(formerly The Radiation Protection Adviser) incorporating ADS News
Welcome to issue 24 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.
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HSE is currently developing a small package of amendments to IRR99. These should include the following requirements:
In addition HSE is commissioning work to add the missing reference figures in column 5 of Schedule 8 for the activity of certain radioactive material which, if lost or stolen by/from a radiation employer, should be notified to HSE.
It is planned to publish a Consultative Document setting out the proposals and inviting comments in the first half of 2004.
RPA 2000, the constituent Societies and HSE have been pointing out to potential RPAs that outstanding applications for certification under IRR99 should be submitted to RPA 2000 by early in the year 2004, at the latest. This is to avoid an unmanageable surge in applications during the latter part of the year. The Management Board of RPA 2000 has decided to make the following conditions clear to all persons who expect to apply for certification before the end of December 2004:
Persons applying for certification, and whose applications are received by RPA 2000 after 31 March 2004, will be required to sign an acknowledgement of their acceptance of the above conditions. This acknowledgement will include their acceptance of the fact that they cannot hold RPA 2000 responsible if the processing of their application is unable to be completed until some time after 1 January 2005. In the absence of this acknowledgement, the application for certification will not be accepted by RPA 2000.
* An ‘adequately prepared application’ is one that:
A recent study reported in the British Medical Journal (BMJ) concluded that doctors’ knowledge of radiation doses to patients in radiological investigations remains poor. In a study of 130 doctors at two hospitals in Oxford and South Wales, none of them knew the approximate dose of ionising radiation (IR) received by a patient during a chest X Ray (0.02mSv), or even the units of radiation measurement used, though ten were consultant radiologists.
The doctors were asked to estimate doses of IR for other investigations relative to that for a chest X Ray (CXR) e.g. a plain abdominal X Ray exposes the patient to 75 times the dose in a CXR, a CT scan of the abdomen is equivalent to 400 CXRs whilst a lumbar spine X Ray is equivalent to 120 CXRs and so on. Five doctors (4%) gave no correct answers, six (5%) did not realise that ultrasound does not use IR and eleven (8%) did not know MRI does not involve IR. Overall, 97% of the answers were underestimates of the actual dose e.g. a patient undergoing an arteriogram of the leg would receive 400 times the radiation of a CXR but the average mean answer was 26 times.
The paper points out that an estimated 100 to 250 deaths occur each year from cancers directly related to medical exposure to IR.
Reference: Shiralkar S, Rennie A et al. Doctors’ knowledge of radiation exposure: questionnaire study. BMJ 2003;327:371.
Recent inspection activity by HSE Specialist Inspectors (Radiation) in NHS Trusts has revealed some confusion surrounding the duties, role and function of Radiation Protection Supervisors in hospitals etc.
Under the IRR99 it is quite clear that the ‘Radiation Employer’ is the principal duty holder. In many cases this has not been reflected by NHS Trusts in that too much responsibility has been placed upon Radiation Protection Supervisors (RPS) (ref. Regulation 17(4) of the IRR99).
The duty of the RPS is to supervise the work so that it is done in accordance with local rules drawn up under Regulation 17(1) of the IRR99. In some Trusts and hospitals the RPS does not supervise work and is not given sufficient management authority to supervise all those engaged in work with ionising radiations. In other places there are insufficient RPSs to properly supervise work with radiation. Many RPSs also have been allocated duties/responsibilities which would more properly rest with the relevant Heads of Departments or local managers. In the case of staff who are both RPS and Head of Department it must be made clear when they are acting in which capacity (for example when attending the Trust Radiation Protection Committee).
Some of the confusion surrounding the role of an RPS may stem from the requirements of the IRR99 and the guidance contained in the Medical and Dental Guidance Notes. Whilst Appendix 3 of the latter offers some advice on what ‘functions’ may be allocated to an RPS it is important to remember that responsibility for compliance with the IRR99 rests with the Radiation Employer. Therefore the existence of RPSs does not mean that management no longer have to manage radiation protection or supervise work. When carrying out inspections HSE expects to find that any documentation relating to the role of the RPS should be clear as to their duties under the IRR99 and their management functions. In addition any such documentation should not confuse the role of an RPS with the employer’s responsibilities under IRR99. HSE would expect any such documentation to be concise.
The checklist at Appendix 3 of the MDGN does not always distinguish sufficiently between these two different but complementary roles. Appendix 3 lists 21 general functions that are relevant to an RPS’s role. It is clear that 11-13, 15, 16, and 21 are not for the RPS to carry out. While all the others may well be functions that the RPS might carry out, HSE inspectors would only see 1 as being the appropriate duty of the RPS as required by IRR99.
An example of where confusion may arise is after for example a radiation accident. In many cases we have seen procedures and plans where the accident has to be reported only to the RPS. It is then the RPS who carries out an investigation and liaises with the Radiation Protection Adviser (RPA) over remedial action etc. At no time in this scenario is the radiation employer or local management involved and this is clearly wrong.
Some key points which may help to remove possible confusion are as follows:
HSE’s has updated its internal guidance to inspectors on how to ensure that employers are complying with the Ionising Radiations Regulations 1999 (IRR99) with respect to outside workers. Part of that guidance is reproduced here. This is based on guidance originally published in the Approved Code of Practice to the Ionising Radiations (Outside Workers) Regulations 1993, the provisions of which were superseded by the IRR99.
NOTE: For the purpose of this guidance and to increase clarity, the following terms are used:
These terms are not used in IRR99 and therefore have no legal standing, nor will they be found elsewhere, e.g. L121.
When an outside worker (OW) arrives at the IE’s site and hands over their passbook for checking the name and address of the IE should be entered. This will ensure that a space for, the dose estimate is clearly identified in the event that the estimate cannot be entered when the OW leaves the site at the end of the activities (or earlier, if they are interrupted before completion).
It will generally be relatively simple to estimate doses of external radiation received, by means of direct-read or locally-read dosemeters. For internal exposure, the use of area or workplace measurements may be appropriate in some circumstances; such measurements should be made in consultation with the radiation protection adviser and should be backed up by comparison with doses received by any other workers wearing personal dosemeters or personal air samplers.
Because the estimated dose needs to be ready for insertion in the passbook as soon as the work has been completed, to avoid unduly delaying the OW’s departure, quality of information may be less important than immediacy. The estimation of internal dose may require more time and it may not be possible to make an entry immediately on completion. In such cases the estimate, which may be based on air sampling results or even time of occupancy and knowledge of general levels of airborne activity, should be sent to the DE as soon as practicable.
As a general rule, dose estimates will be needed in any situation that would require the dose received by any classified persons employed by the IE to be assessed under IRR99. This would include estimates of, for example, extremity dose or dose to the lens of the eye in certain cases. When devising methods of dose estimation, IEs are recommended to consult their radiation protection adviser and, where appropriate, the DE.
Factors that operators may wish to bear in mind when considering any training needs for employees who are authorised to make dose estimates may include:
IEs generally only need to provide quick, simple, dose estimates. A quick estimate that tends to overstate the dose is preferable to a more accurate estimate that cannot be made for several weeks. The accuracy of the estimate and complexity of the means of making it should be commensurate with the size of the expected dose: gross overestimates may result in unnecessary restrictions being placed on workers. The period covered by the dose estimates will commonly be different from the dose assessment period. The dose assessment will provide the more accurate picture of the personal dose received over a month or a year.
In many circumstances, personally worn direct-reading dosemeters will offer the most practicable means of providing a quick estimate of whole-body dose from external radiation. External whole-body dose can also be estimated from environmental monitoring or past records, for example:
However, it may not be possible to estimate some doses, e.g. to the lens of the eye or to the skin of the hand, using a single dosemeter. In these circumstances a separate dose estimation will be needed. Methods of extremity dose estimation include us of:
A personal (or, where appropriate, a static) air sampler can give a relatively quick indication of whether intake has occurred. Similarly where work involving potentially volatile iodine is undertaken, direct internal monitoring of the thyroid using a suitably calibrated scintillation detector can give an estimate of intake. An indication of a positive intake may require additional biological monitoring, which may take some time.
The following methods may be used for estimating internal exposure (the list is not exhaustive):
If the dose estimate is below the minimum level detectable by the measurement method being used, the estimate may be entered as ‘<N’, where N is the value of the minimum detectable dose in mSv. This may be useful where personal air samplers are used as confirmation that inhaled radioactive contamination is below specified levels.
Occasionally an OW may receive, or be thought to have received, a dose from a contamination incident. This may result from:
In these circumstances it is unlikely that an initial estimation of dose will be possible. Normally an assessed dose would be credited to the dose record of the affected person following an investigation. In this situation, a note in the dose estimate section of the OW’s passbook should record that an investigation is in progress, naming the IE and ADS involved.
Radon is a major source of ionising radiation exposure to the UK workforce. The risk posed to life from excessive radon exposure at work is significant and may cause or aggravate up to 280 lung cancers per year.
HSE’s has updated its internal guidance to inspectors on how to ensure that employers are complying with the Ionising Radiations Regulations 1999 (IRR99) with respect to radon in the workplace. The guidance gives the information needed to ensure employers take effective action in radon affected areas during their routine health and safety inspections. It is also being made available to Local Authority inspectors in the Local Authority Circular series.
Over 100 inspections were recently undertaken in radon affected areas by Radiation Specialist Inspectors to ensure that the advice in the guidance was both practicable and enforceable in the Courts. The common response from employers was that although aware of domestic radon, they didn’t think it was a workplace issue, but were very willing to take action when the matter was brought to their attention.
Most workplaces that have carried out a suitable and sufficient risk assessment find that they do not have a radon problem. Employers who do have high levels find that by drawing on the expertise of enforcement agencies, radiation protection advisers, and remediation consultants, practical and effective solutions can usually be found without excessive cost.
IRR99 applies to work ‘carried out in an atmosphere containing radon 222 gas at a concentration in air, averaged over 24 hour period, exceeding 400 Bqm-3’ and it is estimated there are 16,000 workplaces located in Affected Areas of Great Britain with radon levels in excess of this action level.
The Health and Safety at Work etc. Act 1974 requires all employers to ensure the health and safety of their employees and others who have access to the work environment. The Management of Health and Safety at Work Regulations 1999 require that employers assess all relevant risks to employees. Employers with premises in affected areas should therefore carry out a risk assessment to determine whether or not the premises have radon levels above the action level.
This assessment should be recorded and factors to be considered include construction and ventilation of all parts of the premises and the likelihood (as identified by NRPB maps) of having high radon levels. The assessment is likely to include a number of measurements around the premises.
Where levels exceed the action level, remedial actions should be taken to try and reduce them to below the action level. This can usually be achieved using relatively simple and inexpensive engineering methods. If such measures do not reduce the levels sufficiently (i.e. to below 400 Bqm-3), then IRR99 apply as for any other occupational exposure to ionising radiation. In this case a Radiation Protection Adviser must be consulted and additional measures such as occupancy controls may be implemented in order to restrict employee exposures so far as reasonably practicable.
In 1990, the House of Commons Select Committee on the Environment specifically recommended, "those who are found to be exposed to high levels of radon at work are specifically targeted and advised to have surveys at home." To achieve this during recent inspections, inspectors have also made contact with employee representatives to encourage the performance of radon measurements at employee’s homes.
HSE "Radon in the workplace " IND(G)210L (withdrawn March 2006) and joint HSE/Building Research Establishment guidance on remedial actions employers may take, BR 293, "Radon in the Workplace" [ISBN 1 86081 040 3] are available from HSE (Tel: 01787 881165) and BRE (Tel: 01923 664444) respectively.
A revised version of the guidance on the criteria of competence for RPA bodies will soon be made available on the web at http://www.hse.gov.uk/radiation/ionising/rpa/rpa.htm. Though it is presented differently, in terms of content, there is virtually no change from the current version.
Outstanding applications for recognition by HSE as an RPA Body should be submitted to HSE by early 2004, at the latest. This is to avoid an unmanageable surge in applications during the latter part of the year.
All applications for recognition by HSE as an RPA Body should be sent to: Peter Storey, Head of Research & Radiation Unit, NSD 4A, Health and Safety Executive, Room 313, St Peter's House, Stanley Precinct, Bootle L20 3JZ.
HSE will complete the processing of all adequately prepared applications* that are received by 31 March 2004.
HSE expects to complete the processing of all adequately prepared applications* that are received by it on or before 30 June 2004 but is not prepared to guarantee this if excessive demand precludes such an outcome.
HSE gives no assurances as to when it would be able to complete the processing of adequately prepared applications* that are received after 30 June 2004.
*An adequately prepared application is one that includes sufficient evidence to enable the HSE Recognition Panel to complete the assessment without further reference to the applicant for additional information (see guidance on the criteria of competence for RPA bodies at http://www.hse.gov.uk/radiation/ionising/rpa/rpa.htm.
This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. Please acknowledge the source as HSE.
Published on the HSE web site 26 November 2003