Truck and Track Spring 2024

Truck and Track Spring 2024 www.truckandtrack.com 58 DANGEROUS GOODS More details on making notifications and applying for registration and consent can be found via the websites below: ■ Ionising Radiations Regulations 2017 — ‘Graded Approach’ https://www.onr.org.uk/irr17/index.htm ■ Working with ionising radiation: notify, register or get consent https://www.hse.gov.uk/radiation/ ionising/notifiy-register-consent.htm ONR has recently engaged with a number of transport dutyholders who don’t have IRR17 registration and consent, so it would urge all transport dutyholders to seek advice from their appointed Radiation Protection Advisers (RPAs) to ensure all requirements are in place. As a regulator, what powers do you have, particularly in relation to the transport of radioactive material? ONR is the competent and enforcing authority for CDG and the enforcing authority for IRR17 for the civil transport of class 7 dangerous goods (radioactive material) by road and rail. It undertakes transport compliance inspections* of nuclear and non-nuclear dutyholders to ensure they are meeting their legal obligations, performs roadside stops* of vehicles carrying radioactive material, investigates transport incidents that dutyholders are required to report to ONR through its INF1 notification system*, assesses packages that require competent authority approval and issues package approvals. If ONR identifies non-compliances, it has the power to take enforcement action. This can range from informal enforcement action such as regulatory advice provided in inspection records and enforcement letters (requiring specific action to be taken within certain timescales) to formal enforcement action such as the issue of improvement and prohibition notices. Ultimately, ONR can stop the transport of radioactive material and can instigate prosecutions against non-compliant transport dutyholders. ONR’s Enforcement Policy Statement* and Enforcement Technical Inspection Guide* explain this in more detail. These documents, together with information about ONR enforcement action, can be found in the Enforcement section of the ONR website*. Radioactive material has a variety of uses, which many people won’t be aware of. Can you give some examples of the dutyholders that ONR regulates and how they use radioactive material? In addition to nuclear dutyholders, we regulate non-nuclear industrial, medical and carrier dutyholders such as: ■ radiography companies who use special form (sealed) sources to undertake non-destructive testing of components in dedicated facilities and on sites ■ companies who have to deal with waste material from the cleaning of oil and gas drilling which may be contaminated by naturally occurring radioactive material ■ universities who undertake research work involving radioactive material ■ hospitals who use radioactive material to treat patients ■ companies who have in-transit depots at airports/ports where material is stored prior to collection for road transport Most of us don’t understand the risks of radioactive material. When we see a Class 7 hazard label or ’Radioactive material trefoil’ mark, should we be extra cautious? There is a graded approach to radioactive material transport packages. This means that, as the potential hazard associated with radioactive material increases, so do the requirements for package robustness, labelling, vehicle placarding and emergency planning. Provided transport dutyholders comply with these requirements for the radioactive material they are transporting, the risk to members of the public is very low. ONR transport compliance inspections, roadside stops of vehicles, investigations into transport incidents and package assessment work are all undertaken to confirm transport dutyholders are meeting their legal obligations to keep risks to as low as is reasonably practicable. What are the differences in hazard posed by the different categories of Class 7 dangerous goods – and what does the term ‘Fissile’ mean? There are various Class 7 dangerous goods United Nations (UN) numbers which form a graded approach to classifying the hazards associated with radioactive material. They vary from UN numbers associated with excepted packages (which are considered to pose the least hazard) through to UN numbers for Type B and C packages (which reflect the greater hazard posed by the contents). Some packages are permitted to contain fissile material which is material that can, under specific conditions, generate large amounts of heat and radiation through fission (when atoms are split apart to form smaller atoms, releasing energy). The most A roadside CDG stop

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