The Carriage of Dangerous Goods (Amendment) Regulations 2019 – Radioactive Substances

The regulations are currently at a draft stage and there are a few parts which will hopefully be amended prior to them becoming law.

This should have been completed by the 5th of February, but apparently there is something else on the agenda that has been taking up a lot of time.

These regulations will be of particular interest if you consign or carry any type of Class 7 goods. Including excepted packages.

The Schedule of CDG 2019 replaces Schedule 2 of CDG 2009.

It is this schedule which covers radiological emergencies.

You will need to update your emergency plan and radiation risk assessment in order to comply with CDG 2019.

Proposed notable amendments include;

• 3 year review requirement,
• notification of review outcome to ONR (ONR are trying to have this removed from the regulations),
• the provision of a risk assessment which covers the transport operation, from both a consignor and carrier, is made part of the CDG regs (this will need to have been carried out by a Radiation Protection Advisor (RPA) -who will also be able to let you know if you need to notify or register with the HSE under the new (ish) Ionising Radiation Regulations 2017)
• the emergency plan now has specified elements and requirements
• these include specific dose limits and a procedure to notify an emergency to the relevant local authority

The ONR are set to produce draft guidance to help duty holders, defined as consignors and carriers, comply with CDG 2019. This will be released when CDG becomes law.

There is a 12 month transitional period, during which arrangements made under Schedule 2 of CDG 2009 (as amended) can still be used.