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Ionising Radiations Regulations 1999: Notification of offshore site radiography work

  • Operations notice: 34
  • Issue date: Mar 2010

Introduction

1. The Ionising Radiations Regulations 1999 (IRR) require employers who undertake site radiography to notify the Health and Safety Executive (HSE) before carrying out the work. Annex 1 to this Notice describes the notification requirements and indicates how they can be complied with for offshore site radiography, including repeat notifications, and notification of unforeseen and emergency work. It also provides updated information on the mechanism of notification (see Annex 1, paragraph 7).

2. Radiographers are required to notify HSE, at least seven days beforehand, of every site radiography job they undertake. This is intended to help contractors in planning and controlling their radiography work, and to help HSE plan inspection activities. Details of notification requirements can be found at http://www.hse.gov.uk/radiation/ionising/notification.htm. To avoid the need for repeat notifications where work continues over a period with no significant change HSE may, subject to certain conditions, accept one notification for a series of radiography operations, covering a period not exceeding 12 months (see Annex 1, paragraphs 11 and 12).

3. HSE may also accept a one-off reduction in notice requirements for genuinely unforeseen work and emergency work, which it is not reasonably practicable to delay (see Annex 1, paragraphs 13-19). It is the duty of the radiography contractor to notify, not the installation operator or other client company. Installation operators need to be aware of, and be sensitive to, how these requirements affect the radiography services that they employ. Co-operation and good liaison between client and contractor is therefore essential in planning radiography to ensure that the latter has sufficient warning of impending work to fulfil the requirement to notify.

Further information

4. Any queries relating to this notice should be addressed to:

Health and Safety Executive
Hazardous Installations Directorate
Offshore Division
Lord Cullen House
Fraser Place
Aberdeen
AB25 3UB

This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice

Annex 1 – Notification requirements for offshore site radiography work

Introduction

1. The Ionising Radiations Regulations 1999 (IRR) require employers undertaking site radiography to notify HSE before carrying out the work. This annex describes the requirements and indicates how they can be complied with for offshore site radiography.

2. The term 'site radiography' means any radiography of inanimate objects other than that which is carried out in an enclosure or cabinet that restricts the dose rate (averaged over a minute) outside the enclosure to 7.5 microsieverts per hour.

Background

3. The notification requirements are in two parts.

Initial notification

4. Under IRR regulation 6(2) employers must notify HSE 28 days before they undertake work with ionising radiations for the first time. The requirement is subject to certain exceptions which will not normally apply to offshore radiography. The details to be notified are in Schedule 2 and include:

5. Existing radiography contractors should have submitted this notification to an HSE office before they started work with ionising radiation. New or re-formed companies will need to notify before they start radiography work. Companies who have already notified HSE with respect to onshore radiography need not re-notify for offshore work.

Notification of site radiography

6. Using their powers under regulation 6(3) and 6(4) of IRR, HSE has served a notice on individual radiography companies to require notification of every site radiography job they undertake, at least seven days beforehand. This is intended as an aid to contractors in planning and controlling their site radiography work. It also helps HSE to plan inspection activities. The notice introduced the new notification procedure described in paragraph 7.

Notification procedure

7. All notifications for site radiography should be sent to: HSE, Ionising Radiations Notifications, Phoenix House, 23-25 Cantelupe Road, East Grinstead, West Sussex, RH19 3BE or, e-mail: siteradnot@hse.gov.uk) .

8. E-mail is the preferred method of notification, for speed and reliability of delivery. The notification should arrive at least seven days before work is due to start. It is the duty of the radiography contractor to notify, not of the installation operator or other client company. Good liaison between client and contractor is therefore essential to ensure the latter has sufficient warning of impending work to fulfil the requirement to notify.

9. It may not always be possible to give an exact start date, as plans may need to be changed at short notice. HSE will accept a provisional earliest start date providing it is at least seven days ahead, with the precise date confirmed later.

10. Notification is only required for site radiography, as defined in paragraph 2. The risks from site work are significantly greater than when a shielded enclosure is used, and contractors are reminded of their duty to take all necessary steps to restrict personal exposure, so far as is reasonably practicable. Further guidance on precautions is in Work with ionising radiations. Ionising Radiation Regulations 1999. Approved Code of Practice and guidance L121 HSE Books 2000 ISBN 978 0 7176 1746 3. Operators should take these matters into account when assessing their radiography needs.

Repeat notifications

11. To avoid the need for repeat notifications where work continues over a period with no significant change, HSE may accept one notification for a series of site radiography operations, covering a period not exceeding 12 months. Examples are work which is all related to a particular maintenance programme, pipe-laying contract, or a sub-sea project. The following conditions should be satisfied:

12. Any changes to these details will require re-notification, seven days before they come into effect.

Unforeseen work

13. Most site radiography work is planned in advance and can be notified without undue difficulty. Situations may arise, however, where work needs to be done unexpectedly, for example because of unforeseen plant breakdown. In these cases, HSE may accept a one-off reduction in notice requirements, subject to the following conditions:

14. Requests for shorter notice should be made by email to the address at paragraph 7. The contractor should be able to demonstrate that all the conditions in paragraph 13 have been satisfied. Work should not proceed until agreement has been given in writing by HSE, normally by e-mail in the first instance.

Emergency work

15. Exceptionally, there may be an urgent need to mobilise radiography staff out of office hours. In these cases the contractor should contact the HSE duty officer (see paragraph 19 for contact details), who will inform the OSD duty inspector. When the duty inspector calls back, the contractor should supply an explanation of why the work is urgent. The contractor should also indicate what job planning has been performed and what procedures will be used to ensure safe working.

16. If the duty inspector is satisfied that the conditions for accepting shorter notice have been satisfied, and that work can go ahead safely, verbal agreement will be given to the contractor to proceed. The contractor should provide written details to HSE as in paragraph 14, on the next working day. The agreement to shorter notice will then be confirmed in writing by the OSD nominated IR focal point inspector.

17. If the duty inspector is not satisfied with either the need for a reduction in notice requirements or with the working methods proposed, the work must not proceed. It may be possible for the contractor to supply additional information to satisfy the duty inspector, but failing this the work should be delayed until discussions can be held between the contractor, the inspection team leader responsible for the installation, the OSD IR focal point inspector and, if necessary, with the client. Notification will still ultimately need to be sent to HSE as in paragraph 14.

18. Note that the contractor should seek agreement to accept less notice, not the installation operator or owner. The duty inspector will only give agreement to proceed to a representative of the radiography company.

19. The HSE duty officer can be contacted by telephoning 0151 922 9235. This is an answer-phone that will give the number of the duty officer. They are available out of office hours (Monday-Friday - 8.30-17.00), weekends and public holidays.

This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice.

Updated 2011-09-29