For the transport of Class 7 radioactive material as an “Excepted Package” under ADR the appointment of a DGSA is not a requirement.
There will however be some very significant changes across all transport modes for excepted packages from 2015.
The changes are based on the updated International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material, 2012 edition.
The following references are from the changes to ADR 2013, updated to ADR 2015.
Excepted packages already have to comply with the general construction requirements of ADR Chapter 6.4.4.
A new provision is added in 220.127.116.11.1 to require compliance with ADR 18.104.22.168.2 or 22.214.171.124.3 as applicable.
For consignors of excepted packages that do not require CA approval or authorisation, this means that the consignor must hold documentary evidence that the package design conforms to the requirements of 6.4.4. and make this available to the competent authority on request.
If the material authorised for transport as an excepted package is also classified in another class by way of special provision 290 or 369, a further paragraph is added to 126.96.36.199.1 to specify that compliance with the other provisions relating to the main class is also required.
Excepted packages must now also comply with 188.8.131.52; CV33
(3.1) – Consignments shall be securely stowed
(5.1) – Assessment of contamination and restriction of area if it is discovered that a package is damaged or leaking
(5.3) – Periodic checking of vehicles regularly used for the carriage of radioactive material
(5.4) – Decontamination of vehicles
(6) – Procedure to be followed, including notification to the CA if a consignment is undeliverable.
In addition to,
(5.2) – Damaged packages shall be removed from the vehicle, under supervision, to an interim location and shall not be forwarded until repaired, reconditioned or decontaminated.
Which was already a requirement under ADR 2013.
Further amendments and additions are made to 184.108.40.206.2 to require excepted packages that are subject to CA approval and/or permissions to require the CA reference and approval certificate identification mark to be shown on transport documents.
Transport documents used for excepted packages must now be retained for a period of 3 months in accordance with 5.4.4.
At EcoStar we provide consultancy and training services for the transport of all classes and divisions of dangerous goods.