(formerly The Radiation Protection Adviser) incorporating ADS News
Welcome to issue 26 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.
Please send any comments, queries and contributions to Ionising Radiation Policy, Health and Safety Executive, Level 6, North Wing, Rose Court, 2 Southwark Bridge, London SE1 9HS
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Schedule 8 of IRR99 contains a list of about 800 radionuclides and column 5 of Schedule 8 contains values for reporting the loss or theft of a quantity of radioactivity for all of these radionuclides except for 30 radionuclides representing the gaseous isotopes of Nitrogen, Oxygen, Neon, Argon, Krypton and Xenon.
HSE commissioned the NRPB to identify, through scientific modelling, the
missing reporting values for the above radionuclides. This work has now been
completed. HSE will therefore add these values to column 5 of Schedule 8 by
means of Executive approval. A certificate of approval containing the missing
reporting values will be posted on HSE’s ionising radiation website
by the end of this year.
In accordance with the provisions of Annex 1, Part II, of the HSE Statement on radiation protection advisers HSE has recently recognised the following as an RPA Body under the Ionising Radiations Regulations 1999:North Western Medical Physics
HSE will be changing, with immediate effect, paragraph 10(a), Part II, Annex 1 and paragraph 1(a), Annex 2 of the HSE Statement. The change relates to the first criterion for both RPA Bodies and Assessing Bodies, which currently states that the Body ‘is constituted as, or comprises an identifiable part of, a legal entity which is capable of being recognised and is responsible for any liabilities that may arise from its work…’
Paragraph 10(a), Part II, Annex 1 and paragraph 1(a), Annex 2 will now read as follows: ‘is constituted as, or comprises and identifiable part of, a legal entity or partnership or other grouping that is capable of being recognised.’
It was always HSE’s intention that Assessing Bodies and RPA Bodies could be either a company, partnership or statutory body and this is reflected in HSE’s guidance on the requirements for Assessing Bodies and RPA Bodies. But HSE recently received legal advice that a partnership is not a legal entity, the term used in the Statement. An immediate change to the Statement is therefore necessary. This change will allow partnerships and other groupings that are not legal entities to apply for recognition as RPA Bodies and Assessing Bodies.
The previous wording ‘is responsible for any liabilities that may arise from its work’ has also been removed as it is unnecessary: responsibility for any liabilities is a contractual matter between an RPA Body/Assessing Body and its clients/applicants. Such contractual issues are not a matter for HSE.
The above changes have immediate effect and restore the situation to that previously intended and agreed with stakeholders.
A new Statement has been signed and will shortly replace the statement to be seen on the HSE website.
In the last issue we said that HSE was starting work on a review of the HSE Statement on radiation protection advisers. The main objectives of the review will be to:
The result should be a revised, and simplified, Statement that takes due account of Stakeholder input.
HSE will be consulting widely on any proposals to change the Statement. It is planned to publish our proposals in early 2005. They will be made available on HSE’s ionising radiation webpage inviting comments from all with an interest.
If you have not already done so, and want to ensure that you are consulted, please send your name, address and e-mail details to: firstname.lastname@example.org.
The Forum held its second meeting on 13 October 2004. Items considered included the ICRP’s draft recommendations, radon in the workplace, compliance with health and safety legislation, and the publication of HSE guidance documents. The opportunity was also provided for all members to provide updates on recent and future developments.
The Forum also considered the future basis of its membership in the light of requests for other bodies to be represented. It acknowledged that there could be benefits from holding its future meetings on a more open basis, whilst retaining its core membership as presently constituted. Those with an interest in attending the next meeting of the Forum (likely to be in October 2005) are invited to inform the Secretariat. Dependent upon the numbers, a decision will then be made on how the next meeting will operate.
Following the issues identified in the Radiation Protection News article of May 2003 (Security of radiation generators in hospital nuclear medicine departments), HSE organised a meeting, in November 2003, to bring together relevant Government bodies, suppliers, and representatives from the appropriate professional bodies. The meeting proved to be a very constructive vehicle for agreeing on practical ways of improving handling arrangements at hospitals when radioactive products are delivered or collected. Whilst recognising that there could not be one common procedure appropriate to all NHS Trusts, it was agreed that all Trusts must have in place adequate procedures addressing security and accountability issues for the receipt and despatch of radioactive materials. The widespread use of the different arrangements previously identified as not complying with the requirements of the Ionising Radiations Regulations 1999 and the Radioactive Substances Act 1993 could not continue.
It was agreed that guidance covering acceptable practices for different situations that could arise would be useful. The professional bodies agreed to prepare this guidance.
HSE, following consultation with relevant government bodies, has commented on the proposed guidance and welcomes its appearance. The guidance is shortly to be published by the British Nuclear Medicine Society on behalf of the professional bodies in their journal Nuclear Medicine Communications and also placed on the BNMS website.
It is, of course, the employer’s responsibility to ensure that adequate arrangements are in place for the delivery and collection of such products on their premises, and that these arrangements comply with the Ionising Radiations Regulations 1999 and the Radioactive Substances Act 1993. HSE is aware that some of the practices described in the May 2003 article continue in some Trusts. HSE and the Environment Agency will take appropriate enforcement action where such cases come to their attention. Employers should discuss their arrangements with their RPA if they need advice on their particular situation. If RPAs and employers require further clarification they should contact an HSE Radiation Specialist Inspector.
Published on the HSE web site 24 November 2004