Regional Workshop for the Safe Transport of Regional Workshop for the Safe Transport of Radioactive Material in the CaribbeanRadioactive Material in the Caribbean

Module 4.6 Module 4.6 Denial of Shipment

Paul GrayVice President

External Relationships and Global LogisticsNordion, Inc.

Canada

June 5, 2014Panama City, Panama

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OverviewOverview

• Introduction• International activities on denials of

shipment of radioactive material• The NFP handbook for addressing denials of

shipment• Current status• Future activities• Summary

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Why transport radioactive materials

Radioactive materials are produced in only a few facilities in the world. From there they have to be carried to the end user : a hospital, a factory, a power station or a home. Some of these radioactive materials have a short useful life, and must therefore be transported by air. Regardless of the mode of transport, efficient and reliable movement of these products is required.

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Regulations for the safe transport of radioactive material

Transport of radioactive material is governed by international modal regulations. IMO, ICAO and other international organizations adopt and integrate with the IAEA Regulations. The regulations specify design safety standards for radioactive materials and packages, and control measures during transport. A radioactive consignment which satisfies IAEA regulations is safe for handling, transport, and storage.

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History of Safe TransportHistory of Safe Transport

“Over several decades of transport, there has never been an in-transit accident with serious

human health, economic or environmental consequences attributable to the radioactive

nature of the goods.”

Source: IAEA International Conference ; Abu Dhabi, 2013

Still applies today! An exemplary record over 60 years.

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Instances of delay / denial

In some ports, radioactive shipments are delayed or stopped.

Carriers refuse to take radioactive cargo because:

Special requirements and fees for handling radioactive material.

Ship allowed in port only if the radioactive material on board the

ship was intended for use in that country and not otherwise!

Port official thought radioactive consignments were unsafe!

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What is a denial and what can we do?What is a denial and what can we do?

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A denial is “a refusal to carry or allow a shipment of radioactive material though it conforms to all the applicable regulations”. All applicable regulations include international as well as national regulations. Non-compliance with regulations cannot constitute a denial. National regulations may have additional requirements for transport of radioactive material. If however such additional requirements result in a denial this should also be reported. This applies also to additional operational requirements by carriers which may result in a denial.

How can denial related problems be solved?The means/methods/mechanisms established by National Focal Points to resolve instances of denial are varied depending on the situation and the location.

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History and Framework 

In recent years there have been many reported instances of denial of radioactive shipments despite compliance with national and international regulatory requirements and good transportation practices. National Focal Points (NFP) in Member States have been established as well as a reporting system on denials and delays in an effort to resolve the issues. Member States should assign responsibilities, authority and resources to support the NFP. The role of the NFP and the Regional Coordinator (RC) in dealing with denial of shipment of radioactive material is pivotal to ensuring that the causes are successfully resolved. The NFP acts as the Focal Point for all matters related to denial of shipment of radioactive material in their country. The RC functions to support the activities of a number of NFPs in a specific geographic region. 

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International activitiesInternational activities

• 2003: International Conference on Safe Transport of Radioactive Material´s findings included:– Industry was facing problems to timely deliver

radioactive material even when the consignments complied with IAEA Regulations.

• 2006: Establishment of the International Steering Committee on Denials of Shipment of Radioactive Material (ISC)

• 2013: IAEA goal : Denials of Shipment reduced to non significant level – End of ISC lifetime

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Objective of the ISCObjective of the ISC

To serve as a mechanism to facilitate the

establishment of a comprehensive

international work plan of activities

related to denials and delays of shipment

of radioactive material

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ISC - Membership (1) ISC - Membership (1)

• IAEA – International Atomic Energy Agency

• IMO – International Maritime Organization

• ICAO – International Civil Aviation Organization

• IFALPA – International Federation of Airline Pilots Associations

• ICHCA - International Cargo Handling Co-Ordination Association

• IAEA Member States

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ISC - Membership (2)ISC - Membership (2)

• Transport organizations - Edlow International, USA; REM, Brazil

• Suppliers of radioisotopes – ISSPA (International Source Suppliers and Producers Association) and Nordion Inc.

• Transporters of industrial ores – TIC, Tantalum-Niobium International Study Centre,

• Nuclear industry – WNTI (World Nuclear Transport Institute) and WNA (World Nuclear Association)

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The nature and extent of the issuesThe nature and extent of the issues

1. To know the scenario

2. To attack the root causes

3. To quantify the problem

4. To diminish the instances

Initially, evidence of denial causes, location and frequency was not accurate enough

IMO and IAEA established a database

around an agreed data format13

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Six areas of ISC Action Plan FocusSix areas of ISC Action Plan Focus

• Awareness, regarding the events, their consequences, the underlying issues and their resolution;

• Training of service providers;• Communication to educate service providers;• Lobbying for marketing, outreach and promotion of

industries requiring transport of radioactive material;• Economic assessment and measures to identify and

reduce economic burdens causing sustainability problems;

• Harmonisation of international requirements

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The six areas integrated in the Action PlanThe six areas integrated in the Action Plan

• The ISC set out a challenging action plan with some 200 actions in the six areas to combat denials

• Over time many of these actions have been completed and some have been consolidated

• In 2012 the outstanding list of actions was reduced to around 15

• There have been several successes, and some of the actions completed are useful on an ongoing basis

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The NFP Handbook for Addressing The NFP Handbook for Addressing DenialsDenials

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THE NATIONAL FOCAL POINT AND REGIONAL COORDINATOR HANDBOOK FOR ADDRESSING DENIAL OF SHIPMENT OF

RADIOACTIVE MATERIAL

June 2013

1. Introduction2. Definitions & FAQ3. New structure4. Roles and Responsibilities of National Focal Point5. Establishing a National Network6. Knowledge Management and Information Dissemination7. Facilitating Transport8. Roles and Responsibilities of Regional Coordinator

http://gnssn.iaea.org/RTWS/general/Shared Documents/Transport Safety/ISC8 Working Material/Denials Handbook - V1 Markup_V6.doc

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Establishing a National Network

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A National Focal Point will need a contact network within the country so that they may keep abreast of changing circumstances. The figure

below identifies who might be involved in the national network and what an NFP needs to do to establish this network.

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Establishing a Regional Network

Examples of which stakeholders could be involved in a Regional Network

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Current statusCurrent status

• By Air

– There is an increased acceptance of carrying Class 7 goods by air, attributed to the availability of communication tools, (e.g. the IATA video or the correlation between air transport of medical radioisotopes and cancer therapy), suggesting that the issue with the air mode is more related to one of negative perception of Class 7 goods

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Current status (2)Current status (2)

• By Sea– A number of problem areas remain in the shipment of

Class 7 goods by sea• There may be additional requirements for Class 7

which make the transport unsustainable (routes, seasons, schedules and carrier amalgamations)

• There may be multiple regulatory bodies which could result in conflicting requirements for Class 7 (transits typically pass through a number of countries en route to final destination)

• There may be requirements which conflict with those of other countries or other Ports along a route

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Recent DecisionsRecent Decisions

• End of ISC after ISC 8 in June 2013, but not end of actions to deal with denials since denials continue to exist in many locations around the world

• At a meeting in April, 2014, it was agreed that the ISC will be transposed into the TFWG (Transport Facilitation Working Group) which would report to the Inter-Agency Group (IAG) comprised of (ICAO, IMO, UNECE, IAEA)

• Agreed to continue the roles and responsibilities of NFPs and RCs. The network of NFPs needs to be consolidated and extended

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Future activities Future activities

• Harmonization plays a key role in preventing denials

• Awareness, communication and lobbying have demonstrated to be the core solutions to addressing these problems

• Training is an area identified to improve the understanding of service providers and other major stakeholders so that they find it easier to comply with class 7 regulations

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Who can help?Who can help?

• Regulations makers: – Nuclear and modal regulations internationally, but also at

national level, need to be harmonized.

– Ports and service providers’ policies should be consistent and, at least, nationally harmonized.

• IAEA: Proposed Inter-regional project (TC – NSRW)– Appoint a roving Denial of Shipment “Ambassador” to meet

with appropriate entities in different regions, engage governments and customs officials, carriers, and ports

– Would visit “hot spots” where DoS is a significant issue– The Ambassador will be supported by a network of

international experts

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Who can help? (2)Who can help? (2)

• Industry– For carriers, ports and airports, accepting class 7 goods

in the same manner as other classes of dangerous goods– For consignors, complying with class 7 regulations

• Governments – Implementing regulations consistently with international

guidance and standards– Appointing NFP and supporting her/his work– Encouraging harmonization

• All together– Providing training, awareness and communication

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What you can do to facilitate safe movement of radioactive material

• If your department proposes new procedure which may restrict transport of radioactive material, examine how the objective could be achieved without denying the society the benefits from radioactive materials.

• Coordinate with other authorities in your State and

communicate with all involved parties • Inform the other authorities and carriers in advance

about deviations of your regulations and procedures from international practice.

• Minimise such deviations.

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Summary

• Radioactive materials have specific and needed public health and use applications

• Radioactive material are used for health care, for applications in industry and research, for power production, etc.

• Regulations assure safety of transport.

• Delay or denial of a shipment result in • lack of diagnosis, treatment, and care (palliation) for patients; • stopping production in a factory or a nuclear power plant; or • denying a home of a safe product that would enhance the quality of life

• Communication and cooperation between all stakeholders is essential by using the system of National Focal Points and National and Regional Networks to prevent delays and denials

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Questions?Questions?

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