THE NATIONAL FOCAL POINT AND REGIONAL COORDINATOR HANDBOOK FOR ADDRESSING DENIALS OF SHIPMENT OF RADIOACTIVE MATERIAL
June 2013
INDEX
1. Introduction
2. Definitions & FAQ
3. New structure
4. Roles and Responsibilities of National Focal Point
5. Establishing a National Network
6. Knowledge Management and Information Dissemination
7. Facilitating Transport
8. Roles and Responsibilities of Regional Coordinator
Annexes
Annex A: Process for reporting a denial of shipment of Radioactive Material
Annex B: Denial Report Form (Air)
Annex C: Denial Report Form (Sea)
Annex D: Examples of Stakeholders Potentially Involved in National Network
Annex E: Abbreviations
1. Introduction
Scope
The intent of this Handbook is to provide an overview of the tools necessary for the National Focal Point (NFP) and Regional Coordinator (RC) to effectively deal with the denial of shipment of radioactive material. Significant additional resources and guidelines are available on the IAEA website (http….)
History and framework
Radioactive materials are transported for use in medicine, industry, research and for production of power. Transport of such materials is governed by national and international regulations which are based on the IAEA Regulations for the Safe Transport of Radioactive Material. 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.
The role of the NFP and the 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 denials 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.
2. Definitions and FAQ
· What is a denial?
A denial is “a refusal to carry a shipment of radioactive material though it conforms to all the applicable Regulations”. Then, the non-compliance of Regulations CANNOT lead to Denial Reporting/Notification. All applicable regulations include international as well as national regulations. National regulations may have additional requirements for transport of radioactive material. If however such additional requirements may cause a denial this should also be reported. This applies also to additional operational requirements by carriers which may result in a denial.
· Why is denial reporting necessary?
No report equates to no denials. By reporting instances of denials, stakeholders can be made aware of the problem and can then initiate those specific actions required to minimize or eliminate such instances.
· How can denial related problems be solved?
The means/methods/mechanisms established by NFPs to resolve instances of denial are varied depending on the situation and the location.
· How are denials reported?
Denial report forms are included in Annex B (Air) and Annex C (Sea) and these are to be completed by the organization experiencing the denial.
· What happens once a denial is reported?
The reporting process is followed by 2 DWG & NFP activities: analysis of the denial (root causes) and an action plan to resolve the cause of the denial (corrective and preventive actions).
The denial report is initially submitted to the National Focal Point and subsequently to the Regional Coordinator and the IAEA Transport Safety Unit (TSU), who enters the data into the denial’s database. A periodic analysis of the data is completed by the Denials Working Group (DWG) which functions within the Inter-Agency Group (IAG). Results of the analysis of the denial reports submitted will be available to National Focal Points on the IAEA website. (http://...... )
3. New structure
The above diagram shows the relationships between the various entities associated with review of denials. A central resource is the IAEA Transport Safety Unit (TSU) which contacts Member States requesting their nomination of a National Focal Point (NFP) together with an overview of the skills and experience considered appropriate and an outline of duties and responsibilities. The TSU will also nominate Regional Coordinators (RC) and a register of NFPs and RCs will be maintained on the IAEA website. Denials reporting forms are available on the IAEA website and elsewhere by the efforts of NFPs, ICAO, IMO, UNECE and several industry forums. When submitted to the TSU, the information is input on a denials database managed by the TSU.
Training, guidance and advisory material is maintained by the TSU and made available on the IAEA website.
It is proposed that a small group of experts, the Denials Working Group (DWG),will be formed reporting to the Inter-Agency Group (IAG) with DWG making recommendations to the IAG for discussion and agreement. The agreed recommendations will then be submitted to TRANSSC by IAG/DWG for their endorsement, where applicable, and to other bodies including other parts of IAEA as appropriate. Actions accepted by TRANSSC will be incorporated in the TRANSSC transport work plan.
Additional resources and guidance supporting denial activities is available at http://.....
4. Roles and Responsibilities of NFP
Roles and Responsibilities of National Focal Points (Guidance)
Strategic Planning
(Communication, cooperation, analysis and evaluation)
1. To serve as a point of contact with their Government, Regional Coordinators and the TSU in all matters and aspects of denials of shipments of radioactive material and evaluating the reasons for denials reported.
2. To identify and validate reported instances of denials to determine whether or not it is in fact a denial that should be submitted to the TSU. Where denials have occurred and been validated report to TSU.
3. To initiate and/or maintain a national network for coordinating and communicating at the national level with all stakeholders in the solution of denials, including the National Government Organizations.
4. To update and disseminate information at a national level and the TSU for wider distribution (e.g. solutions for denials, training material etc.)
5. To liaise with the relevant authorities to identify and recommend the suitable candidates to the meetings/conferences/workshops in the area for denials of shipment of radioactive material.
6. To promote the awareness of denials to those national agencies involved in dangerous goods transport.
Approach Determination
(Identification, approach and solutions)
7. To identify stakeholders who are key to sustainability of radioactive material transport.
8. To provide examples of what has been done proactively to facilitate the safe and cost effective transport of radioactive material in accordance with regulations.
9. To initiates a process for solving denials.
10. To assist NFP counterparts in actions to solve denials, as necessary.
11. To identify national needs including training in the area of denials of shipment of radioactive material with the cooperation of the stakeholders.
12. To review the successes and failures of interventions and provide feedback to the Regional Coordinators and the TSU.
13. To develop actions necessary to resolve denials in cooperation with relevant stakeholders and Regional Coordinators.
Operational Actions
(Implementation, measurement and report)
14. To maintain records of denials and actions taken regarding resolution activities.
work related to the denials of shipment of radioactive material.
5. Establishing a National Network
As a National Focal Point you will need a contact network within your country so that you may keep abreast of changing circumstances. The figure below identifies who you might involve in your national network and what you as a NFP need to do to establish this network. Examples of potential actions include:
· Identify and establish effective communication with key stakeholders in relation to the sustainable transport of radioactive material in line with government policies and approaches;
· Ensure coordination with all relevant national stakeholders relating to the preparation, and prioritization of solutions for denials of shipment;
· Establish a National Committee, if necessary, for coordinating work related to formulating and executing necessary actions;
· Remain aware of national institutions taking part in activities related to denials of shipments, and to inform the TSU of new activities.
· Develop a list of contacts for each stakeholder and the level of involvement that they have in the national network.
Figure: Examples of which stakeholders could be involved in a National Network.
Annex D provides examples of which stakeholders could be involved in a National Network.
6. Knowledge Management and Information Dissemination
As a National Focal Point, you will need to collect and consolidate knowledge on denial of shipment related to your country. The information contained in this section is an example of what could be made available as knowledge and tools for the national network: Examples of potential actions include:
· Serve as the Focal Point in your country relating to denials of and facilitation of shipments of radioactive material;
· Monitor lessons learned and best practices;
· Build a knowledge base for national facilitation and identify potential areas for regional collaboration;
· Ensure that the benefits of identified solutions are known and understood by all relevant units of industry, government, Regional Coordinators and the TSU;
· Identify variation between national and international regulations for the safe transport of radioactive material, e.g. in ports and report such information to appropriate regulatory bodies and DWG.
7. Facilitating Transport
As a National Focal Point, you will help facilitate resolution of shipping denials in your country. Examples of potential actions include:
· Identify instances of denials and report them to TSU;
· Liaise with the relevant authorities to identify and recommend the suitable candidates to any meetings/conferences/workshops relating to denials ;
· Disseminate policies and procedures for solutions related to denials of shipment within the country;
Simplified reporting process is described in AnnexA; denial report forms are shown in Annex B (Air) and Annex C (Sea).
To optimize denial reporting
· Circulate the denial report form and reporting process to industry/Class 7 licensees.
· Collect input from those reporting
· Remind key stakeholders of the importance of reporting on a regular basis by providing feedback
8. Roles and Responsibilities of the Regional Coordinator (RC)
Roles and Responsibilities of Regional Coordinator (Guidance)
Strategic Planning
(Communication, cooperation, analysis and evaluation)
1. To serve as a Coordinator and a conduit for disseminating knowledge about the denials programme from the DWG to NFPs. To ensure that the lessons learned and proposed corrective actions, adaptations and innovations for future solutions from the region are documented and reported to TSU.
To serve as the interface between the NFPs of the region, the DWG and TSU in all matters related to all aspects of denials of shipment of RAM.
2. To network with UN agencies and NFPs, forming alliances and partnership to facilitate transport and to address national/regional priorities
3. To inform the DWG/IAEA, on the severity and importance of specific cases of denials of shipment of RAM in the region and to support National Focal Points to seek adequate solutions to the problems with the help of such agencies as IMO, ICAO, etc.
4. To provide information about their region to the DWG and assist the DWG in formulating relevant policies and strategies
5. To build a knowledge base for regional facilitation and identify potential areas for national/regional/international collaboration and the participation of others
Approach Determination
(Identification, approach and solutions)
6. To maintain current knowledge on the status of denials of shipments in the region and encourage resolution of issues that preclude the effective shipment of radioactive material;
7. To coordinate with representatives of the international organizations, associations and NFPs in the region for training needs.
Operational Actions
(Implementation, measurement and report)
8. Through other Regional Coordinators:
· keep up to date on progress, problems and actions concerning denials of shipment and,
· facilitate solutions by taking actions as necessary, and,
· replicate processes which have been found to be effective in different networks.
9. To coordinate implementation of actions determined by the DWG according to regional priorities.
10. To develop, evaluate and review the implementation of resolution activities.
11. To review the success or failure of delivered solutions and to provide feedback to TSU;
12. To assist NFPs other Regional Coordinators as necessary;
13. To monitor and encourage timely completion of any resolution activities
15. To prepare and report to DWG.
Figure 3: Examples of which stakeholders could be involved in a Regional Network.
Annex A: Process for reporting a denial of shipment of Radioactive Material
Step 1 / Inform promptly on Denial when difficulty arises / Industry (Shipper / Consignor) / User / Consignee / Initial notification / Link to report form
Step 2 / Identify / Validate reported Denial
Find solution to Denial / NFP* / Industry, RC, TSU, ports, CA, Carriers, consignor, consignee
Stakeholders / Report of ID&D or Report of non-Denial (***)
(sent both to TSU and RC) / The reported Denial includes identification of causes and root causes;
NFP contacts industry to validate info and check if the concern is a valid denial or delay
Step 3 / Coordinate / communicate at national-regional-global level on solution of Denial / NFP*
RC / DWG / NN / RN / DWG
NFP / Updated action plan
Information bulletin / webpage
Step 4 / Feed database with new reports
Perform analysis of new database inputs / TSU** / NFP / RC / DWG / stakeholders / Periodical analysis / A 6-month analysis is consistent with feedback optimization.
(*): If NFP refuses reporting on the Denial or if the NFP has not been appointed yet, refer to RC or at last to TSU.
(**): TSU has the exclusive access to all the data included in the database.
(***): To keep record of such cases of "false" denials with the precise description of non compliances as this could help the national/international efforts to improve/harmonize regulations regarding the safe transport of RAM.
Denial: Instance of Denial of Shipment of Radioactive Material
NN / RN / DWG: National Network / Regional Network.
Note: Add Annex B & Annex C
Annex E: Abbreviations
GC: General Conference
IAEA: International Atomic Energy Agency
IATA: International Air Transport Association
ICAO: International Civil Aviation Organisation
IMDG Code: International Maritime Dangerous Goods Code (issued by IMO)
IMO: International Maritime Organization
NFP: National Focal Point
RAM: RadioActive Material
RC: Regional Coordinator
TSU: Transport Safety Unit (IAEA/NSRW/RIT)
UN: United Nations
UNECE: United Nations Economic Commission for Europe
DWG: Denial Working Group
IAG: Inter-Agency Group