LESSONS FROM THE PREPARATION OF PACKAGE DESIGN SAFETY REPORTS

he IAEA Transport Regulations [1] require that compliance assurance be carried out by competent authorities. The specific requirement is set out as follows in Paragraph 311 of ST-1 [1]. “The competent authority is responsible for assuring compliance with these Regulations. Means to discharge this responsibility include the establishment and execution of a programme for monitoring the design, manufacture, testing, inspection and maintenance of packaging, special form radioactive material and low dispersible radioactive material, and the preparation, documentation, handling and stowage of packages by consignors and carriers, to provide evidence that the provisions of these Regulations are being met in practice.” According to the draft advisory material to the IAEA Transport Regulations [2], amongst the measures that should be part of a competent authority’s compliance assurance programme are review and assessment, including the issue of approval certificates. A specific requirement relating to this is identified in Paragraph 311.6 of [2]. This states that “in order to ensure the adequacy of special form material and certain package designs, the competent authority is required to assess these designs. In this way, the competent authority can ensure that the designs meet the regulatory requirements and that the requirements are applied in a consistent manner by different users. When required by the Regulations, shipments are also subject to review and approval in order to ensure that adequate safety arrangements are made for” Consignors are required to make the following or equivalent declaration in the transport documents (Paragraph 550 of [2]). “I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name and are classified, packed, marked and labelled, and are in all respects in proper condition for transport by (insert mode(s) of transport involved) according to the applicable international and national governmental regulations.” Unless the contents and the packaging together form a package that complies with the IAEA Transport Regulations [1], the declaration cannot be signed. From these requirements, it can be concluded that a package designer needs to be able to demonstrate that the package meets the relevant requirements of the IAEA Transport Regulations [1] in order that the competent authority can carry out its role of compliance assurance and also so that the consignor can sign the consignor’s declaration prior to transport. The Package Design Safety Report (DSR) is a key document in achieving this, and this paper reviews aspects of the structure and production of DSRs.