(formerly The Radiation Protection Adviser) incorporating ADS News
Welcome to issue 21 of Radiation Protection News which aims to clarify areas of concern and update readers on further developments in the field of ionising radiation. We are pleased to welcome several contributions from outside HSE and would be happy to consider others for future issues.
Please send any comments, queries and contributions to Ionising Radiation Policy Unit, Health and Safety Executive, Level 6, North Wing, Rose Court, 2 Southwark Bridge, London SE1 9HS;
This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. Please acknowledge the source as HSE.
The Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) http://www.legislation.gov.uk/uksi/2001/2975/contents/made require operators to notify HSE of the dose levels they have determined to be appropriate for intervention workers in the event of a radiation emergency. Under REPPIR, in the event of a radiation emergency the dose limits contained in the Ionising Radiations Regulations 1999 (IRR99) http://www.legislation.gov.uk/uksi/1999/3232/contents/made are disapplied. Operators already carrying out work with ionising radiation when REPPIR came into force had until 20/2/02 to notify HSE under regulation 14 of the emergency exposures they have determined to be appropriate for intervention workers in the event of a radiation emergency. It has been recognised that neither HSE's recently published guidance on REPPIR, nor NRPB guidance on the protection of workers (Documents of the NRPB Vol.1 No 4 1990, p3) included numerical values which could assist duty holders, and provide HSE inspectors with a benchmark against which to judge operator's proposals for emergency exposure levels. Provisional guidance to HSE NII's Assessors has therefore been developed and is on our website for information.
A workshop was held at Chilton on 15 March 2002 to discuss draft proposals on principles for the protection of on- site personnel in the event of a radiation accident. The event was jointly sponsored by NRPB and HSE and was attended by almost 100 practitioners from a broad range of industry sectors. A number of speakers gave presentations based upon a recently released draft NRPB discussion document (NRPB web site, www.hpa.org.uk/radiation/publications/) This proposed, inter alia, that when making emergency plans employers should identify the areas where non-stochastic and stochastic doses are likely to be received. An emergency planning threshold of 1.0 Gy for low LET radiation and 0.5 Gy for neutrons is proposed. Justification and optimisation of protective measure for the high risk group on site (non-stochastic doses) would need to be demonstrated separately from the justification and optimisation of measures for those at risk of stochastic health effects only.
A number of issues and queries were raised by participants which included the role of prior passive measures as part of the relevant plant safety case, the usefulness of on-site ERLs and the interface with REPPIR requirements. NRPB and HSE are allowing a period for further written comments to be submitted (by 30 June 2002 ) before revising the current proposals.
The IAEA is developing a Safety Guide which will specify levels of radionuclides, both natural and artificial, which are intended to distinguish between commodities that could be traded freely and those that require special consideration on radiological protection grounds. Commodities includes substances, materials, goods, foodstuffs, consumer products etc. Concern over the absence of internationally accepted levels for international trade in commodities was expressed in the 2000 session of the General Conference of the IAEA. This led to resolution GC(44)/RES/15 which included an objective for developing the radiological protection criteria for consideration by the General Conference at the September 2002 meeting. The IAEA draft values are set in terms of Bq g-1 and are referred to as 'scope defining levels'. The intention is that commodities with activity concentrations below the levels could be traded freely. If above these levels, the commodity would be subject to special considerations on radiological protection grounds but not necessarily banned.
The first UK National Radon Forum was held at Matlock Bath on 12 April 2002. Some 90 people attended, including radon scientists, national and local government officials, remediation companies, house builders, building contractors, and materials suppliers. This is a new initiative, funded by the European Commission (as part of the European Radon Research and Industry Collaboration Concerted Action project - ERRICCA) to bring people together who have a role to play in helping to reduce the risk from radon in the UK. The Forum heard about current radon activities from a number of organisations, including representatives of central government - the Department of the Environment, Food and Rural Affairs, the Department of Transport, Local Government and the Regions, and the Health and Safety Executive - the National Radiological Protection Board (NRPB), the Building Research Establishment (BRE), the British Geological Survey, and the Radon Council. The Forum will meet on an annual basis.
The UK Forum is one of twenty fora being set up across Europe, all of which will be linked to a European Radon Forum. The intention is that each Forum will be linked in due course via the Internet to create a network of radon information sources accessible to anyone. The UK co-ordinator is the Building Research Establishment. Further details can be found on its website - http://www.bre.co.uk/radon
The counties most seriously affected by radon are Cornwall and Devon. However, surveys of radon levels indicate substantially increased radon levels in Northamptonshire and parts of Derbyshire, Somerset, Grampian and the Highlands regions of Scotland. Elevated levels have also been found in small pockets in other areas. NRPB have carried out, and mapped the results of, extensive measurements from across the UK. Further details are available on the NRPB website - http://www.ukradon.org/services/
The Ionising Radiations Regulations 1999 (IRR99) http://www.legislation.gov.uk/uksi/1999/3232/contents/made require employers to take action where radon is present above a defined level - generally 400 Bq/m3 averaged over 24 hours. Employers with premises in radon affected areas should carry out a risk assessment to determine whether or not their premises have radon levels that are subject to IRR99. This assessment is likely to include a number of measurements around the premises and the results and conclusions should be recorded. Where levels are found to exceed 400 Bq/m3 averaged over 24 hours then remedial actions should be taken to reduce the levels. If the levels cannot be reduced sufficiently, then a radiation protection adviser must be consulted and measures put in place to restrict exposures to a level which is as low as reasonably practicable. Further advice is available from the local HSE Office or the Environmental Health Department of the Local Authority, as appropriate.
HSE has published a free leaflet on Radon in the Workplace (reference INDG210 available from the HSE website - (withdrawn March 2006) and is considering if further guidance should be published to help employers in radon affected areas.
We welcome the following contribution from Kevin Connor, The Hannah Institute, on a distance learning course being developed to help people with their applications to RPA2000 for certification of core competence.
The requirement for RPAs to become certified by December 2004 is still causing some concern at all levels. Many RPAs are finding it difficult to put Portfolios together for various reasons. In many cases these reasons are subjective and once they "grasp the nettle" of putting together their evidence they should have fewer problems. However for many their concerns are quite real and we must respect this. Some people just need help and if we do not provide it now many will just give up or fail to become certificated in time. With RPA 2000 currently taking on average 4 months and occasionally up to a year to deal with certain Portfolios at the present low submission rate, the worry is that most RPAs will delay their Portfolio submission till 2004, resulting in a log jam of applications and still further delay. The best advice is that if you do not get your Portfolio in by mid 2003 you may have little chance of meeting the deadline.
Within Universities and Hospitals many RPAs do not have full-time duties in radiation protection. Many deal with only specific hazards i.e. only unsealed sources or only X-rays etc and much of this for only small percentages of their time. As such, many RPAs in part-time posts will find it difficult to put a Certification Portfolio together that will demonstrate core competence for aspects of radiation protection that have never been in their remit. What is required in these cases is some education to teach them those bits of the HSE Basic Syllabus missing from their experience, and some tutoring on how to put together a Portfolio of Evidence.
There is a real need to formally teach people radiation protection. With few formal academic routes of study there are few ways of teaching the underpinning knowledge required by an RPA. In the Author's opinion the training courses currently available are not ideal, not benchmarked specifically to the HSE's basic syllabus (as per Annex 3 of HSE's Statement on RPAs ) and are very expensive. In many cases they are not available to people outside of the big organisations. At present within radiation protection "on the job training" is the accepted norm as most people learn through experience. The catch 22 is how are we going to bring new blood into radiation protection if such formal routes are not improved? How are you going to demonstrate core competence in a workplace that does not provide you the opportunity to demonstrate the core competencies? Are we really saying that people who have been working for 20 years in a narrow field within radiation protection are no longer competent? Before IRR99 such a person was considered to be competent and suitable for the specific job. But the goalposts moved in January 2000 and the law is now saying that such a person is not competent unless they can demonstrate they meet the HSE Criteria of Competence. This includes demonstrating that they have the knowledge and understanding of the Basic Syllabus as set out in the HSE Statement on radiation protection advisers.
Within the AURPO we have recognised these issues and are now working with the University of Strathclyde to be a training provider to teach only to the Basic Syllabus for the RPA and provide guidance in creating a Certification Portfolio. It is hoped that, by working closely with both HSE and RPA 2000 to benchmark our course to their standards, the AURPO certificate would provide real value when presented as part of a certification portfolio. This would potentially be invaluable in speeding up the certification process. HSE and RPA 2000 are not in the business of approving courses. We are not looking for that. Rather we would wish this course to be seen as something real that would add value to a Portfolio.
The AURPO Certificate will be on offer from October 2002. It will be a distance learning course lasting approximately six months led by certificated AURPO Tutors. This is not about teaching people to be radiation protection advisers. We are only concerned with teaching and demonstrating the basic core competencies. Suitability for post is an employer's issue and not what RPA 2000 is concerned with. As such, all RPAs need to be able to demonstrate the basic competencies and this course is relevant to all RPAs and not just AURPO, University or Hospital based RPAs.
The course will involve around 60 hours study and cost around £700. It will be Internet based using electronic learning software. If you already have quite some experience and knowledge in radiation protection you should skate though the modules very quickly. Learning outcomes will be validated by completing both assignments and practical activities. At the end of each module the student could chose from up to 10 practical activities. Some of these would be compulsory and require to be written up in the course work-book. If you have particular gaps in your knowledge or skills then the course will provide an opportunity to address these. For example, in situations where a student's workplace may not provide an opportunity to demonstrate a particular competency it is hoped the tutor can liaise within AURPO to allow a student to fulfil this gap at another AURPO establishment. We also hope to offer optional AURPO practical workshops to address particular issues.
One of the confusions with the Portfolio system has been just what to include in a Certification Portfolio. RPA 2000 have in the past received huge Portfolios submitted with too much evidence and much that is not relevant. The tutor will advise on what evidence to include in your Certification Portfolio and how to set it out to make the RPA 2000 Assessor's job easier. The Tutors will also be able to guide you in what to accumulate in an optional "Suitability Portfolio", that may help satisfy your current or future employer that you are a suitable RPA.
It is envisaged the final award will be in the form of
AURPO Certificate in Radiation Protection
Part 1 - A certificate of Academic Achievement (to address HSE basic syllabus)
Part 2 - A certificate of Practical Performance (to address RPA 2000 criteria)
It is important that the course teaches only to the depth of knowledge required by HSE to avoid the course becoming too bias towards some aspects of radiation protection i.e. nuclear or hospital physics etc. Where possible a Tutor familiar with a students workplace will be appointed to advise on suitability issues. In this way we perceive this course to be of value to all RPAs whether AURPO, SRP, BNFL or IPEM.
Initially the AURPO Certificate is seen as a short-term, stand alone course, aimed at assisting RPAs get certificated by December 2004. In the long-term we see the future of such a course as an optional module integrated into Strathclyde University's current Post Graduate Certificate in Occupational Health and Safety (IOSH accredited). The risk based approach of the IRR99 brought radiation protection clearly back in line with the risk based principles of the Management of Health and Safety at Work Regulations 1999 and other health & safety at work legislation. As many RPAs do already have general health and safety responsibilities it seems natural that such training should be on offer as a specialist option in a General Health and Safety qualification.
We have already had a very positive response to this concept. We have some sixteen RPAs who have already registered a definite intention to enrol on the course this October, with another twenty or so very interested. This course will not appeal to RPAs who feel that they are "re-sitting their driving test" or do not want to do the course work. I would reiterate that we are not trying to teach people to become RPAs. We are only concerned with demonstrating core competency.
Still on the subject of recognition of RPAs, Sheila Hawkins, Employment National Training Organisation, has provided the following update on S/NVQs. HSE, SRP and ENTO are actively working to find to an Awarding Body (possibly City and Guilds again) and Assessment Centres etc to make the qualification available
Revised National Occupational Standards in Radiation Protection (Level 4 S/NVQ) have now been approved. The Employment NTO has worked with HSE and SRP to develop standards that more accurately reflect the role of people working in a diversity of settings to ensure radiation protection. These standards are freestanding, but form part of the review of the Employment NTO Health and Safety Standards which are now available on CD-ROM. The CD-ROM also contains the National Occupational Standards for Health and Safety Regulators and Occupational Health and Safety Practitioners, along with the qualification structures and assessment strategies for each area. All the material is in an easy to read format - and can be printed off for further use.
The new standards are the benchmarks of good practice - capturing the skills and competencies needed to perform activities to a nationally agreed standard.
ENTO sees these Standards as more than just qualifications. Individuals and organisations can use the new standards as personal and organisational development tools, eg to develop:
The Standards can be ordered online from the Employment NTO web-site: www.ento.co.uk or through the Employment NTO orderline 0116-251-9727.
For further information, please visit the ENTO web-site www.ento.co.uk or contact:
Technical Support Manager
Thanks are due to Penny Allisy-Roberts,
Bureau International des Poids et Mesures,for this update.
Medical and Dental Guidance Notes were commissioned and are soon to
be published by the Institute of Physics and Engineering in Medicine
with the support of the regulatory government and professional bodies
to provide a good practice guide on all aspects of ionising radiation
protection in the clinical environment.
The first two chapters lay the foundation for the main ionising radiation regulations. There are a further seventeen chapters relating to each specialty or specialist radiation protection application. Some specific advice is summarised in the twenty-one Appendices that also contain proformas, flow charts, contact details and over 150 references.
The Medical and Dental Guidance Notes will be an essential reference book for all those working with ionising radiation in medical or dental practice, including medical and dental staff, radiographers, scientific and technical staff, and their employers.
It will be available from IPEM Publications, Fairmount House, 230 Tadcaster Road YORK, YO24 1ES
ISBN 1 903613 09 4
@ £20 per copy (IPEM Members £14) plus postage and packing (10% UK, 15% Europe, 20% Airmail). Please contact the IPEM for multiple-copy discounts.
Significant levels of radiation exposure continue to be recorded for people involved in site radiography. Part of the problem appears to be that some clients (i.e. any party involved in a contractual role on site) who employ site radiographers have difficulty in understanding, and therefore effectively managing and monitoring site radiography activities and the associated health and safety standards.
As an HSE inspector with extensive previous experience of site radiography work, I have spent some time dealing with the immediate and specific problems presented by site radiography contractors. The basic 'bread and butter' management and equipment problems have included, for example, the lack of 'emergency' equipment; specific local rules; adequate barriers; and warning lights or monitors (or monitors not calibrated or with low batteries). In many cases, the clients felt insufficiently confident technically to assess, monitor or challenge the site radiographers. The clients who engaged the site radiographers often considered the work to be extremely 'specialist' and highly technical and this, combined with the fact that the work was generally undertaken out of normal working hours, made them reluctant to effectively challenge the way in which the task was performed. This contrasts with similarly complex work that clients have to manage and monitor, such as roofwork, demolition, scaffolding etc, where the checks, challenges and proper responses from sub contractors are now well known and easily accomplished by most clients.
Where it was clear that the clients who had engaged the site radiographers were not managing and supervising the work properly, issuing Prohibition and/or Improvement Notices as appropriate all the way up the contractual chain ensured that no-one escaped their management responsibilities. A typical set of Notices in a situation where, for example, gamma radiography being done without the emergency kit on site, would be:
i) An Immediate Prohibition Notice to the site radiographers - stopping them from working until the emergency kit was on site.
ii) Improvement Notices to all other contractors with responsibilities towards the site radiography work - stating that :- 'there is a need for site radiography awareness training for those persons responsible for managing, supervising and monitoring site radiography work on site. A one day course would be adequate.'
I have backed up issue of the enforcement Notices with advice on where training could be obtained, having allowed between one to three months to accomplish the training and, where necessary, extending the Notice compliance time.
The cost of such training has been easily mitigated by the fact that there were usually 2 or 3 contractors requiring training, and they have co-operated and shared the training costs. Several employers have seen this as an opportunity to train a number of their staff at the same time, and on the same course, so that if they have site radiography work country wide then they are not faced with the same potential problem elsewhere.
The one day courses that I have seen run have been composed of both theory and practical aspects, covering: the basic physics involved; the relevant legislation; radiation protection issues; monitoring and dosimetry; and various practical demonstrations of site radiography. The most useful part of the course has been a faultfinding audit of a simulated site radiography situation. A situation has been set up with a number of 'glaring errors' for the trainees to find and identify; e.g. a 'totally useless radiographer' played by the instructor, who had: no proper paperwork on site; no film badge or TLD; no assistant; no warning devices/notices; incomplete barriers; no emergency kit; and had also set his work up very close to other (simulated) hazards or people.
The majority of trainees have been pleasantly surprised at how easy it is to monitor and challenge site radiographers after this training. Trainees who began the training thinking that they would never get to grips with it have started to really lay into the 'useless radiographer' during the practical exercise, telling him exactly what was wrong and why. On one occasion I heard a trainee say "You can get off my site right now - and you'll never work here again". Clearly he'd really got into the spirit of the exercise! At the end of the course students have confirmed that they now felt confident to approach site radiographers and challenge and monitor them positively.
I have been pleased to find that, on my return to sites that have carried out such training there has been a really positive monitoring of the site radiographers, that faults have been found and rectified without my intervention and, best of all, I haven't found any problems either!
The clear 'spin off' benefit is that site radiographers will have to improve their ways if they know they are going to be challenged, not only infrequently by HSE Inspectors on site visits but also frequently by clients who have previously just waved them through the site or factory entrance.
The Department for Environment, Food and Rural Affairs (DEFRA) has provided the following information
The luminising of the hands and numerals of clocks and watches was one of the earliest uses of radioactive material in the early 1900s. Radium was originally used for this purpose, as it was readily available from certain ores. However, the highly radiotoxic nature of the radium quickly became apparent, most notably in the case of American workers employed to paint luminous dials by hand - many suffering severe health effects or death as a result. It was not until artificial radionuclides began to be produced on a commercial scale in the 1950s that less dangerous radioactive luminising agents such as tritium and promethium became available. The use of radium in timepieces has now been discontinued but significant numbers of radium luminised timepieces remain in circulation in the UK, particularly in the antique market. These days only tritium and promethium are used in line with international standards. It is believed that hundreds of thousands of new watches with radioactive paints on their hands and numerals are sold in the UK every year. In addition, watches containing light sources which use tritium gas in sealed glass bulbs are also available to the general public.
Up until now those in the retail and antique trade have been free to dispose of damaged clocks and watches luminised with radioactive material, that are beyond repair, in the dustbin with other general refuse. Today because of a change in legislation made necessary by the Basic Safety Standards Directive (96/29/EURATOM) the situation has changed (see final paragraph of this article) and you may be required, in certain circumstances, to seek Environment Agency approval under the Radioactive Substances Act 1993 (RSA 93) http://www.legislation.gov.uk/ukpga/1993/12/contents before disposing of such timepieces. Those circumstances are:
If you believe you will find yourself in either situation you will need to obtain a certificate of authorisation for the disposal of these articles from the Environment Agency, who administer the Act. A formal written application will have to be made using form RSA-3, available on the Agency website at www.environment-agency.gov.uk. The assistance of a specialist radiation adviser may be necessary in making an application. The Environment Agency will charge a fee for processing the application; the process should be completed within 4 months from receipt of the application. The application and related details will be included in the local Environment Agency public register. Non-compliance with this requirement can result in prosecution. If you have any queries about the authorisation procedure required under RSA 93 you should contact the Environment Agency on 0845 9333111.
If you are involved in the manufacture or repair of clocks and watches involving radioactive luminous material you will already be working within the confines of RSA 93 and IRR 99 and the introduction of this new legislation will have no effect on you.
A major implication of this change in the law is that those in the retail and antique trade will now need to know what radioactive substances are on their premises and in what quantity. To find this out will mean contacting clock and watch manufacturers who will be able to tell you about the radioactivity in their products. If, for any reason, this is not possible then an organisation such as the National Radiological Protection Board (NRPB) can take specialist measurements to determine the amount of radioactive material in each article. Contact with the NRPB should in the first instance be made via their Consumer Product Group in Leeds; telephone 0113 2679041 or email email@example.com.
The change in law has been made by way of the Radioactive Substances (Clocks and Watches) (England and Wales) Regulations 2001 (SI 2001 No 4005) http://www.legislation.gov.uk/uksi/2001/4005/contents/made which insert new text into RSA 93 and which should be read in conjunction with the Act. Copies of the regulations can also be obtained from the Department for Environment, Food and Rural Affairs, Ashdown House, 123 Victoria Street, London SW1E 6DE; telephone 020 7944 6277. The Environment Agency will be able to assist you with any queries about the details of the regulations. Please note this legislation does not apply to private individuals with a related horological hobby/collection.
Recent inspection activity in the aerospace and industrial radiography industry has revealed that those engaged in the restoration of vintage civil and military aircraft are largely unaware of the radiological risks involved in their work.
Many aircraft, but mainly those built before circa 1950, have instrument dials luminised with radium paint. Dose rates on contact with these instruments can sometimes exceed 200 μSv h-1 β/γ (e.g. Seafire fuel gauge) and dose rates in the pilot's position may be as high as 15 μSv h-1 β/γ (e.g. North American Harvard). If the instruments are taken apart there may also be a significant contamination risk and, in enclosed cockpits or storage areas, radon exposure may be significant.
A risk of significant radiation exposure to those restoring, maintaining and flying such aircraft, and those visiting museum cockpit exhibitions, therefore exists although, for the most part, those carrying out such activities are unaware of those risks.
The HSE will be exploring ways to further publicise and research the problem. In the meantime the following steps can be taken to reduce likely exposures to levels which are as low as reasonably practicable. In all cases, however, the advice of a suitable radiation protection adviser should be sought.
1. A risk assessment should be undertaken and a radiation survey of
the instruments and cockpit should be performed. Where dose rates in
excess of, say, 2.5 μSvh-1 β/γ exist at the pilot's position,
steps should be taken to reduce radiation levels and/or prohibit access
by members of the public. Simple measures such as replacing the instrument
glass with a thicker variety (provided there is no likelihood of contamination),
or the replacement of switches etc. with newer types, may be reasonably
2. When not in use or installed in the aircraft, instruments should be stored in sealed plastic bags. Checks for loose contamination should be undertaken when the instrument is overhauled or fitted in the aircraft. Where large numbers of instruments are stored together checks on radon levels will be appropriate.
3. When maintaining or overhauling instruments care should be taken to avoid the spread of contamination or possible personal contamination. They should only be handled when wearing appropriate gloves and, where there is evidence of paint flaking, a simple dust mask should also be worn.
4. If it is decided to replace the instrument and to dispose of the radium luminised item, a specialist company must be used for the disposal of radioactive waste. There are only a small number of such companies operating in the UK, these include: Safeguard International Ltd and Active Collection Bureau (01795 437001). There are currently some difficulties over the disposal of radium in the UK and some delay in disposing of the item may be experienced, and it may be necessary to store the items in the meantime.
The Committee on Medical Aspects of Radiation in the Environment (COMARE) was asked last year to provide fresh advice to Government on the risk factors that should be applied to radiation arising from radioactivity within the body. To do this it set up a broad based working group, CERRIE, that was given the remit "To consider the present risk models for radiation and health that apply to exposure to radiation from internal radionuclides in the light of recent studies and any further research that might be needed". The group was announced by Environment Minister Michael Meacher on 31 July 2001 and has now met several times, though the membership was only announced in a PQ on 20 March (15575, Hansard Column 372W), with further information being given in another PQ on 12 April (Hansard Column 654W) - there is also an entry on the COMARE website http://www.comare.org.uk
CERRIE will prepare a report for COMARE in due course, which will be published. COMARE will then advise Ministers on the need for changes to the existing risk models and for further work. CERRIE will have its own website shortly which will include, amongst other things, summary minutes of its meetings.
Professor Dudley Goodhead, MRC Radiation and Genome Stability Unit - Chairman
Mr Richard Bramhall, Low Level Radiation Campaign
Dr Chris Busby, Green Audit
Dr Roger Cox, NRPB
Dr Philip Day, University of Manchester
Professor Sarah Darby, ICRF Cancer Epidemiology Unit, University of Oxford
Dr John Harrison, NRPB
Dr Colin Muirhead, NRPB
Mr Pete Roche, Greenpeace UK
Professor Jack Simmons, University of Westminster
Dr Richard Wakeford, BNFL
Professor Eric Wright, Ninewells Medical School, Dundee.
The Chairman of COMARE, Professor Bryn Bridges, attends as an observer, together with officials from DoH and DEFRA.
HSE has recently signed Memoranda of Understanding with the Environment Agencies to ensure the requirements of the two organisations are not in conflict in nuclear and non-nuclear regulation.
The Environment Agency (EA) and HSE signed, on 23 February 2002, a revised Memorandum of Understanding (MoU) in relation to the regulation of radioactive substances at non-nuclear sites and, on 23 April 2002, a revised MoU on the regulation of safety and the environment on nuclear licensed sites. HSE signed a (new) MoU with the Scottish Environment Protection Agency (SEPA) on 21 March 2002, in relation to the regulation of licensed nuclear sites in Scotland.
This MoU has been revised to take account of the overarching MoU between EA and HSE, which was revised and signed on 10 July 2000, the changes made necessary by the Ionising Radiations Regulations 1999 (IRR99) http://www.legislation.gov.uk/uksi/1999/3232/contents/made and the Department for Environment, Food and Rural Affairs (DEFRA)'s Direction to the Agency in respect of the Basic Safety Standards (BSS) Directive.
Its purpose is to ensure effective co-ordination of the regulation of radioactive substances at non-nuclear sites (ie sites not licensed under the Nuclear Installations Act 1965) and measures to protect people and the environment, which are subject to regulation by EA and HSE. Such co-ordination should minimise duplication of regulatory effort and ensure that neither employers and undertakings holding radioactive substances, nor any other party, are faced with conflicting demands as a consequence of regulation under the IRR99 and the Radioactive Substances Act 1993 (RSA93).
EA and HSE have signed this revised MoU to develop and strengthen their working relationship on the regulation of safety and the environment in relation to nuclear licensed sites. The memorandum gives more detailed effect to the 'Statement of Intent' for the working relationship between EA and HSE on nuclear safety and environmental regulatory issues, which was issued in August 2001 and is available on the Health & Safety Executive's www.hse.gov.uk/aboutus/howwework/framework/regulation-of-non-nuclear-sites.pdf and the Environment Agency's websites.
HSE is responsible for regulating nuclear safety, including the safe management, conditioning and storage of radioactive waste on nuclear licensed sites. EA is responsible for regulating discharges to the environment and the disposal of radioactive waste from nuclear licensed sites. Both organisations aim to deliver effective and efficient regulation of the nuclear industry to maintain and improve the protection of workers, the public and the environment by ensuring that radioactive wastes are appropriately managed in both the short and long term, in accordance with legislation, government policy and international obligations.
The purpose of this new MoU is to set out how the regulatory activities of HSE and SEPA on licensed nuclear sites in Scotland will be co-ordinated. Such co-ordination should improve the effectiveness with which public sector resources are deployed and avoid the difficulties that might otherwise arise. The memorandum relates principally to the regulation of nuclear safety and radioactive waste management in a similar way to the MoU between HSE and EA.
The European Commission has now published proposals for a directive on the control of high activity sealed radioactive sources http://europa.eu/scadplus/leg/en/lvb/l27054.htm DEFRA supported by EA is in the lead for negotiations. The proposals complement the general provisions for control of sources in the BSS Directive (96/29/Euratom). The main features are:
For further information, contact Martin Hum, DEFRA RAS (tel: 0207 944 6248; email: firstname.lastname@example.org) or Bob Russ, EA (tel: 01454 624098; fax: 01454 624032; email:email@example.com).
The draft guidance on Equipment used for medical exposure (HSG 226)
has been distributed for external consultation with a deadline of Tuesday
20 August 2002.
The guidance is intended as a revision of Guidance Note: Fitness of equipment used for medical exposure to ionising radiation (PM77). The advice in this guidance is aimed at employers who have to any extent control of equipment used for medical exposure to ionising radiation, including ancillary equipment. This includes NHS Trusts, health authorities or boards, private hospitals, clinics, surgeries, medical x-ray facilities in industry, dentists, physiotherapists, osteopaths and chiropractors. The guidance should also be useful to radiation protection advisers who have been consulted by such employers.
Advice is given on compliance with the Ionising Radiations Regulations 1999 (IRR99) in relation to equipment used for medical exposure. In particular the guidance provides advice on the requirements of regulation 32(1) IRR99, ie that employers ensure such equipment is of a design or construction and is so installed and maintained as to be capable of restricting so far as is reasonably practicable the exposure to ionising radiation of any person who is undergoing a medical exposure to the extent that it is compatible with the intended clinical purpose or research objective.
Users of digital radiography systems may wish to note that the Medical
Devices Agency Medicines and Healthcare products Regulatory Agency has put the following notice on the web:
'Radiation Dose Issues with Digital Radiography Systems'.
The regulatory requirements for medical exposure to ionising radiation: an employer's overview HSG223 is available from HSE's website
Free information sheets in the Ionising Radiation Protection series:
No. 7 Selection, use and maintenance of portable monitoring instruments www.hse.gov.uk/pubns/irp7.pdf
No. 8 Control of radioactive substances www.hse.gov.uk/pubns/irp8.pdf
This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. Please acknowledge the source as HSE.
Updated on the HSE web site 6th June 2002