Who is licensed to transport radioactive material?

Carriers routinely engaged in radioactive transportations are licensed to undertake such activity.  Other licensees include distributors, industrial radiographers and users of nuclear moisture density gauges. A small number of carriers are also licensed to transport Class 7 dangerous goods in Ireland. 

 

How are the regulations enforced? 

In Ireland, all businesses and practices which are involved in the transportation of radioactive materials are required to be licensed by the EPA. Licensees who transport or distribute sources of ionising radiation are obliged by law to 

  • Keep records. 
  • Keep records of incidents. 
  • Maintain a Risk Assessment and Radiation Safety Procedures. 
  • Notify the local Fire Officers in all relevant areas. 
  • Ensure the proper labelling of all radioactive materials. 
  • Comply with the requirements of the ADR. 

These are just some of the conditions imposed on licensees under the Radiological Protection Act, 1991 (Ionising Radiation) Regulations 2019 (Statutory Instrument 30 of 2019). 

Inspections by the EPA of licensees involved in road transportation also include an assessment of compliance with the current Carriage of Dangerous Goods by Road Regulations. 

 

Additional obligations for transport 

Over and above the normal licensing conditions, licensees involved in transporting radioactive material will be required to meet other obligations in line with the Regulations for the Safe Transport of Radioactive Material  published by the International Atomic Energy Agency (IAEA). 

The IAEA regulations are designed to protect people, property and the environment from the effects of radiation during transportation of radioactive material. 

They cover a range of requirements concerning 

  • Training 
  • Inspection 
  • Documentation and certification 
  • Packaging and containment 
  • Labelling, marking and use of placards 
  • Notification of competent authorities 
  • Storage and dispatch 
  • Security 
  • Accident prevention and contingency 
  • Testing 
  • Decontamination of vehicles and equipment 
  • Loading and segregation 

Transport of radioactive material by road in Ireland must be in accordance with the European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR).  This requires persons involved in the transport of dangerous goods by road, subject to some limited exemptions, to appoint a Dangerous Goods Safety Adviser (DGSA). Guidance on the appointment of a DGSA  is available from the Health and Safety Authority. 

Additionally, all drivers of Class 7 (radioactive) material must undergo training. Some drivers - depending on the number of packages carried and the dose rate characteristics of the package (transport index) - are required to have ADR Class 7 specialisation training.  

A Memorandum of Understanding (MoU) is in operation between the EPA and the Health and Safety Authority, which includes activities relating to the ADR and the transport of radioactive materials. 

Transport of radioactive material by sea is covered by the International Maritime Organisation (IMO) Dangerous Goods Code (IMDG Code).  The IMDG Code and its requirements are implemented by the Maritime Directorate (Marine Survey Office) of the Department of Transport, Tourism and Sport. The current edition of the IMO IMDG Code is referenced in all relevant licences.  Arrangements are also in place between the EPA and the Dublin Port Company (Harbour Master's Office) regarding the notification and movement of Class 7 goods through the port. 

For transport of dangerous goods by air, the Irish Aviation Authority(IAA) ensures that Irish aviation operates to safety standards set internationally, principally by the International Civil Aviation Organisation (ICAO).  In Ireland the ICAO Technical Instructions provide the basis for the regulation of the transportation of dangerous goods by air operators.  The EPA and IAA liaise on areas of mutual interest. 

 

IAEA Guidance on the Transport of Radioactive Material

The IAEA Safety Standard and Specific Safety Guides for the Transport of Radioactive Material