Ionising Radiations Regulations 1999: Notification of offshore site radiography work

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 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 8). Letters advising of the changed arrangements, together with accompanying notices under IRR regulation 6(3) and 6(4) have been sent out by HSE Field Operations Directorate, East and South East Specialist Group (ESESG) to all known employers carrying out site radiography work.

2. Radiographers are required to notify HSE, 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. 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 12 and 13).

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 14-20).

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

Tel: 01224 252500
Fax: 01224 252629

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 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 regulation 6(2) of IRR 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:

• the name and address of the employer;
• the address of the premises where the work is to be undertaken;
• the nature of the employer's business;
• the categories of radiation sources to be used;
• whether work is to be performed at other premises; and
• the dates of notification and of commencement of radiation work.

5. Existing radiography contractors should have submitted this notification to an HSE office before they started work with ionising radiation. Any that have not done so should notify now. 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 new notice on individual radiography companies to require notification of every site radiography job they undertake, seven days beforehand. This is intended as an aid to contractors in planning and controlling their radiography work. It also helps HSE to plan inspection activities. The notice introduces the new notification procedure described in paragraph 8.

7. For offshore work, the details to be notified should include:

• a brief description of the proposed work, including type and size of plant involved, and any special features such as proximity to other installations or access ways. A sketch may be helpful;
• particulars of the source(s) to be used, including the type of radiation generator and the nature and activity of any radioactive substance;
• the name of the radiation protection supervisor who will be present on site;
• the start date and the duration of the work; and
• the name, location and description of the installation where the work is to be carried out.

Notification procedure

8. As from 5 April 2003 all notifications for site radiography should be sent to: ESESG, HSE, 3 East Grinstead House, London Road, East Grinstead, West Sussex RH19 1RR (fax: 01342 334257, e-mail: siteradnot@hse.gsi.gov.uk).

9. Fax 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.

10. 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.

11. 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 0 7176 1746 7. Operators should take these matters into account when assessing their radiography needs.

Repeat notifications

12. 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 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:

• the work is carried out by the same contractor to the same client;
• the installation(s) are all identified and do not change;
• the source type(s) used are all identified and do not change;
• the overall work period is specified;
• the proposed work schedule within the overall work period is given, and updated where necessary during the work; and
• the type of work is unchanged.

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

Unforeseen work

14. Most 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:

• the need arises from a genuine unforeseen event rather than from inadequate planning;
• it is not reasonably practicable to delay the work to give seven days notice;
• all the information described in paragraph 7 is provided; and
• the contractor can demonstrate that the work has been adequately planned and can be done safely. This will normally include providing supporting documentation.

15. Requests for shorter notice should be made in writing (preferably by fax) to the address at paragraph 8. The contractor should be able to demonstrate that all the conditions in paragraph 14 have been satisfied. Work should not proceed until agreement has been given in writing by HSE, normally by fax in the first instance.

Emergency work

16. Exceptionally, there may be an urgent need to mobilise radiography staff out of office hours, when it is not possible to contact the ESESG. In these cases the contractor should contact the HSE duty officer, who will inform the OSD duty inspector. When the duty inspector calls back, the contractor should supply the information referred to in paragraph 7 verbally, with 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.

17. 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 the ESESG as in paragraph 15, on the next working day. The agreement to shorter notice will then be confirmed in writing by OSD.

18. 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 and, if necessary, with the client. Notification will still ultimately need to be sent to the ESESG.

19. 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.

20. The HSE duty officer can be contacted by telephoning 0151 922 0609 or 0151 922 0137. These are answer-phones 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.