Welcome to the tenth edition of the Radiation Protection Adviser. The first issue was published in October 1991- so this edition celebrates 5 years of the newsletter. Sometime next year we hope to conduct a survey of all our readers - we first did this in December 1993 - and feel that we could benefit from another dose of feedback.
In the last five years we have covered a wide range of topics and the distribution of the newsletter has increased steadily and is now in excess of 3,000; it is received in 29 countries round the world. The main feature in this edition is the latest news on how HSE intend to implement the revised Basic Safety Standards Directive 96/291 Euratom that was adopted on 13 May 1996.
For those RPA readers who are members of the Society for Radiological Protection (SRP) and to avoid duplication we have amended our distribution lists in conjunction with SRP. SRP members should just receive one copy of RPA News (from SRP) in future. If readers wish to receive RPA News from HSE, please contact the Editor at the address shown.
All HSE free publications, including the recently revised Information
Sheet No 1, may now obtained from HSE Books, PO Box 1999, Sudbury, Suffolk,
CO10 6FS, tel: 01787 881165; fax: 01787 313995.
Issue 9 of RPA Newsletter reported on an informal HSE consultation paper about revising the Ionising Radiations Regulations 1985 (IRR85). We sent out over 100 copies of this paper and received 57 substantive replies. We were very pleased with this consultation exercise and very grateful to those who participated. Replies were clearly set out and views clearly expressed. The conclusions - discussed and agreed with the Health and Safety Commission's (HSC) Ionising Radiations Advisory Committee - will help us to draft the Consultative Document (CD) containing our proposals to revise IRR85. We believe there is now a reasonable consensus on most of the structural issues and respondents to the CD can concentrate on the substantive issues.
The five issues and the conclusions drawn were:
There was very substantial support for the idea of consolidating OWR into the revised IRRs and we are proceeding on this basis. In the process we will draw on operational experience to simplify the OWR provisions as far as we can.
We asked for views on the balance of material in the legislative package between regulations, Approved Code of Practice (ACOP) and non-statutory guidance. Replies clearly indicated support for modern goal-setting regulations. The views expressed on ACOPs were mixed. HSC published a general statement on the role of ACOPs in February 1996, setting out criteria for their future use, and this was annexed to the consultation paper. Application of the HSC criteria will lead to more selective use of ACOP guidance in support of the revised regulations, resulting in a slimmer, but sharper and more focused ACOP.
One clear message, though, was that people did not want to lose existing published advice if the new ACOP did appear in slimmer form. So our intention is to prepare draft guidance directly in support of the regulations and ACOP, and include in it relevant material no longer appropriate to the ACOP. We will then publish the draft regulations, ACOP and supporting non-statutory guidance together in the CD.
Publications providing guidance on IRR85 will need revising. In the process we want to look at its coverage by subject and by sector, and take a strategic view of future need. In some cases this may well mean looking to other organisations to prepare and revise the more detailed guidance in their own areas of interest.
We made the following suggestion for grouping together the principal Parts of the revised regulations to give a better expression: General principles: Controls for equipment and substances: Area controls: Controls for people: Contingency planning: Management systems, and Employee duties. This scheme was widely supported and we intend to proceed on this basis incorporating the further helpful suggestions for amendments and additions, particularly in raising the profile of management systems.
At the same time we asked whether there was value in including an explicit requirement in the revised regulations for risk assessment. Whilst the majority favoured this, there was recognition of the real danger of duplication and confusion with the risk assessment duty in the Management of Health and Safety at Work Regulations 1992. Therefore, we propose to develop an approach which builds on the important role guidance can play in explaining what ALARP should constitute and in making the link with the other relevant legislation, using ACOP and non-statutory guidance as appropriate.
We raised the choice facing us over the new dose limitation system. The revised BSS Directive allows us to adopt either the ICRP 60 system of five yearly averaging or to retain an annual system (with a lower limit). The paper set out arguments for both systems and asked which one we should adopt. Not unexpectedly, there was no clear outcome, but respondents offered a number of extremely helpful ideas on how some of the difficulties of one system or the other could be ameliorated. We therefore intend to develop both options with appropirate safeguards and present them for choice in the CD as two practical alternatives.
We also sought confirmation that the most sensible operative date for revised regulations in respect of dose monitoring and recording would be 1 January. There was almost universal support for it and we will develop our timetabling on this basis.
Finally we asked whether in the revision process we should take the opportunity to simplify and clarify certain parts of the existing regulations. This general principle was overwhelmingly supported and the individual examples cited in the paper each received majority support. Most of the changes will need some form of safeguard, and we accept that the support now given is conditional on satisfying people later about the effectiveness of these safeguards.
Work is now well underway in the informal Topic Groups we set up to help develop the contents of the formal HSC's CD. The first stage is to identify and decide on key approaches in many areas, this will allow us to instruct HSE's Solicitors in drawing up revised regulations. The next stage is to see whether individual regulations need supporting with ACOP paragraphs on the basis of the HSC criteria (see article above) and to draft ACOP material, if appropriate, and guidance. Such decisions will be taken on a case-by-case basis.
An RPA sought HSE's advice on what to do about dose rate monitors that were not scaled in SI units. We are repeating this advice here for others who may be in the same position.
Paragraph 162 of HSE's Guidance Note The examination and testing of portable radiation instruments for external radiations (HS(G)49, ISBN 0 11 885507 7, price £4, available from HSE Books) advises that users of instruments with scales in non-SI units should rescale or purchase new instruments. It goes on to say that "any response or calibration factors given in test certificates should relate to SI units, particularly as health and safety records should by law be in these units. An instrument scaled in old units may be used provided the appropriate response or calibration factor is used to convert to SI units when compiling records".
We have noticed that the guidance contains an incorrect reference to weights and measures legislation. The regulations that implement the EC Directive on SI units are the consolidated Units of Measurement Regulations 1986 (SI 1986 No 1082).
We want to emphasise that the Guidance Note has no legal status. Only where it could be proved that using unauthorised units led to a breach of the requirements of health and safety legislation (such as IRR 85) could an HSE inspector enforce a change of authorised units. We believe that paragraph 162 of HS(G)49 gives advice on good practice. Therefore we would encourage employers to follow the guidance.
The Health and Safety (Safety signs and Signals) Regulations 1996 came into force on 1 April 1996 and implement a European Council Directive. Most firms already use safety signs to warn and instruct employees of risks to their health and safety. The new Regulations are unlikely to impose any significant changes because the bulk of the signboards are the same as those in BS 5378 Safety signs and colours.
But the observant may have noticed that in the recently published HSE guidance booklet the wording shown below the trefoil is 'radioactive material' and for many years the trefoil has always signalled a risk from ionising radiation. The words under the signboards in the guidance document are only given as an example of the meaning of the sign, rather than as an exact specification for where it is to be used. As the wording does not form part of the sign users may add suitable supplementary text of their own choice.
The booklet is called Safety signs and signals and is available from HSE Books, ISBN 0 7176 0870 0, price £8.50.
On behalf of the Department of the Environment, the National Radiological Protection Board carried out a detailed mapping exercise of the whole of England, based on radon measurements in homes. Their report, Radon Affected Areas: England and Wales was published last May and has identified a number of new "hotspots", cutting a swathe from Somerset to Lincolnshire with other areas in Cumbria, North Yorkshire and Shropshire. These new areas are considerably smaller than the five counties of Cornwall, Devon, Northamptonshire, Derbyshire and Somerset.
While HSE does not operate on strict geographical criteria, it continues to monitor information on domestic exposure to radon to help identify buildings used for work that may exceed the workplace "action level". Employers with buildings in the affected areas where the ventilation conditions are similar to houses are advised to have them tested for radon.
HSE's 'Good Health is Good Business' (GHGB) campaign, launched in May 1995, is aimed at demystifying the management of occupational health risks and to help industry improve its performance. The second phase of the GHGB campaign, started in October 1996, is focusing on dermatitis and occupational cancers. Ionising radiation is included in the publicity material but is not a key issue.
In response to the article in issue 9 about local rules one reader commentated:
"We question whether local rules was the correct place to define staff training standards, although we specifically refer to the Protection of Persons Undergoing Medical Examination or Treatment (POPUMET) training in our rules. Reporting incidents is a complex area and one we think is best left to the Radiation Protection Supervisor (RPS) - therefore the local rules only contain an instruction to report to the RPS, the RPS being given detailed information on what to do. Duties under regulation 32 IRR85, critical examinations, would also seem to be best left as instructions for the RPS or department manager rather than all staff. With these exceptions where we see no need for everyone in the department to have detailed instructions, we find the guidance given very helpful."
Information has reached HSE about certain anti-static sources fitted in old Mettler Micro Gram-Atic laboratory balances. Apparently some of these balances contained a number of radium-226 anti-static sources, and bore no label to warn of the presence of radioactive material, in one case the sources were found to be leaking.
The balances were types B5, B6 and M5, and were made about 20 years ago. Although obsolete some of these may still be in use. However, the levels of radiation associated with the sources are very low. RPAs may like to inform their clients of the possibility that some balances containing radioactive material may still be in use. If such balances are found, Tony Mellor of Mettler-Toledo Ltd will be pleased to assist. He can be contacted at:
Mettler-Toledo Ltd, 64 Boston Road, Beaumont Leys, Leicester LE4 1AW, telephone: 0116 235 7070; fax: 0116 236 6399.
Issue 7 advised readers about new requirements under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR95) for reporting certain dangerous occurrences involving radiation equipment (paragraph 8, Schedule 2, RIDDOR95). We have now been asked whether incidents involving stuck shutters or simple radioactive level or density gauges should be reported under these regulations.
It was not our intention when RIDDOR95 was drafted that such events would be reportable. Paragraph 8, Schedule 2, RIDDOR, refers only to radiation generators and gamma sources used for mobile industrial radiography and deliberate irradiation of articles (eg food products and products being sterilised or otherwise processed). Therefore, HSE would not expect to receive notifications under RIDDOR95 for incidents involving simple gauges.