(formerly The Radiation Protection Adviser) incorporating ADS News
Welcome to issue 22 of Radiation Protection News incorporating ADS News, which aims to clarify areas of concern and update readers on further developments in the field of ionising radiation. We are again 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 firstname.lastname@example.org or the Ionising Radiation Policy Unit, Health and Safety Executive, Level 6, North Wing, Rose Court, 2 Southwark Bridge, London SE1 9HS
Health and Safety Executive's Ionising Radiation web site is at http://www.hse.gov.uk/hthdir/noframes/iradiat.htm
This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. Please acknowledge the source as HSE.
ADS will wish to note that Dr John Gill has retired as ADS Programme Manager. His replacement is Dr Jo Nettleton, HSE, Room 428,Magdalen House, Stanley Precinct, Bootle, Merseyside L20 3QZ:
Evolution not revolution was HSE's mantra for IRR99 http://www.legislation.gov.uk/uksi/1999/3232/contents/made , always followed by 'but only if you are already complying with IRR85'. Colleagues had reservations that the message, meant as reassurance, would be misinterpreted.
Experience sadly seems to indicate that many people heard the first part but overlooked the second and therefore failed to put the reassurance in context (or perhaps had an inaccurate view of their level of compliance). So, some two and a half years since IRR99 came into force, please note that the mantra has changed to 'The revolution has arrived'.
Employers of companies where the revolution is overdue should therefore think carefully about what IRR99 require and, if in doubt as to what to do, consult a suitable RPA (if the RPA doesnt know what you should do, then s/he is not suitable!). Weaknesses found by inspectors in visits have included:
However, inspectors have also found some good developments, including:
HSE wishes to remind employers who want to be able to keep their RPAs after the end of 2004 to check if those RPAs have yet sought recognition under IRR99. If not, then encourage them to do so well before the end of the transitional period. As the number of HSE-recognised Assessing Bodies http://www.hse.gov.uk/hthdir/noframes/iradiat.htm#5 is currently limited to two RPA 2000 and BNFL (and the latter will only deal with applications from BNFL employees) employers and RPAs should heed the advice below to apply well before the end of 2003, in order to be sure that the procedures can be completed in time. The following article from Cathy Griffiths offers helpful advice in this respect
Despite RPA certification schemes having been around for a while (RPA 2000 since early in 2000 and the BNFL scheme since December 2001), for many prospective applicants, the putting together of a portfolio still appears to be perceived as a really onerous task. The Assessing Bodies http://www.hse.gov.uk/hthdir/noframes/iradiat.htm#5 have tried to provide helpful advice to candidates in the form of guidance notes and look to revise the guidance as necessary as more experience is gained. Individual line managers or work colleagues can assist potential RPA applicants on a day-to-day basis by highlighting pieces of their work that could usefully be copied and stored in a "portfolio box file" as the candidate progresses collection of evidence. The annual performance appraisal of staff could be an opportunity for line managers to review the evidence collected to date and identify any shortfall by reference to the "Core of Knowledge" and "Areas of Competence". This meeting could be used to focus any training needs for the coming year and perhaps influence delegation of specific work tasks in order to broaden the experience of the future RPA applicant. It is never too early to encourage your staff to start collecting evidence!!
For managers of corporate RPA bodies, where individual staff may wish to apply for certification for the first time, there is a need to ensure that the applicant can personally demonstrate the full range of competence required. The applicant needs to be able to demonstrate that his/her skills go beyond going out and making measurements and completing a pro forma, which is then handed over to the RPA to make all the decisions and provide advice. The applicant needs to have portfolio evidence of their own work showing that, as well as making the measurements, they personally contributed to the decision making process, arrived at an appropriate decision and provided advice, even though it will have been discussed and agreed with the RPA.
People who have already gone through the certification process can help their colleagues by communicating any useful tips and experience they found helpful. The guidance notes to the scheme provide a wealth of information and prospective applicants are urged to read them in their entirety. This could save the applicant a lot of time searching for additional evidence and making the portfolio a much weightier application than it needs to be. In many instances a single document/letter could provide evidence over several areas of competence. By way of example, consider a letter written by the RPA to a medical consultant. The letter is in response to an incident whereby a member of his medical team sedated the patient on the ward before obtaining all the information to correctly complete an x-ray request card. The examination was medically urgent and the radiographer proceeded with the examination, even though it was not possible for her to complete the enquiry re: pregnancy. The patient was subsequently able to inform she was eight weeks pregnant. A letter of this kind could conceivably make reference to:-
This letter could possibly provide evidence for-:
Core of knowledge -
- biological effects of radiation
- Quantities and units
- ICRP principles
- regulatory requirements re: pregnancy and exposures
- safety culture
- communication skills
Areas of competence -
- 2.1 (a and b)
- 2.2 (b and c)
- 2.5 (b)
- 2.6 (a)
- 2.7 (a, b, c)
- 2.8 (a and c)
Some applicants still choose to look at each area of competence in isolation and provide three dedicated pieces of evidence rather than see how many areas of competence are covered by a single piece of evidence, as in the example above. This certainly makes the task more onerous than it needs to be for both the applicant and the assessors.
Whilst it is appreciated that people who have only worked in radiation protection for a couple of years may struggle to collect sufficient evidence, for most potential applicants the evidence probably already exists in your filing cabinets or on computer - so what are you waiting for? Give yourself a confidence boost. Take one piece of your work in radiation protection from recent years and complete the sample analysis shown as a worked example above. Then go on to complete the task, write the cheque and get the portfolio in!!
If you delay you may not gain certification by 1st January 2005 and will not be allowed to work as an RPA. You could be putting your livelihood at risk! The Association of University Radiation Protection Officers (AURPO) is starting a one year training scheme in November 2002 and 40 candidates potentially may be registered, thus 40 applications to RPA 2000 may be submitted in winter 2003. Given that RPA 2000 assessors work on a voluntary basis, you really need to have your application in to RPA 2000 and processed before November 2003 if you want to be sure of being certificated in good time. The workload of 40 applications from the AURPO scheme could swamp assessors for months to come. Don’t delay – progress that portfolio NOW.
I agree wholeheartedly with Kevin Connor's view (see Issue 21 May 2002) that we really need to teach people radiation protection, something NRPB https://www.gov.uk/radiation-products-and-services has been involved in since the early ‘70s and is just as committed to today. There are of course a number of ways in which this can be achieved. Distance learning courses, in some working environments, would be an appropriate training solution but, where practicable, there is value in removing individuals from the distractions of the workplace and facilitating interaction between like minded individuals.
When the opportunity came to re-shape NRPBs training at the professional level, we developed a series of short modestly priced courses to provide initial training of RP professionals (the Core of Knowledge Module of the Radiological Protection Training Scheme (RPTS)), not aimed at any particular business sector but focussed very much on the needs of the radiation protection adviser (RPA). Collectively, these courses aim to cover the technical content of the HSE Basic Syllabus for RPAs.
The Core of Knowledge Module currently consists of: Foundation in Radiological Protection; UK Legislation and International Recommendations; Principles of Protection Against External Radiation Sources; Principles of Protection Against Internal Radiation Sources; and Radiation Emergencies - Planning and Response. These courses range between three and four and a half days in duration, and contain a significant element of syndicate exercise/practical work to reinforce the taught material. The Foundation course is being developed to further introduce the topics of radioactive waste and radon, and the Scheme as a whole has now been extended to include training in specialist areas outside the remit of RPA certification. A course on the Management of Radioactive Waste has recently been delivered, and work is in hand to provide a course next year on the selection and use of radiological protection instrumentation.
The Update course provides an opportunity for more senior professionals to hear about, and to discuss, the latest developments in radiological protection, whilst work is progressing on the provision of a short course aimed at refreshing the knowledge of RPAs. Both of these courses contribute to continuing professional development.
The standard of assessments used on NRPB's RPTS courses has evolved through experience gained in setting examinations for the Postgraduate Radiological Protection Course (PGRP) within the validation framework of the University of Surrey, together with its own experience of providing RPA consultancy services. However, there is a requirement to ensure consistency of such standards between suppliers, and a recognition of that standard by certification assessors. This issue is one that we are currently addressing.
Issue 21 of RP News announced approval of the revised Level 4 NVQ in Radiation Protection. To make it properly available as a genuine alternative route to RPA recognition, an Awarding Body, Assessment Centre(s) and Internal and External Verifiers (verifiers will need to take the appropriate NVQ) are needed. City and Guilds may be willing to be an Awarding Body if other organisations/people offer to fill the other roles. SRPs Qualifications and Professional Standards Committee is willing to help facilitate establish the system by acting as a point of contact the Hon. Secretary of QPSC is Tony Hudson (email him at: email@example.com)
The recent survey report on the QE and Education and Training in Radiation Protection, carried out by NRG under contract to the EC, has shown that harmonisation of the approach to recognition of qualified experts in EU Member States and Applicant Countries remains some distance away, as there is still a wide variety of systems. Nevertheless, the UK (HSE) and the Netherlands have agreed to start bilateral discussions to see whether some form of mutual recognition between the two countries can be achieved, and perhaps even provide a possible blueprint for making progress with other countries. Watch this space and wish us luck!
If a classified worker is also a frequent flier the dose incurred when flying on company business should not be added to the record kept under IRR99 as (i) IRR99 do not apply to doses on aircraft; and (ii) for the purpose of travelling on the plane they are a passenger and therefore a member of the public. As a matter of practice and caution, however, it may well be advisable for employers to keep a separate record of the doses from cosmic exposure and doses received abroad.
The Packaging, Labelling and Carriage of Radioactive Material by Rail Regulations 2002 (RAMRAIL 2002) http://www.legislation.gov.uk/uksi/2002/2099/contents/made came into force on 2 September 2002.
Schedule 4 of the Regulations contains amendments to REPPIR. http://www.legislation.gov.uk/uksi/2001/2975/contents/made The key changes are:
REPPIR = RADIATION (EMERGENCY PREPAREDNESS AND PUBLIC INFORMATION) REGULATIONS http://www.legislation.gov.uk/uksi/2001/2975/contents/made
Part 1 of Schedule 2 to REPPIR sets out the threshold quantities of radionuclides for application of the Regulations at premises and provides for the Executive to approve another quantity for any radionuclide not specified.
On 30 May 2002 HSE issued Approval No. AP1 that approved the following quantities for the purpose of Part 1 of Schedule 2:
7 1013 Bq
1 1014 Bq
2 1013 Bq
5 1012 Bq
1 1013 Bq
ADS are necessary for regulation 14 of REPPIR which deals with the assessment and recording of exposure of certain employees to ionising radiation during a radiation emergency.
HSE already recovers a fee for ADS approval for IRR99 purposes through the annual Fees Regulations, and has done since 1986. The Fees Regulations now need to be amended to include provision for a fee to be charged for REPPIR ADS approvals.
The Approved Dosimetry Services are being consulted and have been asked to provide comments on proposals for a fee structure for REPPIR.
For further information contact Dr J Nettleton either by e-mail to: firstname.lastname@example.org or write to:
Technology Division 4
Health and Safety Executive
Room 428 Magdalen House
Merseyside L20 3QZ
The REPPIR website has been considerably extended to provide more information about the Regulations and latest developments. Log on at: http://www.hse.gov.uk/radiation/ionising/reppir.htm
It has been drawn to our attention that there is a discrepancy between the Schedule 8 col 5 figures for tritiated compounds in the printed Regulations/L121 and the internet version (1010 in Regs/L121 and 1012 on internet). The correct value is 1010. We apologise for the confusion and will be seeking amendment of the internet version
We have been asked whether termination records are required where a parent company splits into two, or where a company changes its name. The following guidance may clarify the position.
Where a company simply changes its name, no termination records are required. However, where there is a change in a legal entity that employs staff (e.g. when a company splits into two, or part of a government department is privatised) then termination records are necessary.
Recent legal developments that may have implications for dose records for classified persons who have undergone gender reassignment
Employers and ADS will wish to be aware that there have been new legal developments that may have implications for the making and maintenance of dose records for classified persons who have undergone gender reassignment. On 11th July 2002, the European Court of Human Rights (ECtHR) found unanimously in favour of two transsexual women against the UK Government (Goodwin v UK and 'I' v UK). The ECtHR found that failure to change records, including birth certificate and national insurance number, resulted in a breach of transsexuals right to respect for private life under Article 8 of the European Convention on Human Rights. The Court also found that failure to change records resulted in a breach of transsexuals right to marry under Article 12.
Employers and ADS are therefore advised to seek legal advice to ensure that their arrangements for the making and maintenance of dose records belonging to classified persons who have undergone gender reassignment are consistent with the ECtHR judgements outlined above.
Martin Hum, DEFRA RAS http://www.defra.gov.uk/ has provided the following progress report on negotiation of the proposed directive to improve control of high activity sealed sources. (http://europa.eu.int/eur-lex/en/com/pdf/2002/en_502PC0130.pdf)
Negotiations on the proposed directive are continuing in the Councils Atomic Questions Working Group (AQG). Points to note are:
The procedures under the Euratom Treaty require the European Commission to consult the European Parliament and the Economic and Social Committee (ECOSOC, sometimes also known as ESC); ECOSOC comprises representatives of the social partners, i.e. employers, workers and special interest groups. Often this consultation happens in parallel with negotiations in AQG. In this instance, it will result in the Commission bringing forward (and publishing) a revised text that takes account of the comments it has received from ECOSOC but does not reflect the discussions in AQG., This revised text was awaited at the time of writing and will be subject to further negotiation.
For further information, contact Martin Hum, DEFRA RAS (tel: 0207 944 6248;
email: email@example.com) or Bob Russ, EA (tel: 01454 624098; fax: 01454 624032; email:firstname.lastname@example.org).
The British Vetinary Association (BVA) http://www.bva.co.uk/ has published a new guide of best practice for the use of ionising radiations. The Guidance Notes for the Safe use of Ionising Radiations in Veterinary Practice is a basic, easy to use, guide written by veterinary surgeons who are radiation protection advisers and is supported by the Health and Safety Executive and the National Radiological Protection Board.
The guidance has been produced with general veterinary practice in mind and will assist all members of staff to appreciate basic best practice in radiation safety. The guidance compliments the HSCs own Approved Code of Practice and guidance (L121) providing essential reference to IRR99 as they apply specifically to veterinary surgeons.
The chapter on radiopharmaceuticals covers the increasing use of radioactive substances such as Iodine 131 and technetium 99m in veterinary practice. Included in the guidance for easy reference are checklists such as when to consult an RPA, preparing local rules, setting up X-ray facilities and domiciliary radiography.
Copies of the guidance can be ordered from the BVA Postal Bookshop tel: 01732 886422: fax; 01732 886686: email; email@example.com. The price is £10.00 for BVA members and £17.50 for non-members and includes postage and packing.
The Association of University Radiation Protection Officers (AURPO) have published AURPO Guidance Notes on Working with Ionising Radiations in Research and Teaching. The notes are intended as an aid to radiation protection officers and others with responsibilities for radiation protection in a University or biomedical research environment.
The AURPO Guidance Notes, which were prepared by the AURPO Technical Committee with assistance and guidance from HSE can be found on the AURPO website. AURPO intend to review and update the document on a regular basis.
The following guidance from HSE expands on that in the AURPO document in relation to supervision in unsealed source laboratories.
Adequate supervision must be provided in laboratories where radioactive sources are used, to ensure local rules are followed and that exposures are thus reduced to a level which is as low as is reasonably practicable and to limit so far as is reasonably practicable the frequency and consequences of incidents such as loss of radioactive sources.
In a department where laboratories are located close together and where work undertaken in a number laboratories is similar, to determine the appropriate number of RPSs to achieve adequate supervision it may be appropriate to use a ratio of numbers of employees to appointed RPS. A ratio of approximately 20:1 will provide suitable levels of supervision in a typical university department.
In situations where either the work being undertaken in different laboratories varies significantly, or there is a high turn over of workers (such as PhD or medical students) or where some laboratories are geographically remote, the use of a simple ratio would not be appropriate. For example, the controls in place for a hot laboratory or source store (probably controlled areas used by a number of research groups) are likely to be significantly different than for a supervised laboratory (used by only one research group) where small amounts of radionuclides are used for tracer work. In this situation, the arrangements for supervision in laboratories are likely to differ (one RPS may well be appointed just for the hot laboratory or source store and another for nearby supervised areas). Similarly laboratories that are geographically remote may necessitate appointment of further RPSs.
Where employees (and students) work in a number of laboratories (for example a source store, hot laboratory and tracer laboratory), it is important that they are familiar with and follow all relevant local rules and are adequately supervised.
In all situations, HSE sees it as important that RPSs should be in a position to ensure that the local rules are being followed. This means that they should command sufficient respect from those undertaking the work and, on occasion, check compliance.
The deadline for comment on the draft guidance on Equipment used for medical exposure (HSG 226,) distributed for external consultation and also made available on the internet, was Tuesday 20 August 2002 (issue 21 of this newsletter also offered readers the opportunity to comment). We would like to express our thanks to everyone who responded. The feedback has proved extremely useful.
We will shortly be distributing, on a reduced consultation list, a revised draft for comment. We will be making the revised draft available on the internet at http://www.hse.gov.uk/hthdir/noframes/iradiat.htm and would welcome your comments. Until then, the original draft can still be seen on our website at http://www.hse.gov.uk/hthdir/noframes/pm77draft.pdf
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 RPAS who have been consulted by such employers.
Advice is given on compliance with IRR99 in relation to equipment used for medical exposure. In particular the document provides advice on the requirements of regulation 32(1) IRR99, i.e. 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.
(reproduced from Toxic Substances Bulletin Issue 48)
HSE publishes enough of it so it would seem reasonable that we should know the status of our guidance. And we do. But do others in the health and safety system know the difference between material that is contained in an Approved Code of Practice (ACOP), and that which is guidance?
If you do, then fine, but if, like a lot of people, you are not sure then this article might help you.
HSE operates under the law: principally the Health and Safety at Work etc Act 1974 (HSWA), which is based on 'reasonable practicability'. HSWA and associated regulations frequently set goals. ACOPs and guidance can advise on meeting such goals.
ACOPs have a special legal status in criminal proceedings. They can be used in a court of law. They are admissible in evidence and, when the Code is relevant to the offence but not observed, the defendant must show that the law has been complied with in some other way.
Guidance - advice on how to keep the law - lacks this special status, but it will seek to illustrate practices which will help to secure legal compliance. In some instances it may help employers who strive towards a standard better than the legal minimum and where it does this it should be clear that this is the expectation.
Often, published material will include the law (specific regulations); an explanation of what this law means or requires; ACOP setting out preferred, specific duties to ensure compliance; and some guidance advising on ways to secure legal compliance.
In practice, guidance is likely to be doing one or more of the following:
Free information sheet in the Ionising Radiation Protection series:
No.3 Portable nuclear moisture/density gauges in the construction industry www.hse.gov.uk/pubns/iris3.pdf
Portable nuclear moisture/density gauges are commonly used during road building or repair projects to check surface density, thickness and the moisture content. The information sheet gives advice on the use, keeping transportation and disposal of these gauges, to limit the exposure to workers and members of the public to ionising radiation.
Readers are asked to note that, since this leaflet went to press, the Radioactive Materials (Road Transport)(Great Britain) Regulations 1996 have been replaced by the Radioactive Material (Road Transport) Regulations 2002: http://www.legislation.gov.uk/uksi/2002/1093/contents/made
Statutory Instrument 2002 No. 655 - The Health and Safety (Fees) Regulations 2002 http://www.legislation.gov.uk/uksi/2002/655/contents/made
Statutory Instrument 2002 No. 1093 -The Radioactive Material (Road Transport)
Statutory Instrument 2002 No. 1092 - The Radioactive Material (Road
Transport) (Definition of Radioactive Material) Order 2002
Statutory Instrument 2002 No. 282 - The Health and Safety at Work etc. Act
1974 (Application to Environmentally Hazardous Substances) Regulations 2002
Statutory Instrument 2002 No. 2099 -The Packaging, Labelling and Carriage
of Radioactive Material by Rail Regulations 2002
Statutory Instrument 2002 No. 618 - The Medical Devices Regulations
Statutory Instrument 2002 No. 1177 - The Radioactive Substances (Natural
Gas) Exemption Order 2002
Statutory Instrument 2002 No. 2533 The Atomic Energy (Americium) Order
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 21 November 2002