FINDINGS FROM NON-NUCLEAR SMALL USER INSPECTIONS IN 2009 / 2010

Towards the end of 2009, the Dangerous Goods Division of the DfT began a programme of inspections at the premises of smaller organisations whose business involves the transport of radioactive material. These organisations included industrial radiographers, hospitals, road construction services and couriers. The inspections were based on the requirements of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009. The majority of the requirements of these regulations are referenced from the European ADR 2009 Agreement, which, in turn, is based on the requirements of the IAEA TS-R-1 with regard to radioactive material. This paper presents a summary of the findings from approximately one hundred inspections carried out over the past twelve months. Across the inspected organisations, there were a number of common non-compliances against the above regulations. These non-compliances included: • Emergency Arrangements not prepared or tested, • Inadequate Instructions In Writing for drivers, • Transport Documents with incorrect / incomplete requirements, • Lack of training and awareness in transport security, • Radiation Protection Programmes with inadequate structure and review, • Package marking and labelling incomplete / incorrect, • Package and Special Form Certificates out-of-date / missing, • Insufficient Fire Extinguishers in the vehicle, • References to out-of-date regulations, • Driver training and certification incomplete, • Instrument calibration out-of-date, • Miscellaneous Equipment in the vehicle incomplete, • No Dangerous Goods Safety Advisor appointed. It is concluded that small organisations often do not have the capacity to implement complex regulations, and, where this is the case, there needs to be greater emphasis on appointing specialists to ensure that all transport-related activities are conducted in accordance with the applicable requirements.