Title of document

Transporting radioactive material -

Security Guidance on the carriage of Class 7 radioactive material
Who is this guide for?
This guide has been prepared primarily to help non-nuclear sector duty holders transporting
radioactive material by road in Great Britain to determine:

 the security requirements to be complied with in the transport of all Class 7 radioactive
material; and
 the additional provisions to be implemented for transporting dangerous goods of Class
7, high consequence radioactive material.

Who needs to implement the security provisions for the transport of Class 7 radioactive
material and why?

The carriage of dangerous goods, including radioactive materials, is regulated by the Carriage
of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG).
All persons engaged in the carriage of Class 7 radioactive material by road shall consider the
security requirements set out in Chapter 1.10 of ADR* commensurate with their
responsibilities. This document provides guidance on the interpretation of the implementation
of the security provisions contained in the ADR.

For the purposes of Chapter 1.10 of ADR, security means measures or precautions to be
taken to minimise theft or misuse of dangerous goods that may endanger persons, property or
the environment.

General Provisions for the transport of all Class 7 radioactive material:

Company roles and responsibilities

Depending on the size of the organisation, there could be one or more persons managing
security. However, it is ONR’s expectation that one person in an organisation should have
overall responsibility and accountability for ensuring the security requirements are met. A
security function should be included in the job description of all persons engaged in the
carriage of radioactive material and they should ensure that they understand their
responsibilities.

Recruitment
Documentary evidence of the background and experience of anyone being recruited should
be obtained. When conducting pre-employment checks, candidates should be asked for the
following information:

 Full name.
 Address.
 Date of birth. Employers should insist on seeing the applicant’s original birth certificate,
not a photocopy.
 National Insurance or other unique personal identifying number where appropriate.
 Details of any past criminal convictions by requesting a disclosure certificate (where
this is allowed by law).
 Full details of references (where applicable).

Temporary storage during carriage of Class 7 radioactive material

Areas used for temporary storage of radioactive material shall be properly secured, well lit
and, where possible and appropriate, not accessible to the general public (Section 1.10.1.3 of
ADR refers).
All relevant areas should be subject to a security risk assessment to establish what measures
are required to prevent unauthorised access and action taken accordingly to reduce identified
risks. A Risk Assessment Template and information on conducting a Risk Assessment is
contained in the Department for Transport (DfT) publication, ‘Security Guidance on the
Carriage of Dangerous Goods by Road and Rail’, which is available on the DfT website at
https://www.gov.uk/government/publications/security-requirements-for-moving-dangerous-
goods-by-road-and-rail. This document also contains security guidance and measures for the
transport of all other classes of dangerous goods.

Identification

Each member of a vehicle crew shall carry with them means of identification, which
includes their photograph, during carriage of dangerous goods (Section 1.10.1.4 of
ADR refers).

Photographic identification must be carried at all times during carriage. A driving licence or
passport would be sufficient to meet this requirement.

Security Training

The training and the refresher training specified in Chapter 1.3 of ADR, shall also
include elements of security awareness (Section 1.10.2.1 of ADR refers).

Duty holders are required to provide security awareness training for everyone engaged in the
carriage of Class 7 radioactive material. This training shall include the actions to be taken
in the event of a security breach. In the event of a security breach, in addition to following
company procedures and notifying the police if applicable, the duty holder shall report the
occurrence to the competent authority, ONR, in accordance with the requirements detailed in
Section 1.8.5 of ADR. Duty holders should be aware of the procedures for reporting
occurrences to ONR, this can be found on the ONR website at
www.onr.org.uk/transport/index.htm

In addition to in house training, security training can also be obtained from private training
suppliers or government departments including the Centre for the Protection of the National
Infrastructure (CPNI) www.cpni.gov.uk and Counter Terrorism Security Advisors (CTSAs).
www.gov.uk/government/organisations/national-counter-terrorism-security-office

Security training shall be periodically supplemented with refresher training. It is recommended

that security awareness training is refreshed either at 2 to 3 yearly intervals or following a
significant event. Records of all security training received shall be kept by the employer and
made available to the employee or competent authority, upon request. Training records
should be retained in a secure location for a minimum of 4 years from the date of the training.

Provisions for High Consequence Radioactive Material

In addition to the above guidance duty holders involved in the carriage of Class 7 high
consequence radioactive material, also known as high consequence dangerous goods, are
subject to additional security requirements.

High consequence dangerous goods as defined in the ADR, are those which have the
potential for misuse in a terrorist event and which may, as a result, produce serious
consequences such as mass casualties, mass destruction or, particularly for Class 7, mass
socio-economic disruption (Section 1.10.3.1.1 of ADR refers).
Security Plans

Security Plans are required for carriers, consignors and other participants engaged in
the carriage of high consequence radioactive material (Section 1.10.3.2.1 of ADR
refers).

Duty holders are required to comply with a security plan that addresses at least the following
elements:
 specific allocation of responsibilities for security to competent and qualified
persons with appropriate authority to carry out their responsibilities: one person
should have full responsibility for security procedures and have sufficient authority to
design and implement these. The person responsible for security should control the
security plan and the sharing of the information as required within the organisation.
 records of dangerous goods or types of dangerous goods concerned: a
summary of the types of Class 7 radioactive material regularly carried should be
included. Records of Class 7 radioactive material transported, should be kept for a
minimum of 3 months from the date of carriage.
 review of current operations and assessment of security risks, including any
stops necessary to the transport operation and the intermediate temporary
storage of dangerous goods: the purpose and scope of the plan and an overview of
the current operation should be included at the start of the document. This will set out
the reasons for the plan, how and why it applies to the business and the carriage of
Class 7 high consequence radioactive material. Security plans should consider
whether drivers should be encouraged to keep their cab doors and windows closed
and locked throughout the journey.
 clear statement of measures that are to be taken to reduce security risks,
commensurate with the responsibilities and duties of the participant, including:
 training;
 security policies (e.g. response to higher threat conditions, new
employee/employment verification, etc.): consideration should be given to
changes to business or national threat levels. Up to date information and
guidance regarding the National Threat Levels can be found at
https://www.mi5.gov.uk/home/news/news-by-category/threat-level-updates.html
 operating practices: document how Class 7 high consequence radioactive
material is accepted and the process for determining specific security
requirements necessary for a particular movement such as how movements
are controlled and monitored to ensure security. Additionally, the plan should
detail how any problems with the movement are dealt with, for example during
unplanned stoppages.
 equipment and resources that are to be used to reduce security risks:
identify and record the equipment and resources deployed in the security
arrangements for Class 7 high consequence radioactive material movements.
 effective and up to date procedures for reporting and dealing with security
threats, breaches of security or security incidents: detail the system or procedures
in place for reporting a security incident or a security concern.
 procedures for the evaluation and testing of security plans and procedures for
periodic review and update of the plans: detail the requirement for testing of
security plans and the frequency for periodic review and update of the plans.
 measures to ensure the physical security of transport information contained in
the security plan: state how the information in the plan is protected from unauthorised
access e.g. held electronically on a password-protected computer in a location with
restricted access. If printed, the plan should be kept secure and treated as a sensitive
document, only to be shared with emergency services or the competent authority on
request. Everyone with access should be aware that this information should only be
made available on a need to know basis.
  measures to ensure that the distribution of information relating to the transport
operation contained in the security plan is limited to those who need to have it:
detail the measures in place to restrict the distribution of information about the Class 7
high consequence radioactive material transport operations to those who need to have
it.

Devices, equipment or arrangements to prevent the theft of the vehicle carrying high
consequence radioactive material and its cargo, shall be applied and measures taken to
ensure that these are operational and effective at all times. The application of these
protective measures shall not jeopardize emergency response (Section 1.10.3.3 of ADR
refers).

The application of measures to prevent theft will need to be determined by the transport
operator and the consignors. Examples of devices and equipment include locks, seals and
tracking devices. Duty holders should seek specialist advice from commercial organisations,
CTSAs or CPNI when appropriate. There should be a system in place for reporting failures of
devices, equipment or arrangements. It is advisable that drivers have a means of
communication at all times when carrying Class 7 high consequence radioactive material.
______________________________
* ADR refers to the European Agreement Concerning the International Carriage of Dangerous
Goods by Road. CDG refers to ADR requirements for road transport of dangerous goods in
Great Britain.