Effective Analysis Submissions – A Regulator Perspective

Transport regulations require that the safety of packages containing radioactive materials be demonstrated deterministically by subjecting the package to a number of physical loadings which have been selected to simulate those which the packages may experience during routine, normal and accident conditions of transport. Such demonstration can be by analysis, physical tests or by reasoned argument. This paper discusses analysis submissions (i.e. those in which demonstration of safety is by means of analysis) from a regulator’s perspective, with the aim of explaining what regulators expect to see in such submissions. This perspective is based on the author’s current regulatory experience of “good” and “bad” submissions and on over thirty years previous experience as an analyst. It is expected that the more complex analyses will not be undertaken by the applicants themselves, but via a specialist, third-party contractor, with the applicants playing the role of an “intelligent customer”. The paper therefore also discusses the effective organisation of the analyses for this particular situation, and the required interactions between the regulator, the applicant and the analysis contractor.