Welcome to the twelfth edition of the Radiation Protection Adviser. This issue includes a further update on progress with revising the Ionising Radiations Regulations 1985 (IRR85). The formal consultation document on these regulations is scheduled for early next year and the revised regulations are likely to come into effect on 1 January 2000.
We have also included a short reader survey and I hope you will find the time to complete and return it to me before 12 December. We will use your responses to this survey to shape future issues of the newsletter and to update our mailing list: we are particularly interested in suggestions for future topics. We would also like to find out how many of our readers are radiation protection advisers - after all, this newsletter is primarily aimed at them.
Issue 11, published in May, went 'electronic' - that is it appeared on HSE's home page on the Internet. I would be very interested to hear your views on how effective the electronic version was - for further details see the reader survey.
All HSE free publications may now be obtained from:
HSE Books, PO Box 1999, Sudbury, Suffolk, CO10 6FS, tel: 01787 881165; fax: 01787 313995.
Issue 11 of the Radiation Protection Adviser explained that we had prepared instructions to HSE's solicitors for drawing up draft revised regulations. Since then, we have been working closely with the solicitors to develop the revised regulations. In parallel with this work we have been drafting the Approved Code of Practice (ACOP) and non-statutory guidance to support the regulations.
A first draft of the regulations and ACOP and an outline of the guidance was discussed by the Health and Safety Commission's (HSC) Ionising Radiations Advisory Committee (IRAC) at its meeting at the end of July. We emphasised that these were early drafts with much work to be done on them but that we wanted IRAC's preliminary comments to guide the next stages of development. IRAC appreciated the opportunity to discuss the draft proposals and respected their preliminary nature. The committee was pleased with the progress being made, supported the general direction the regulations were taking and offered many helpful ideas and comments.
Readers may be interested in the approach we are proposing for that aspect of the radiation protection regime which often attracts the most attention - dose limitation. The revised Basic Safety Standards Directive permits Member States either to continue with a wholly annual system of dose accounting or to change to a system based on five yearly averaging for the main adult worker limit. This has ensured that dose limitation continues to be the focus of attention.
Because informal consultation showed there to be strong advocates of both systems, HSE's intention is to present both options in HSC's formal Consultative Document (CD), fully worked up as regulations, ACOP and guidance. The CD will then invite consultees to express their preferred option as well as commenting on the detail of each system.
Following the July meeting of IRAC, we have refined the draft regulations in conjunction with the solicitor and continued development of the ACOP and guidance. This and other material has been compiled into a full draft of the CD and circulated to IRAC for discussion at its October meeting. If required, IRAC will reconvene before Christmas to complete consideration of the document. Following IRAC approval, the draft CD will be submitted to HSC for approval to publish. Assuming these approvals are forthcoming without major revisions, the CD should be published in early 1998.
To give readers details of the CD once it is published, and to draw attention to some key issues, we intend to produce a special edition of the Radiation Protection Adviser, probably in January or February. This is part of a programme for ensuring the widest awareness of the CD and its contents and the broadest range of comments. A copy of the CD will also be accessible from the HSE home page on the Internet.
Issue 11 of the Radiation Protection Adviser gave details of the Carriage of Dangerous Goods by Road (Driver Training) Regulations 1996 (DTR2). A reader sought further clarification and we are repeating the information here for others who may be interested.
On the classification of packages, HSE and the Department of Transport generally accept that when 'Type A' radioactive material is carried in a Type B package it should be considered as a Type A package and labelled as a Type A package (on the outside). If such a package satisfies the criteria in regulation 4(9) DTR2, then the requirement for drivers to be vocationally trained does not apply.
Regarding 'adequate instruction and training', exemption from regulation 4(9) of DTR2 is on the basis that drivers have received instruction and training required by regulation 3 of DTR2. This regulation requires drivers to receive adequate instruction and training to enable them to understand: the nature of the risks involved and what to do in an emergency, plus their duties under the Health and Safety at Work etc Act 1974; and their duties under the Radioactive Material (Road Transport)(Great Britain) Regulations 1996.
There are no requirements on how such instruction and training should be delivered. For example, the operator may arrange formal training courses or arrange 'in-house' training. The main test applied by an HSE inspector would be whether drivers had an adequate knowledge of the issues detailed above.
When employers send instruments for test and calibration at a test house, what kind of service and information should they expect under the law? At a recent meeting of the Ionising Radiations Metrology Forum (IRMF), HSE was asked to provide some clarification on this issue. IRMF is an informal forum for calibration and test house centres that meets twice a year at the National Physical Laboratory to discuss ionising radiation measurement and calibration issues.
In recent months, a number of test houses have told HSE that they are unsure about the advice they should give to clients who submit equipment for test that is either obsolete or no longer within manufacturer specification. Test houses are also worried about their liabilities to clients who they know are using instruments in circumstances not covered by the calibrations they have been asked to complete. In the past, test houses have offered this kind of advice freely to clients but financial considerations are forcing them to take a fresh look at just how helpful they need to be in order to meet the requirements of IRR85 and applicable civil law.
Increasingly, employers want their equipment tested as cheaply as possible and they do not want to pay for the full range of traceable calibrations unless this is needed for the work they do with a particular instrument. In response to these commercial pressures, test houses have begun marketing cheaper, single energy calibrations for clients who have less stringent measurement needs. This has led some test houses to question the legality of these simpler types of test, before entering this market themselves.
IRR85 are clear about who has responsibility for the adequacy of these tests. It is the employer's duty to ensure that their measurement equipment is 'suitable' (regulation 24(2)), 'properly maintained', 'examined' and 'tested' (regulation 24(2)(a) and 24(2)(b)). Usually the employer's RPA should be consulted on how best to meet these requirements in relation to the work done (see IRR85 ACOP Part 1 paragraphs 75 and 150).
The employer may choose to ask a test house for advice on how to meet the requirements of regulation 24(2) for the particular working environment or the RPA may consult a test house before giving advice to the client. It may also be acceptable for the employer to appoint a suitable test house as an RPA for the specific purpose of advising on adequate monitoring under regulation 24 IRR85.
However, so far as instrument examination and/or calibration is concerned, the test house's duties are strictly confined to completing the tests specified by the employer competently and comprehensively. In this context, paragraphs 151 to 158 of Part 1 of the Approved Code of Practice to IRR85 give the relevant advice on the responsibilities of the 'qualified person'. The only caveat here is that, as with any service, test houses should ensure that their clients know exactly what sort of examinations and calibrations they have contracted for.
In June 1997 the Medical Devices Agency (MDA) issued a Hazard Notice to all health authorities, hospitals and independent health care units concerning a manufacturer's recall of lead protective devices. The warning was based on information supplied by the American Food and Drug Administration (FDA). The warning relates to protective devices manufactured after 1 October 1996 which had been found to be contaminated with a radioactive isotope. The contaminants are lead-210 (Pb-210) and its daughter nuclides bismuth-210 (Bi-210) and polonium-210 (Po-210).
The FDA had been advised that a small number of lead-impregnated protective devices might have been affected, including lead aprons, thyroid collars and gonad shields used in radiation shielding of staff and patients involved in X-ray examinations. The contaminated products do not pose a significant personal exposure hazard to those persons wearing such protective devices but best practice would suggest their use should be avoided wherever possible. The MDA warning advised managers to identify any stocks of lead protective devices delivered since October 1996 and to contact the supplier immediately to check if the stock was likely to contain contaminated material.
Copies of the MDA Hazard Notice and the FDA Public Health Notice are available from the Editor at the address given above.
Earlier this month HSE published the 1996 summary of annual doses on the Central Index of Dose Information (CIDI). Free copies of the summary are available from the Editor, see the front page for address. A further report on dose trends is in preparation.
The Institute of Physics and Engineering in Medicine (IPEM) has recently published, with HSE support, guidance on Minimum standards for routine performance testing of diagnostic X-ray imaging systems ISBN 0 904181 871.
HSE's Guidance Note PM77 Fitness of equipment used for medical exposure to ionising radiation ISBN 0 11 886313 4, first published in 1992, is being updated and is scheduled for publication in early 1998. Copies of the revised PM77 will be available from HSE Books, see page 1 for details.
HSE's booklet The examination and testing of portable radiation instruments for external radiation HS(G)49 ISBN 0 11 885507 7 will be withdrawn in December 1997. A working group of the IRMF supported by HSE is preparing updated guidance due for publication by the end of 1997.
An RPA recently sought advice on appropriate training for dental nurse assistants (DNAs) under the Ionising Radiations (Protection of Persons Undergoing Medical Examination or Treatment) Regulations 1988 (POPUMET).
The DNAs would have to operate dental X-ray equipment (both intra-oral and panoramic radiography). Their employer thought a six-week day release training course provided for dental surgery assistants by a local college was excessive for dental assistants. He proposed to provide this 'in-house' on the basis of his own training, experience and expertise.
The Department of Health (DH) believes that a six-week day release course is not excessive. Of course, it depends on the knowledge of staff and what the training course is supposed to address, but if the course is for general dental radiology, including radiation protection, practical aspects etc then it seems like a reasonable investment.
A one-day POPUMET 'core of knowledge' course given by the RPA (which would not cover practical training) might not be relevant for dental assistants. Such courses must be tailored to those attending them - a POPUMET course for doctors will assume
a baseline knowledge that cannot be the same for DNAs. DH advised that dental assistants can be accredited as DNAs but this is not a prerequisite to practice. Courses for DNA accreditation include dental radiology but DH is not aware that any NVQs have been developed in this area.
the next Society for Radiological Protection (SRP) Scientific Meeting will be held on 5 November 1997 at the Cavendish Conference Centre, London. The theme of the event is 'Medical exposures, health surveillance and the Patient Protection Directive'. For further information please contact SRP on 0171 287 4955.
The National Physical Laboratory (NPL) are holding a series of practical workshops in November on radioactive surface contamination, including IRR85 requirements. The workshops are aimed at the nuclear industry and nuclear medicine and hospital physicists. For further information please contact Clare Scott at NPL on 0181 943 6398.
In issue 11 we published a short article on the effect of mobile phones on safety equipment. The correct reference number should be
BS EN 61543 -Residual current-operated protective devices for household and similar use: electromagnetic compatibility. Apologies for any confusion caused.
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