Welcome to the eleventh edition of the Radiation Protection Adviser. Some of the articles in this edition give clarification on Ionising Radiations Regulations 1985 (IRR85) and the supporting ACOPs - so although we are very busy preparing IRR99, we still need to ensure that IRR85 are clearly understood by all parties. We hope to continue this role with the new regulations.
In Issue 10 we said that the information sheet on industrial radiography had been revised. Unfortunately some readers have experienced problems in getting hold of the revised version. We have now been assured that free copies are available from HSE Books at the address given below. The reference number to quote is 'IRIS01'.
All HSE free publications may now be obtained from: HSE Books, PO Box 1999, Sudbury, Suffolk, CO10 6FS, tel: 01787 881165; fax: 01787 313995.
Readers will be interested in the short article giving brief details on the progress with the revision of IRR85.
The Carriage of Dangerous Goods by Road (DriverTraining) Regulations 1996, which came into force on 1 September 1996, have changed the requirements for training drivers involved in the transport of radioactive materials. HSE enforces the Regulations, which cover driver training during transport of all dangerous goods.
The 1996 Regulations have removed the exemption under earlier regulations from formal vocational training for drivers where the gross weight of the vehicle was below three tonnes. Under the Road Traffic (Training of Drivers of Vehicles Carrying Dangerous Goods) Regulations 1992 employers had a more general duty to ensure that drivers had received adequate instruction and training to enable them to understand the nature of the risks involved and what to do in emergency situations.
The 1996 Regulations do not apply to the transport of excepted packages. Persons carrying Type A packages containing non-fissile material do not require vocational training if there are less than ten packages on the vehicle and no more than three transport indexes for the packages. However, the person responsible for transport will need to provide drivers of vehicles carrying such material with a certificate to confirm that they have received adequate instruction and training. All other drivers transporting radioactive material by road will need to obtain a Vocational Training Certificate obtained by examination after attendance at an approved training course.
HSE has not identified all the employers likely to be affected by the new duties under the 1996 Driver Training Regulations. However, one group of employers that will be affected is industrial radiographers. For example, an industrial radiographer driving a vehicle containing a 1 TBq source of iridium-192 with a source capsule which is special form construction will need a Vocational Training Certificate. There are other large radiography sources which would trigger application of the Regulations.
Because the scope of the training requirements has changed, transitional arrangements have been made to allow operators of vehicles which were previously exempt to train drivers now covered. The required vocational training should be completed by 1 July 1997. RPAs with clients who may be affected by these changes are encouraged to advise their clients accordingly.
A list of bodies approved by the Department of Transport (DoT) to give vocational training can be obtained from the DoT on 0171 271 4537 or the City and Guilds on 0171 294 2468.
HSE has recently published guidance on the new Driver Training Regulations for drivers of vehicles carrying radioactive materials: The Carriage of Dangerous Goods Explained: guidance for road vehicle operators and others involved in the carriage of dangerous goods by road HS(G)161 ISBN 0 7176 1253 8, available from HSE Books (see details above) and all good booksellers.
Issue 10 of the Radiation Protection Adviser gave details of the early stages to revise IRR85. Since then we have been working closely with the informal Topic Groups established to advise HSE on developing proposals in order to implement the majority of the new Basic Safety Standards Directive and revise IRR85.
The feedback from the Topic Groups has allowed us to take key decisions on the general direction for revised IRRs. This has enabled us to prepare instructions to HSE's solicitors for drawing up draft regulations. The draft regulations will form part of the Health and Safety Commission's (HSC) formal Consultative Document (CD). This CD will also include drafts of the supporting ACOP and non-statutory guidance: currently being written. We intend to produce the CD by the end of the year.
In September 1996 the European Commission formally proposed a revision to the Patient Protection Directive 84/466/Euratom. The Department of Health have been leading the negotiations for UK, with support from HSE. (There will be further details in the next issue.) Negotiations have been underway in the Council's Atomic Questions Group since October. At the time of going to press the revised Directive was close to adoption.
HSE has issued advice to employers in the food, drink and packaging industries about the maintenance of fill-level devices containing 241Am. The guidance, HSE Food NIG Circular No 3, was published in September 1996 and is available from the Editor. The circular advised on the application of IRR85 to fill-level devices, particularly those containing 241Amsources of activity in the range 1-4 GBq. Clients may have sought advice from RPAs about this advice.
The circular gives advice on notification, local rules etc and includes details of the steps to be taken to ensure the continued integrity of the source capsule. IRR85, regulation18 requires users of such sources to take all practicable steps to prevent the leakage of radioactive material. The circular warns that the radiological implications of the loss of containment of these sources could be serious.
The main messages in the circular are that users should:
Normally, these sources are of 'special form' construction. Therefore an employer will not need to produce a Special Hazard Assessment (regulation 26 IRR85) even if the total inventory exceeds 2 GBq. However, sources which are outside their recommended working life are no longer regarded as 'special form'.
Therefore, RPAs with clients in the food, drink and packaging industries may find it useful to discuss the Information Circular with their clients. The advice may also be applicable to other users of large 241Am sources.
There appears to have been some confusion recently about the correct reference numbers for the Approved Code of Practice (ACOP) supporting IRR85. ACOP Parts 1 and 2, The protection of persons against ionising radiation arising from any work activity was reprinted unchanged in 1994 (ISBN 0 7176 0508 6). However, it did not include any reference to ACOP Part 4. ACOP Part 4 was published in 1991 (ISBN 0 11 885605 7) and Issue 1 of the Radiation Protection Adviser included a lengthy article on its introduction.
We will publish a new ACOP, replacing the existing publications, when the revised regulations are introduced in a few years time.
Inspectors visiting a freight handling company which processed large quantities of radioactive packages each week identified a series of problems. These led to the issue of enforcement notices followed by a prosecution under IRR85. The company concerned had appointed an RPA but had repeatedly ignored the advice given.
The sorting bays where packages were stored before onward dispatch were poorly shielded and some members of staff had received doses exceeding 15 mSv a year. Inspectors also found inadequate records, lack of monitoring, an inconsistent policy for the classification of staff, poor training and no agreed local rules.
This prosecution highlights the importance of good management control and supervision and the need to take the advice of RPAs to ensure that exposures are kept as low as reasonably practicable. Proper staff training is important as well as the need to keep procedures under review and to guard against complacency.
The message here for RPAs is that they should seek reassurance that clients are following their good advice and if they are unhappy with the response consider withdrawing from the contract.
One reader has written to say that an alpha-in-air monitor switched off when a nearby mobile telephone was used. The monitor was connected to the electrical supply via a portable residual current device (RCD). This device was activated and the electrical supply to the monitor was switched off. Where safety equipment is supplied via an RCD it is possible that the electrical supply to that equipment can be unintentionally switched off by the use of mobile telephones or portable radio transmitters nearby.
The manufacturers of RCDs state that the devices now available conform to the required standards set by the European Directive for Electromagnetic Compatibility through compliance with BS EN 1543. However, employers responsible for potentially hazardous areas should ensure that mobile phones and portable radios are not operated in the vicinity of sensitive equipment that is supplied via an RCD, be it a portable device as in the above case or one that is part of the fixed installation.
The provision of RCDs on the electrical supplies to safety and on-line monitoring equipment should be carefully considered and all the risks assessed.
The European Commission has produced a poster to mark adoption of the revised
Basic Safety Standards Directive, as an aid to communicating with the public
on radiation protection matters. A generous supply has been sent to each Member
State, NRPB hold the stocks for UK: we understand that DH has arranged for
distribution to Health Authorities but NRPB would welcome further ideas on
how to get copies to the right places. If you would like a copy of the poster,
please contact the publications section at NRPB, Chilton, Didcot, Oxon, OX11
Tel 01235 831600, Fax 01235 833891.
In February, HSE published the 1995 summary of annual doses on the Central Index of Dose Information (CIDI), one of Europe's most established national dose databases. Nearly
49 000 individuals had records on CIDI in 1995 and their average dose was 0.8 mSv; over 35% had a recorded dose of zero. Seven workers had recorded doses above 50 mSv; four of these were industrial radiographers and two were involved in fuel reprocessing. Of those exceeding the 15 mSv investigation level, 86% were non-coal miners working underground and 9% were industrial radiographers.
Free copies of the summary are available from the Editor. Readers may be interested to know that HSE aims to publish a further 'dose trends' report' - the last one covered the years 1986-91.
HSE has been asked to clarify IRR85 Schedule 6 Part II and the application of Schedule 2 Part I Column 5 - the use of total activity in the classification of controlled areas. We thought that readers may be interested in our advice.
The query related to classifying an area as controlled solely on the basis of total activity present, ie where more than 10 ALI of a radionuclide was being used or stored.
For values below those in Schedule 2 Part I Column 5 employers do not need to consider either airborne or surface contamination as a reason to designate a controlled area. Exceeding the Schedule II values would only cause an area to be designated as controlled if the criteria in Schedule 6 Part II paragraph 6(a) or (b) were also exceeded. Of course, the figures in Schedule 2 Part I Column 5 could be taken as a basis for designating controlled areas, but this is not a legal requirement.