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Radiation Protection Adviser

Issue 17 May 2000

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Welcome to the seventeenth edition of the Radiation Protection Adviser.

The new Ionising Radiation Regulations (IRR99) came into effect on 1 January 2000 and this issue provides a further update on supporting procedures such as prior authorisation and the scheme for RPA recognition. Other news includes a review of two prosecutions and an example of good practice for site radiography.

Readers will be pleased to note that the IRR99 ACOP 2 was published on 3 April 2000. It provides practical help for employers who need to comply with IRR99. It can be obtained from;

HSE Books
P O Box 1999,
Sudbury,
Suffolk CO10 2WA
Tel: 01787 881165
Fax: 01787 313995
Website: http://books.hse.gov.uk.

*Work with Ionising Radiation' Approved Code of Practice, Regulations and Guidance. ISBN 0-7176-1746-7.

Please send your comments, queries and mailing list details to:

Karen Davies,
The Editor,
RPA Newsletter,
Health and Safety Executive (HSE),
Level 3, North Wing, Rose Court,
2 Southwark Bridge,
London SE1 9HS.

HSE's Ionising Radiation web site: http://www.hse.gov.uk/radiation/ionising/index.htm


RPAs

RPA 20001 became the first organisation to be recognised by HSE as an Assessing Body for the certification of individual RPAs. Individuals who wish to act as an RPA must either :

  1. hold a valid certificate of competence from an organisation recognised as an Assessing Body by HSE;
  2. hold a National or Scottish Vocational Qualification (N/SVQ) level 4 in Radiation Protection Practice issued within the last five years; or
  3. under transitional arrangements up to the end of 2004, have held a formal appointment by an employer as an RPA under IRR85.

Before undertaking work with radiation, employers may need to consult suitable RPAs for advice on how to comply with IRR99.

HSE's statement on RPAs, including the criteria of competence, is available on the HSE website

*RPA 2000,
PO Box 27,
Ilfracombe,
Devon EX34 7YS
tel: 01271 862665;
fax: 01271 862151;
E-mail: admin@srp-uk.org

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Prior Authorisation

From 13 May, Regulation 5 of the Ionising Radiation Regulations 1999 places a new legal duty on radiation employers, to have written permission from HSE before carrying out specified operations.

HSE has issued two certificates of generic authorisation:

(i) for the use of X-ray sets for:

(ii) for the use of accelerators (other than electron microscopes, which do not need to be authorised under IRR99).

The certificates were prepared after considerable consultation with the employers likely to be affected. Because of our in-depth consultation we hope that no-one will need to apply for individual prior authorisation. Copies of the certificates are available on HSE's website at:

Where employers are able to meet all the conditions in the relevant generic authorisation, authorisation is automatic: the employer does not have to apply to the HSE. Employers will only need to apply to HSE for individual authorisation where these conditions cannot be met. Any employer who believes that an individual authorisation under the Regulations is required, may wish to discuss the issue with the local HSE Inspector. All applications for individual authorisations should be made to the local office.

An information Sheet on authorisation under IRR99 was published on 19 April, and is available from HSE Books. It contains guidance on which practices are subject to authorisation and includes the text of the certificates of generic authorisation.

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Appointed Doctors

Medical surveillance under IRR99 is essentially similar to that under IRR85, although there are a few changes to the regulations and ACOP. For instance, in regulation 24(2) it is now spelt out that the purpose of medical surveillance is to determine 'the fitness of each employee for the work with ionising radiations which he is to carry out.' This reflects the thinking in the International Commission on Radiological Protection 60 recommendations which gives due weight to the fitness for work component of the examination. Greater leeway is given in regulation 24(5) with regard to the timing of periodic reviews of health. Reviews can take place one month before, to one month after the review date. This greater flexibility, which was requested by industry, should ease the planning of periodic reviews of health. In the ACOP there is one change to the definition of adequate medical surveillance. This is the need to consider whether a review of health after cessation of work is necessary to safeguard the health of the individual. However, there are likely to be few occasions where this is necessary.

The guidance on medical surveillance prepared for Appointed Doctors has been extensively revised and expanded, and this will be sent out to them by their regional Senior Medical Inspectors. The guidance emphasises the need for co-operation between the various parties who have an interest in health surveillance and parts may be of interest to employers and employees. Appointed Doctors are at liberty to copy the document on request.

Probably the greatest change to the Appointed Doctor system is the introduction of a requirement for doctors appointed under IRR99 to attend a one day training course on the regulations, health effects of ionising radiation and the practical aspects of providing medical surveillance. It is expected that these courses will be run by the same organisations that provide introductory courses in occupational medicine, and that courses will be run on an occasional basis to meet demand. The syllabus for this training is included in the revised guidance which will be sent to Appointed Doctors.

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Type Approval - Gaseous Tritium Light Sources

HSE has issued updated type approval certificates. The certificates relieve employers of the obligation to notify HSE where ionising chamber smoke detectors are installed/stored in bulk or gaseous tritium light source devices (GTLS/Ds) are installed, and no other work with ionising radiation is carried out. Despite our best efforts and consultation over the text of the certificates, an error crept into certificate No.TA2. As currently worded, it implies that there is type approval under certificate No.TA3 for the bulk storage of GTLS/Ds. As there is no such type approval, and it is unlikely that an application would be successful, HSE have revised certificate No.TA2.

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Outside Workers

The Information Sheet, Protection of outside workers against ionising radiation (IRIS 4), published on 19 April gives advice to employers on provisions relating to outside workers under IRR99.

It provides information on:

Readers are reminded that radiation passbooks approved under the 'Outside Workers' Regulations 1993 may continue to be used until the outside worker changes employer, after which the new employer will need to obtain a radiation passbook approved under IRR99 (if the employee continues to be an outside worker).

Outside workers are classified persons (i.e. those likely to receive an effective dose in excess of 6mSv per year or an equivalent dose which exceeds three-tenths of any relevant dose limit), who carry out services in the controlled area of any employer other than the controlled area of their own employer.

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Prosecutions

Cambridge University was conditionally discharged and ordered to pay £22,000 costs recently, after it pleaded guilty to three charges relating to the loss of radioactive material. The prosecution was brought under Section 32 of the Radioactive Substances Act 1993, the Health and Safety at Work etc. Act 1974 and the Ionising Radiations Regulations 1985 following the loss of 9.25 MBq of phosphorus-32 by the university's department of biochemistry.

 

The United Kingdom Atomic Energy Authority was fined a total of £100,000 at Dornoch Sheriff Court on 29 March 2000, after entering guilty pleas to three separate charges under Regulation 7 of the Ionising Radiation Regulations 1985 (IRR 85).

The charges related to three of UKAEA's employees having intakes of plutonium in 1995. The intakes of plutonium of the three individuals, who all worked in the Fuel Cycle Area at Dounreay, were detected during their annual routine reassurance urine sampling in 1996. During 1995 there had been no evidence to suggest that the three individuals had been involved in any incidents, eg high readings from static air samplers, which would have alerted UKAEA to the possibility that there was a potential for plutonium intakes and a need to start special biological sampling.

The affected individuals needed to go through an extended period of special biological sampling in order to arrive at an estimate of the intake and hence the committed dose. This resulted in dose estimates for committed effective dose equivalents were up to 244mSv whole body and up to 4400mSv individual organ. These exceeded the IRR85 Schedule 1 limits of 50mSv and 500mSv respectively. Following an application from UKAEA, the amendment by special entry to the individuals' 1995 dose records were approved by HSE in accordance with Regulation 13(9) of the IRR85, in 1998. HSE's formal investigations followed immediately and a report recommending prosecution of UKAEA was submitted to the Procurator Fiscal in March 1999.

As a result of the intakes to these personnel, UKAEA undertook a review of not only the internal dosimetry arrangements across the site but also the general contamination control aspects. The review team included experts from other companies, the outcome of which has lead to an increase in the use of personnel air sampling on the site. Also UKAEA prepared four codes of practice covering aspects of active handling (Use of fume cupboards and glove boxes; temporary containments (tents); pressurised suit operations: personal and equipment monitoring) and considerable refresher training of staff was undertaken. UKAEA now believe that their arrangements at Dounreay are in line with modern best practice.

At the court, the Sheriff emphasised that it was "particularly important that employers should do all that was reasonably practicable to ensure the safety of its employees particularly when the risk was silent, invisible or insidious, like radiation". The Sheriff was disturbed by the fact that cause of the intakes was not known, and the level of fine reinforced this concern.

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Site Radiography - Example Of Good Practice

HSE has been informed of a good example of a client and an industrial radiographer contractor working together to restrict exposure to ionising radiation as far as is reasonably practicable.

The example involved the development of a specially designed pipe line crawler for a particular company in the offshore oil and gas production sector. The exposure mechanism had been altered to enable the source to be driven from its shielded position by compressed air. A restraining spring was designed to ensure that the source returned to its shielded position if the air pressure was removed. Control of the crawler movement and source was by a remote computer system. The contractor also constructed a series of lead-lined boxes in different sizes to fit around the particular shapes of the pipe. The aim of the shielding boxes was that they restricted the size of the controlled area by reducing the dose rates generated from the pipeline crawler. On inspection of the operation, dose rates were measured at less than one metre from the pipe and they did not exceed 1 microsievert per hour.

HSE were particularly impressed by the two companies working together to produce this design and it is certainly a good example of effective co-operation between two employers. The steps taken to automate this work and to provide shielding close to the exposed source also enabled the radiography to be done in situ without interrupting production. Thus both parties benefited: the radiographer had doses restricted and the client did not lose out by lowering the rate of production.

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New Ionising Radiations (Medical Exposure) Regulations 2000

The Ionising Radiation (Medical Exposure) Regulations 2000 (IR(ME)R), which replace the Ionising Radiation (Protection of Persons Undergoing Medical Examination or Treatment) Regulations 1988 (POPUMET), have been made to implement Council Directive 97/43/Euratom (the Medical Exposure Directive). IR(ME)R come into force on 13 May 2000 and are available on the Internet at
http://www.legislation.gov.uk/uksi/2000/1059/contents/made.

Information on the associated non-statutory regulatory guidance is available on the Internet at
Department of Health.

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HSE Guidance

HSE has published free Information Sheets in the Ionising Radiation Protection Series:

The following information sheets will be published at a later date:

These Information Sheets are available from HSE Books and will soon be available on the HSE website.

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Pregnant Workers Guidance

HSE is about to consult interested parties on draft guidance: Safe work with ionising radiation for expectant and breast-feeding mothers. If you would like to receive a draft to comment on, please email: ionising.radiation.hd@hse.gov.uk

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Stop Press

Issue 18 (due to be published in November 2000) will be the last paper copy distribution. Future issues will be published on HSE's web site. We will be consulting readers shortly to update our database and we will be asking whether you have access to the internet. For those readers who do not have access to such facilities we will send you paper copies.

This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. The information it contains is current at 11/2000. Please acknowledge the source as HSE.

Printed and published by the Health & Safety Executive

All HSE free publications may be obtained from: HSE Books, PO Box 1999, Sudbury, Suffolk, CO10 6FS Tel: 01787 881165; fax: 01787 313995 

Updated 2011-10-14