Welcome to the fourteenth edition of the Radiation Protection Adviser. This issue includes a further update on progress with revising the Ionising Radiations Regulations 1985 (IRR85).
We have reviewed your responses to the readership survey, included with Issue 12, and decided that RPA News will continue in its existing form, at least until the revised regulations are introduced. It will also continue to be a free publication.
RPA News was originally aimed at RPAs only but since it was launched the readership has widened considerably. To reflect this, we are considering changing the title to Radiation Protection News - we would appreciate your comments.
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 13 of the Radiation Protection Adviser gave details of the formal Consultative Document (CD) published by the Health and Safety Commission (HSC). In May, and thanks to the good offices of the Society for Radiological Protection, the HSE team made a series of presentations, starting in Glasgow, finishing in Cardiff, and taking in London, Chilton and Manchester on the way. The seminars allowed HSE to set out some of the key issues in the CD, but with plenty of time for comments from the audience. Total attendance exceeded 300, which was very pleasing. Equally pleasing was the level of understanding of the proposals, as demonstrated by many of the questions and observations. Some of the main themes to emerge from the seminars were:
There was little criticism of the proposed justification requirement itself, but concerns were expressed, particularly from the medical sector, about how it would operate in practice. We recognise that the operative procedures for considering justification have yet to be developed.
It seems likely that the use of X-ray sets for medical treatment would also need to be covered by the relevant regulation. However, the main interest focused on the sub-regulatory activities; the development of generic authorisations and procedures.
The basic requirement for prior risk assessment seemed uncontroversial. The issue which raised more discussion was its potential combination with the risk evaluation for accidents (the updated version of IRR85 Regulation 25). Views on this seemed to be fairly evenly balanced.
The main discussion issue here was the 'ALARP investigation' and whether the 15 mSv dose level remained appropriate - again views on this varied. The other substantive regulatory changes here, including treatment of female employees, produced little comment.
Discussion was focused, not so much on the direct choice between Options A and B for the adult worker dose limit, but on the operation of the procedures within the options. There was also considerable interest in the proposed flexibility for the public dose limit relating to exposure from patients administered with radiopharmaceuticals.
There seemed to be little support for the status quo in IRR85 and little opposition to the basic regulatory scheme set out in the CD. Most of the comments centred on the workings of the recognition scheme itself and we appreciate that, once the regulatory requirements are settled, much work is needed on this aspect. We also were given a clear message that the requirement for written appointment of RPAs should be retained!
There was a range of views on the level of flexibility introduced into the draft revised regulations. However, the potential for confusion over 'specified systems of work' and 'local rules' was illustrated at one seminar in discussing how the draft regulation might affect dentists and this will need further thought.
The approach in the CD was based on using multipliers of values of individual nuclide quantities and concentrations that would appear in a schedule to the regulations. A number of comments suggested that the total quantity thresholds for this requirement would, for certain commonly used radionuclides, lead to notification of spillages to HSE with much greater frequency than is the case under IRR85, particularly in the medical sector. Clearly further work is needed on this, since the purpose of statutory notification is to draw to HSE's attention the more serious situations, giving HSE the option to conduct its own investigation.
We stressed at the seminars that HSC could only formally take account of written comments sent in on the CD. The message seems to have been heeded, as nearly 200 substantive replies were received! We have been analysing these and identifying where further change seems merited. The next stage is to put the proposals for the final version of the revised regulations and Approved Code of Practice to HSC's Ionising Radiations Advisory Committee (IRAC), and, subject to IRAC's views, on to HSC itself.
There was almost universal support from the comments received that the main parts of the regulations should be operative from 1 January 2000. Though the timetable remains tight, we are still on course for the revised regulations to be made and laid before Parliament in the summer of 1999. If achieved, this would allow duty holders several months to ensure they will be in compliance with the revised regulations by the operative date.
The task of analysing the comments, though daunting, was nonetheless rewarding for the ideas it provided to further improve the CD proposals. We are pleased that the earlier message asking for supportive as well as critical comments was heeded, as it helped to avoid introducing change where there was demonstrable support for the CD proposals. We are extremely grateful for the time and effort taken by all those who sent their comments or who have contributed within their organisations to a corporate response.
HSE has identified problems with two test houses offering examination and testing of radiation monitors for employers in the non-destructive testing (NDT) sector. The tests were insufficient to assure the performance of the monitors used during industrial radiography.
HSE carried out a limited campaign to increase the awareness of NDT employers about their responsibilities and to give general advice on testing. We thought that readers would be interested as the advice is applicable to employers all sectors, not just NDT employers
Under regulation 24 IRR85, it is the employer's duty to ensure that monitors are thoroughly examined and appropriately tested by a qualified person - Issue 12 of the Radiation Protection Adviser also gave advice.
The NDT employers were asked to consider in what circumstances monitors needed to be used and, in consultation with their RPAs, what minimum tests would be appropriate. The exact use of the monitors depends on the location and the circumstances during the radiography, but it is possible to identify common aspects, for example:
We were pleased to see that RPAs consulted on this issue gave similar advice. Therefore, HSE has suggested appropriate minimum tests for monitors used in the general run of mainstream industrial radiography. A thorough examination would generally include a test:
Also, where the monitor is used in X-radiography at energies less than 150 kV, the tests would normally need to give assurance of the response at lower energies. This can be done by testing the monitor's response, over part of the dose rate range, to radiation emitted from an 241Am check source. It should be possible to carry out the tests at the highest dose rates without positioning the radiation monitor too close to the radiation source. A distance shorter than 100 mm would usually be insufficient.
All employers need to be able to identify the minimum level of testing required for their monitors. Normally, this would be done in consultation with the appointed RPA and, frequently, the qualified person in the test house. In any event, the employer needs to be satisfied that the test house is able to complete the required tests in a competent manner.
HSE has recently issued a new certificate of approval under IRR85, Schedule 2, giving values for barium-137. The certificate was granted when HSE became aware that barium-137m was being used in relatively small quantities in the education sector and there were no specific values in schedule 2 IRR85; the default numbers for other nuclides were thought to be unreasonably restrictive. The new values were calculated on the same basis as the values for other radionuclides in schedule 2 IRR85. A copy of the certificate is available from the Editor.
HSE published the second dose 'trends report' in July 1998, covering the period 1990 to 1996. Free copies of the report , Occupational exposure to ionising radiation 1990 - 1996 - analysis of doses reported to the Heath and Safety Executive's Central Index of Dose Information, are available from the Editor, see front page for address.
The major part of the the report is also available on HSE's web site - http://www.open.gov.uk/hse/cidi2.pdf
For classified persons as a whole the data on CIDI suggest that, in general, employers have continued with the successful reduction of exposures reported in the first trends report. When the special case of non-coal miners is excluded, the number of classified persons exceeding the investigation level in IRR85 (15mSv) had fallen to 17 by 1996 compared with the 1986 figure of 1,911 (after corrections for notional doses).
The Institute of Physics and Engineering in Medicine has recently published a report looking at the ccritical examination of x-ray generating equipment in diagnostic radiology, Report 79, ISBN 0-904181-89-8, priced £8. This gives advice on the requirement in regulation 32 IRR85 on persons installing or erecting articles for use in work with ionising radiation.
Earlier this year HSE published revised guidance on respiratory protective equipment, the selection, use and maintenance of respiratory protective equipment, HS(G)53, ISBN 0-7176-1537-5, priced £9.50. Copies are available from HSE Books, see front page for address. This practical guide revises the 1990 version of HS(G)53 and replaces EH53, Respiratory protective equipment for use against airborne radioactivity.
A domestic and commercial waste company was recently prosecuted, by HSE and the Environment Agency, and fined £120,000 plus costs, for losing two radioactive gauges. Further details in Issue 15.
This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. The information it contains is current at 10/98. Please acknowledge the source as HSE.
Printed and published by the Health and Safety Executive C45 10/98