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Radiation Protection Adviser

Issue 4 December 1993

CONTENTS


Introduction

Welcome to the fourth issue of the newsletter, which now has a circulation in excess of 2000 individuals. Again we are including a wide variety of topics of interest to RPAs.

Any articles based on information supplied to the newsletter will exclude details which might identify the contributor. Draft articles will always be cleared with the contributor before publication.

We want the newsletter to represent both HSE's views and those of RPAs. So we welcome your opinion on the newsletter and the contents. Included in this edition is a reader survey, which we hope you will take time to complete and return to us. We aim to use the information you provide to enable us to more effectively target the newsletter.

Please send your comments, queries and mailing list details to:

Ann Loach,
The Editor,
RPA Newsletter,
Health and Safety Executive,
Level 6,
North Wing,
Rose Court,
2 Southwark Bridge,
London SE1 9HS.


Outside workers' Regulations

The Ionising Radiations (Outside Workers) Regulations 1993 (SI 1993 No 23792) and supporting Approved Code of Practice, will come into effect on 1 January 1994. The Regulations, which implement Council Directive 90/641/Euratom, will apply when workers designated by their employers as classified persons under the Ionising Radiations Regulations 1985 (IRR85) perform 'activities' in the controlled area's) of another employer. Under the Regulations these classified persons will be 'outside workers', their employers will be 'outside undertakings' and the employer in charge of the controlled area(s) will be an 'operator'.

Workers such as those carrying out site radiography who bring their own radiation sources onto site and designate controlled areas around their working locations will, in general, not be defined as 'outside workers'. Also, service engineers who visit various sites to maintain radiation generators will not be 'outside workers' if the nature of their work is such that they have to designate and take charge of controlled areas around these generators, eg because they have to operate equipment with some of the shielding removed.

The Regulations will:

The operator and outside undertaking will have to exchange specified information before the outside worker starts work for the first time in controlled areas on the operator's site. Also, the outside worker may need additional training or personal protective equipment.

The radiation passbook, which is an HSE-approved and uniquely numbered document, will contain information about the outside worker, his or her medical classification, assessed doses during the year and (after activities in operators' controlled areas), estimated does (see later on in this newsletter).

...The operator will have to make arrangements to enable doses received by outside workers on their sites to be estimated promptly and entered into the passbook at the end of the work.......

Outside undertakings can only obtain passbooks from dosimetry services approved by HSE for the purpose of co-ordination and record-keeping (ADS records'). These dosimetry services have to purchase the passbooks from HSE but they will probably hold a small stock to deal with urgent orders from outside undertakings. Normally, 'ADS records' will allocate passbooks to outside undertaking who will then individually allocate them to outside workers. The ADS will keep records for each passbook issued.

The operator will have to make arrangements to enable doses received by outside workers on their sites to be estimated promptly and entered into the passbook at the end of the work.

Copies of the Regulations are available from HMSO. A composite document containing the Regulations, supporting ACOP and associated non-statutory guidance is available from HSE Books.

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ADS News

Readers will be interested to note that Issue 2 of ADS News was published in November 1993.

The main purpose of this HSE newsletter is to share information with Approved Dosimetry Services and encourage feedback of ideas and/or concerns to HSE about the requirements for approval.

Copies are available from the Editor.

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Trends in occupational exposure 1986-91

In October 1993, HSE published a report covering annual doses to classified persons in Great Britain between 1986 and 1991. The report is based on data held by HSE's Central Index of Dose Information (CIDI), which receives dose information from Approved Dosimetry Services.

The report analyses annual whole-body doses greater than zero for particular occupational groups; reported doses of zero were excluded to minimise the possibility of bias. It shows that over the six year period there has been an overall reduction of around 50% in average and collective doses. Moreover, it demonstrates a ten-fold decrease in the proportion of classified persons with doses greater than 15 mSv a year (the main investigation level in IRR85); in 1991 fewer than 200 classified persons had a recorded dose above this level. The improvement was particularly marked in the nuclear sector. In 1986 around 60% of those with an annual dose greater than 15 mSv were accounted for by this sector; by 1991 the corresponding figure was under 10%.

Overall, these findings suggest that IRRS5 have helped to bring about a sustained reduction in radiation doses to classified persons. In contrast to this general picture, however, the report reveals adverse trends since 1988 in doses for two groups: industrial radiographers and non-coal miners underground.

More detailed statistical summaries of CIDI data for the years 1989, 1990 and 1991 were published at the same time as the main report. For further details see the enclosed order form.

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Industrial radiography

It appears that some industrial radiography companies are not applying appropriate engineering controls to restrict exposure to ionising radiations. HSE inspectors have found examples of companies carrying out routine radiography work on the same site over long periods without providing a shielded enclosure.

Where site radiography conditions can be justified, not enough attention has been given to the location of the control point and to the provision of localised shielding, including collimation, to restrict the size of the controlled area around the work. Also, inspectors are still finding examples of inadequate contingency plans for dealing with 'stuck sources': plans are often unrealistic or unrehearsed and emergency kits, including bags of lead shot and long handled tools, are not available on site.

HSE is producing an information sheet which summarises the key precautions necessary to restrict exposure so far as reasonably practicable, in accordance with IRR85 requirements. Copies will shortly be available from the Editor and HSE Area Offices.

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Special entries in dose records

An article in Issue 2 explained the circumstances in which HSE considers it worthwhile for employers to apply for special entries in dose records under regulation 13(8) IRR85. We would like to make it clear that the factor of two quoted in the article only related to applications requesting changes for a single assessment period in respect of one individual. Where the error concerns a number of dose assessment periods, HSE would expect to receive an application for a special entry, even if the proposed changes are less than the factor of two, especially if different years or doses approaching dose limits are involved. RPAs should note that regulation 13(8) concerns any dose quantity referred to in schedule 1 IRR85, not just the sum of these quantities.

.....Where the error concerns a number of dose assessment periods, HSE would expect to receive an application for a special entry, even if the proposed changes are less than the factor of two, especially if different years or doses approaching dose limits are involved........

When such applications are made employers should be prepared to provide HSE with a copy of the actual dose record(s) so that the precise entry to be replaced can be identified. Wherever possible, an estimated dose should be provided to replace the existing entry.

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Unauthorised dose record-keeping

In the last year, an employer operating from a number of premises was found to have been keeping dose records for classified persons without approval from HSE. The employer concerned had obtained dosemeters from an Approved Dosimetry Service (ADS), but did not make it clear that all the individuals to whom the dosemeters were to be issued were classified persons. Consequently, statutory dose records were only established for some of the employees; for the remainder the ADS reported the results directly to the employer.

It is important that RPAs make sure employers receive adequate advice about which types of employees should be classified and how radiation doses received by these people should be assessed and recorded. In this case the employer was an industrial radiography company undertaking site radiography - a type of employer who would normally be expected to classify almost all of its industrial staff.

If the employer requires dosemeters for non-classified staff it is essential that clear and separate systems are established for the issue of issue of dosemeters for both types of dosemeters for both types of employee to avoid possible confusion. The RPA should recommend the employer to seek advice from a dosimetry service approved for co-ordination and record-keeping.

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Radiation shine paths

One large organisation has written to point out that radiation shine paths, which were discussed in an article in Issue 3, are of a very small area and, unfortunately, so are the cross-sections of some of the detectors used in radiation monitors. So it is very easy to miss shine paths unless detailed checks are made. Consequently, it can be more productive to use large area contamination monitors to check for shine paths. Then, if a path is identified, check the magnitude of the dose rate with a suitable radiation detector.

Thank you for the advice

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Videos on veterinary practice

HSE is collaborating with the Unit for Veterinary Continuing Education (UVCE) to produce training materials for use in training staff in veterinary practices on the hazards associated with ionising radiation and how these may be overcome.

The first part of the package is available now and consists of a video and workbook called Radiation Safety. These explain the risks of exposure to radiation in veterinary practice and defines procedures that avoid these risks. The second part of the package is a further video/workbook and concentrates on the role of the RPA in helping veterinary practices to improve both veterinary radiology and radiation protection. It will be available from the end of the year.

For more information about this HSE-sponsored package and other UVCE programmes please contact Bob Brewster at UVCE, The Royal Veterinary College, Royal College Street, London NW1 0TU (tel: 0171 387 2898 ext 380/351)

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Radiation protection supervisors

Employers must appoint one or more Radiation Protection Supervisors (RPSs) under regulation 11 IRR85 to exercise general supervision of the work with ionising radiations. Until now, HSE has not issued any advice regarding such training. In order to give some guidance on this subject, and particularly to make clear that, in many cases, only a limited amount of training is required, HSE has prepared an information document on the training of would-be RPSs. It deals with the core of competence required by an RPS in terms of a number of modules. The extent and depth of knowledge required in each module will differ widely according to the tasks which have to be supervised.

Copies of the document will shortly be available from the Editor.

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Public information Regulations

The Public Information for Radiation Emergencies Regulations 1992 (PIRER) have been fully in force since 1 July 1993 and contain two main duties, one falling to employers and the other to local authorities. The first duty concerns work activities from which a radiation emergency is reasonably foreseeable. In these cases the employer carrying out the activity is required to distribute certain information to those likely to be affected by such an emergency. Operators of major nuclear sites had already distributed information along these lines on a voluntary basis; it seems that they have not found any real difficulty in conforming with the new legal requirement. Other employers who have a large inventory of radioactive materials on a site, particularly those obliged to prepare a biennial special hazard assessment under regulation 26 IRR85 (copied to HSE), should have obtained advice from an RPA as to whether the site comes within the terms of this requirement.

.... The other main duty under PIRER requires local authorities at county level to prepare arrangements for providing information to members of the public affected in the event of an actual radiation emergency.....

HSE inspectors have discovered a few employers who were unaware of this need. Therefore, it is particularly important that RPAs seek accurate information from employers so that appropriate advice can be given. If, following an assessment, it is decided that information does not have to be made available to the public, the employer will need to satisfy the HSE inspector that a radiation emergency is not reasonably foreseeable from that particular site.

The other main duty under PIRER requires local authorities at county level to prepare arrangements for providing information to members of the public affected in the event of an actual radiation emergency. The role of the local authorities should be as facilitators rather than as executors of a process.

HSE has prepared a non-statutory guide to these regulations.

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Children of Sellafield workers study

HSE published the report of this study on 21 October 1993. The study was carried out following publication of a report by Professor Gardner and his colleagues in the British Medical Journal in 1990. This report suggested that the raised incidence of leukaemia anti non-Hodgkins lymphoma (NHL) in young people near the Sellafield plant was statistically associated with exposure of fathers to relatively high levels of ionising radiations before conception of their children.

...The main purpose of the study, which was based on records held by British Nuclear Fuels Plc, was to see if HSE needed to take any specific action to further restrict workplace exposures. HSE's study concentrated on children born in West Cumbria between 1950 and 1989 to male workers at the Sellafield plant. In all, about 200 children were identified who were born in West Cumbria and developed cancer....

The main purpose of the study, which was based on records held by British Nuclear Fuels Plc, was to see if HSE needed to take any specific action to further restrict workplace exposures. HSE's study concentrated on children born in West Cumbria between 1950 and 1989 to male workers at the Sellafield plant. In all, about 200 children were identified who were born in West Cumbria and developed cancer. Out of these, 16 cases of leukaemia and NHL and 16 other cases of cancer were traced to fathers who had been directly employed at the plant.

The findings of the report suggest that no further preventative action is needed to protect the occupational health and safety of the Sellafield workforce over and above the measures which are already in place.

Copies of the report are available from HSE Books.

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Co-operation between employers Regulations (Regulation 4 IRR85)

Earlier this year, HSE had an enquiry from an RPA about how much co-operation is needed under regulation 4 IRRS5 for employees who share premises with another employer working with ionising radiations. There was a dispute between the two employers about how much information they were required to share under this Regulation.

....The information that has to be given should enable the second employer to take some action (eg to provide training or instruction) to ensure compliance with IRR85....

Regulation 4 IRRS5 requires an exchange of information (or some other form of co-operation) when the work of one employer (the first employer) is likely to expose the employees of another employer (the second employer) to ionising radiations. The information might concern:

The information that has to be given should enable the second employer to take some action (eg to provide training or instruction) to ensure compliance with IRR85. If the employees of the second employer are not likely to be exposed to ionising radiations from the work of the first employer there is no duty to cooperate, but it would be good practice to exchange information to reassure the second employer's workers.

In short, regulation 4 IRR85 requires co-operation for a purpose. It is not a blanket requirement for the exchange of all information about the work, eg to enable the second employer to cheek the validity of the hazard assessment under regulation IRR85.

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'Low specific activity materials'

Materials containing small amounts of naturally occurring radionuclides thorium-232 or uranium-238 (and their decay products) are often referred to as 'low specific activity' materials, since they usually have an activity concentration below 100 Bq gm-1. Industrial processes in which these materials are handled may give rise to a significant radiological hazard, eg in foundries using zircon sand, premises where refractories, pottery glazes, phospliates or abrasive materials are manufactured and places where scale build-up is cleaned from plant used for oil and gas extraction.

The main hazard arises from inhaling dust and fumes. Individuals can also receive significant exposure to external radiation while working near bulk stores of the material or near radium deposits in phosphate and titanium dioxide plants.

The main hazard arises from inhaling dust and fumes. Individuals can also receive significant exposure to external radiation while working near bulk stores of the material or near radium deposits in phosphate and titanium dioxide plants. In most cases employers can control the hazard from internal radiation using straightforward dust control techniques.

HSE has prepared an information document which describes the hazard and gives advice on control measures. Copies are available from the Editor and HSE Area Offices.

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International news

EC Shipments Regulations


The EC Regulations on Shipments of Certain Radioactive Substances between Member States of the Community came into effect on 9 July 1993. From that date holders of sealed sources (and until 1 January 1994 radioactive waste covered by separate Regulations from the New Year) have not been allowed to export these radioactive substances to another Member State until a written declaration, endorsed by the regulatory authority in that state, has been received from the prospective recipient. A written declaration may be valid for up to three years. Quarterly reports (in arrears) on actual shipments of sealed and other relevant substances that have taken place must also be sent to the appropriate regulatory authority in each Member State.

The regulatory authorities in Great Britain are HM Inspectorate of Pollution (England and Wales), HM Industrial Pollution Inspectorate (Scotland) and for licensed sites HSE's Nuclear Installation's Inspectorate. Employers likely to be affected by the Regulations should have received an information pack from the relevant regulatory authority.

Revision of Basic Safety Standards Directive


The Commission of the European Communities (CEC) submitted proposals for a revision to Council Directive 8018361 Euratom (the Basic Safety Standards Directive) to the European Council in August 1993 (published in the Official Journal of the EC on 9 September 1993). A basic negotiating line, taking account of the likely contents of the draft proposals, had been discussed with representatives of Government Departments, employers and employees in April 1993 and refined at a similar meeting in September, in the light of the actual proposals. Further consultation with representatives of interested parties will continue on an ongoing basis throughout negotiations, which began in September.

IAEA Basic Safety Standards

Issue 3 referred to the revision process taking place on the International Atomic Energy Agency (IAEA) BSS and that process continues. The fourth draft arrived in August inviting comments by mid-October. HSE acted as coordinator for the UK response, advising the Department of Trade and Industry which is the formal UK point of contact with the IAEA.

.....In November 1992 the European Court of Justice (ECJ) ruled that, contrary to previous beliefs, there could be circumstances that justified a Member State setting tighter radiation protection standards than those specified in the Euratom Basic Safety Standards (BSS) Directive.....

While the fourth draft was a considerable improvement on previous versions, we still think there is a long way to go. The next stage is another Technical Committee meeting in Vienna in December to discuss the fourth draft and any comments made.

European Court of Justice ruling


In November 1992 the European Court of Justice (ECJ) ruled that, contrary to previous beliefs, there could be circumstances that justified a Member State setting tighter radiation protection standards than those specified in the Euratom Basic Safety Standards (BSS) Directive. CEC had held that the Directive set uniform, not minimum, (dose limits) and alleged that, by setting stricter dose limits for certain young workers, Belgium was in breach of its obligations under the Euratom Treaty. The ECJ disagreed and ruled that stricter protection was possible.

HSC considered its policy on radiation protection in the light of this, along with other international developments and information about radiation doses to classified persons revealed by the analysis of information on CIDI. In October HSC published a, statement explaining that it had decided there was no need to revise dose limits ahead of adoption of a revised Euratom Basic Safety Standards Directive.

Copies of the statement are available from the Editor.

Qualified experts


The term 'qualified expert' originates from the Basic Safety Standards Directive. As readers will be aware, in Great Britain RPAs and qualified people are regarded as qualified experts within the meaning of the Directive requirement.

The Directive requires competent authorities in Member States to recognise the capacity of appropriate individuals to act as qualified experts. Some Member States have a highly structured approach to the recognition of qualified experts whereas IRR 85 adopt a more open approach to the recognition of these experts. The situation was reviewed in an HSE discussion document published in April 1992. This was followed by an HSE workshop on the subject in March 1993. This concluded that a more positive means of recognising qualified experts in Great Britain would be welcomed in any future revision of IRR 85. A note of the proceedings has been produced and copies are available from the Editor.

.... The Directive requires competent authorities in Member States to recognise the capacity of appropriate individuals to act as qualified experts. Some Member States have a highly structured approach to the recognition of qualified experts whereas IRR 85 adopt a more open approach to the recognition of these experts....

In July 1993 the CEC held a meeting in Luxembourg to discuss harmonisation of procedures for recognising qualified experts. This meeting confirmed the wide variety of approaches between Member States and the difficulty of attempting harmonisation of anything other than a list of minimum criteria for assessing suitability of applicants. The CEC will produce draft recommendations in the near future and HSE will circulate these for limited consultation.

Readers will have seen proposals for the content of National Vocational Qualifications (NVQS) in radiation protection. These were sent to professional bodies, major employers and other interested organisations by EDMC Management Consultants acting on behalf of the Department of Employment-sponsored Occupational Health and Safety Lead Body (OHSLB).

The proposals specifically addressed two levels of competence, level 2 (roughly equivalent to a health physics technician or surveyor) and level 4 (roughly equivalent to an area or senior health physicist). NCQs will be awarded as a result of an assessment of competence and not solely on the basis of training courses completed or academic examinations passed.

It should be stressed that HSE was not responsible for co-ordinating responses to this consultation exercise, which closed at the end of November and there are no plans at present to make the possession of an NVQ a statutory requirement for RPAS.

Published for internet 20/11/97

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Updated 2011-10-18