The Office for Nuclear Regulation (ONR) has issued an Inspector Awareness Brief highlighting potential non-compliances associated with the use of the Gilligan Engineering Limited TecCase Type A package.

While Inspector Awareness Briefs are primarily intended for ONR inspectors, they often provide valuable insight for dutyholders, Radiation Protection Advisers (RPAs), and organisations involved in the transport of radioactive material.

Why this brief is important

Type A packages are commonly used across the nuclear, medical, and industrial sectors. Compliance depends not only on selecting an appropriate package, but also on ensuring it is used strictly in accordance with its approval conditions and safety case.

The ONR brief draws attention to situations where the TecCase Type A package may be used in ways that fall outside the scope of its approved design. In such cases, organisations may unintentionally place themselves in a position of regulatory non-compliance.

Key themes highlighted by ONR

Although the brief itself is aimed at inspectors, the underlying messages for dutyholders are clear:

 

• Approval conditions must be fully understood 

     A Type A package must only be used in the configuration and for the contents covered by its approval. Deviations, even if well-intended, can undermine                    compliance.

• Operational use is critical 

     Non-compliances can arise from loading arrangements, shielding assumptions, closure methods, or changes to the approved configuration.

• Assumptions based on past practice are risky 

     Long-standing use of a package does not guarantee compliance if the approval conditions are not being fully met.

• Evidence and justification matter 

     Dutyholders should be able to clearly demonstrate that their transport arrangements align with regulatory requirements and the package approval documentation.

What organisations should do now

Organisations using, or planning to use, the Gilligan Engineering TecCase Type A package should consider taking the following steps:

• Review current transport arrangements 

     Confirm that the package is being used exactly as approved, including contents, shielding, and closure requirements.

• Check transport documentation and procedures

      Ensure local instructions, risk assessments, and training materials accurately reflect the approved use of the package.

• Seek independent advice if needed

     An RPA or DGSA can provide reassurance or identify gaps before they become inspection findings.

• Prepare for increased regulatory scrutiny 

     The issue of an Inspector Awareness Brief indicates that inspectors may pay closer attention to this package during future inspections.

Final thoughts

Inspector Awareness Briefs often act as an early signal of regulatory concern. Proactively reviewing arrangements now can help dutyholders avoid enforcement action later and demonstrate a strong commitment to compliance. If you would like support reviewing transport arrangements, interpreting regulatory expectations, or ensuring compliance with radioactive material transport regulations, please contact us, early engagement can save both time and cost.