevent the situation from deteriorating• actions to protect the public• actions to protect the emergency services on their arrival• actions to ensure the radioactive materials remain secure without compromising emergency response.• actions to be taken by the consignor• specialist advice• interfaces with other organisations, regulatory environments, and potential cross-border effectsMaking plans effective:Training should be delivered to ensure that everyone understands their duties. Drivers should have copies of the plan accessible in the vehicle. Equipment required by the plan should be carried whenever radioactive material is transported. Where the consignor and carrier have separate plans, arrangements should ensure that there are no conflicts. If there is just the one plan, both the carrier and consignor should be familiar with their roles.Testing emergency arrangements:If a plan is used more than once, it must be tested. How, and how often, is not specified but should be proportionate to the risks (typically, annually). Duty-holders should be able to justify their approach.All relevant aspects of the plan should be tested, and the test should be recorded. The plan should be reviewed and updated if required to reflect experience and regulatory changes, with all relevant people being advised of any changes to the plan as these occur.Tests could include desktop exercises, partial or full simulations involving some or all elements of the arrangements. Testing should not take place in public or involve radioactive material. Emergency services should only be involved with their agreement.