Welcome to the third issue of the newsletter, which now has a circulation of over 1500 individuals outside HSE. Once again we are covering a variety of topics of interest to RPAs.
This issue contains articles about legislation to implement European Directives; Corporate RPAs; advice from the Ionising Radiations Special Entries Committee; a summary of a United States Safety Notice on radiation shine paths from radioactive cells; and details of IAEA Safety Series 107 on radiation safety of gamma and electron irradiation facilities.
We experienced difficulties with the distribution of the second issue of the Radiation Protection Adviser. We apologise to those of you who received your copy late.
Reference in this newsletter to 'IRR 85' or 'ACOP parts 1, 2, 3 and 4' are references to the Ionising Radiations Regulations 1985 and the four parts of the Approved Code of Practice supporting the Regulations.
We would like the newsletter to represent views from both HSE and RPAs and therefore would welcome your thoughts on the newsletter, the material in it, and suggestions for future articles. In particular we would like to make 'lessons learnt' articles a regular feature of the newsletter and would welcome material from you.
Any articles based on information supplied to the newsletter will exclude details which might identify the contributor or his/her employer; draft articles will be cleared with the contributor before publication.
Please send your comments, queries and mailing list details to:
Health and Safety Executive,
2 Southwark Bridge,
London SE1 9HS.
IRR85 recognises that in some large organisations where there is specialisation in particular aspects of radiation protection by certain staff not all the attributes and qualities of the RPA (as described in paragraph 75 of ACOP Part 1) will reside in one individual. However, collectively the organisation will have all the necessary qualities and experience. HSE accepts that such an organisation, or a part of it, can be appointed as a corporate RPA.
If an employer intends to appoint a corporate RPA to meet the requirements of regulation 10 or IRR 85, a full description of the structure and organisation of the corporate body that constitutes the RPA should be made available to HSE. This will enable HSE inspectors to be assured that the right advice/adviser will be directed to any particular problem.
For each intended appointment of the corporate RPA it should be possible to show that the individual members of that body have between them the qualifications and attributes that are required for an individual RPA (ACOP Part 1 paragraph 70). This can be achieved by the corporate RPA supplying the relevant HSE office with CVs for each officer concerned, spelling out the scope of each officer's advice and setting out clear arrangements for communication between the officers on particular issues concerning radiation protection.
Recent experience has highlighted potential difficulties for employers when their Approved Dosimetry Service (ADS) makes assessments of internal doses from intakes of long lived radionuclides.
There may be circumstances in which air monitoring data or urine analysis suggests that an individual has received a significant intake of a radionuclide as a result of an incident or occurrence. Consequently, the ADS would wish to undertake a programme of biological sampling. The outcome of the investigation may not be available for six months or more in some circumstances.
In such cases, unless it can be shown beyond reasonable doubt by a prompt examination of the facts that no over-exposure would have occurred, the employer must notify HSE forthwith in accordance with regulation 29(1). This gives HSE the opportunity to influence, for example, the composition of the group that will carry out the subsequent investigation under regulation 29 and its terms of reference, if it so wishes.
RPAs should be aware that a recent successful prosecution was taken by HSE against an employer under regulation 29 for a failure to report an over-exposure after six weeks had elapsed since the incident. In this case 'forthwith' was interpreted by the court to mean 'as soon as possible'.
Where it is clear that a dosemeter has received a large dose of ionising radiations when not worn (eg, when it has been accidentally dropped in a radiography enclosure), the employer should not return it to the ADS in the usual way to avoid an incorrect dose being entered into the employee's dose record. Instead, the employer should make an investigation under regulation 13(7) with the RPA to estimate the employee's dose during the relevant period and then arrange for the ADS to enter this estimated dose into that person's dose record.
If the employer needs to know what dose was recorded by the dosemeter for the purposes of the investigation, the procedure outlined in appendix 3 of the Requirements for the approval of dosimetry services under the IRR 85 Part 1 should be followed.
Ionising Radiations (Outside Workers) Regulations
HSC issued a Consultative Document (CD) in February 1992 on proposed Regulations to implement the Outside Workers Directive (90/6411 Euratom). The proposed Regulations, which will cover classified workers working in controlled areas away from their employer's premises, have been amended in the light of responses received to the CD and should be presented to the Health and Safety Commission early in 1993.
Basic Safety Standards Directive
A proposal for revision of the EURATOM Basic Safety Standards Directive, on which IRR 85 are based, are now expected shortly to be submitted to the European Council. Preparatory work done during 1992 to identify the issues involved has helped us to set out the likely UK line for negotiations; these still remain our negotiating objectives.
IAEA Basic Safety Standards
Revision of the IAEA Basic Safety Standards, also the subject of meetings and discussions in 1992, is progressing; the timescale for this will be somewhat longer than originally planned in view of the strength of some of the comments on the draft and the need to reach a consensus in all of the areas covered.
The European Commission has proposed a Council Regulation on the shipment of radioactive substances within the Community. Unlike a Directive where the Member State has to make domestic legislation to implement its requirements, a Council Regulation has immediate force of law in every Member State from the proclaimed date, taking precedence over any relevant existing national law. In this case, the proposed Council Regulation covers shipments of radioactive substances within the Community.
It is a fast moving proposal that might have become law by the time this newsletter is published! At the time of writing (December) it proposed that consignors should be required to receive from consignees, prior to any shipment between Member States, endorsed declarations that the consignee complied with relevant legislation in respect of notification or prior authorisation and financial arrangements for return or disposal of the source. We hope to moderate the requirements before adoption.
Public Information for Radiation Emergencies Regulations
Finally, the Public Information for Radiation Emergencies Regulations which were made under the Health and Safety at Work etc Act 1974 and the European Communities Act 1972 are due to come into force on 1 January 1993. These Regulations implement the Council Directive 89/618/Euratom on informing the general public about the health protection measures to be applied and the steps to be taken in the event of a radiological emergency. As is customary, the Regulations permit six months from the date of comin into force for industry and local authorities to bring themselves into compliance. In addition, the Health and Safety Executive is producing explanatory guidance to accompany the Regulations which should be available early 1993. These Regulations and their guidance are being highlighted to RPAs as they may be required in the first instance to help employers assess whether a radiation emergency is reasonably foreseeable from the employer's activities.
In August 1992 the United States Department of Energy's (USDOE) Office of Nuclear Safety issued a Safety Notice DOE/NS-0007 Issue No 92-2 dealing with radial-ion shine paths from radioactive cells. The notice summarised the lessons learnt about radiation safety from a review of radioactive cell facilities which handle sources, irradiated material and fission products. Deficiencies found included covering of radioactive cell penetrations with duct tape, missing shield block bolts and missing or incorrectly designed penetration plugs.
The existence of undetected radiation shine paths could result in personnel overexposure and these shine paths could produce exposures that were not reflected in dosimetry readings. This is because narrow beam radiation exposures would not be detected by a dosemeter worn on the trunk, ie part body exposure only. Furthermore, routine radiation surveys of radioactive cell exteriors would not necessarily detect these shine paths because repositioning of the source within the cell could significantly affect the radiation field.
USDOE suggested the following actions to minimise personnel over-exposures at radiation cell facilities:
The Safety Notice provides useful information that may be applicable to the UK. RPAs should consider whether the USDOE recommendations could usefully be applied to radioactive cells of which they are aware.
The International Atomic Energy Agency (IAEA) has published guidance on radiation safety of gamma and electron irradiation facilities (Safety Series no 107). This new safety guide will be of interest to those concerned with the supply and use of all types of irradiators. HSE has been actively involved in its drafting. It provides a general guide to the standards of safety required in these facilities. An important aspect, which was included at the suggestion of HSE, is a description of the responsibilities which designers, manufacturers, and installers have in the safety of irradiators. Experience has shown that this is an area of crucial importance, especially for provision of adequate safety information. Copies of the Safety Guide, ISBN 92 0101692 1, priced £14.25, can be obtained from HMSO, PO Box 276, London SW8 5DT (tel: 071 873 9090).
Published for internet 20/11/97