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Radiation Protection Adviser

Issue 5 June 1994

CONTENTS


Welcome to the fifth edition of the newsletter, which is now a well established source of information.

In the fourth issue we included a reader survey, asking for comments - thank you for taking the time and trouble to complete it - we received 500 replies. Most of those who replied thought the newsletter was a very useful publication. Some of the articles in this issue reflect comments made by readers. Future issues will contain information on other topics mentioned in the questionnaires returned. In response to readers' requests we have decided from now on to publish two issues a year, in May and October.

A brief analysis of the replies suggests that RPAs and RPSs make up almost two thirds of our readers, with all sectors well represented. Issue 4 raised a lot of interest and a further 100 names have been added to the distribution list.

For those who asked very specific questions, we will try to answer these in future editions. If you requested information sheets but have not yet received them, please contact the Editor. Readers who asked for information on training potential RPSs should have received it in the last few weeks - sorry for the delay.

Many replies indicated that a 'letters section' would be a good addition we look forward to receiving your contributions - by early July for Issue 6 please.

Queries and comments should be addressed to:

Anne Loach
The Editor, The Radiation Protection Adviser
Level 3, North Wing
Rose Court
Southwark Bridge
London SE1 9HS

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Industrial Radiography

HSE's information sheet about industrial radiography mentioned in the last issue was published in March. It is intended to encourage the use of better engineering controls and working practices to restrict exposure & to ionising radiations in this sector.

The sheet summarises precautions required to comply with the requirements of the ionising Radiations Regulations 1985 (IRR85). It is aimed at directors and managers in industrial radiography companies and their clients. Although radiation doses to classified workers as a whole have been falling steadily, this is not the case for industrial radiographers. Also, incidents continue to occur because:

A typical example of poor practice was found by an HSE inspector at a routine visit to an open air fabrication yard associated with the offshore industry. Six thousand radiographs of pipe welds were planned over two months. Radiography was in progress but no shielded enclosure had been provided. The controlled area had not been adequately restricted by local shielding, it was not properly marked; the control point for radiography was well inside the area giving unnecessary exposure to the operators and there was no effective control to prevent employees of the fabrication company from entering the area. The inspector stopped the work until the company's RPA visited the site. As a result many improvements were made.

A fatal accident inquiry held last year into the death of an industrial radiographer concluded that he had received a massive overexposure to ionising radiations at some stage over the previous 10-15 years. However, his recorded doses were not out of the ordinary. Two years before ill health forced him to stop work he developed severe ulceration to the fingers of his left hand; this was not reported to HSE (such a condition would, under normal circumstances, be reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1985). The matter was further complicated by him not having time off sick from work - a poor sickness absence record might have triggered a special medical examination under ACOP Part 1, paragraph 100. It was not possible to reach a definite conclusion about how the overexposure had been received, so long after the event(s).

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Feedback from HSE Inspectors

  1. At a first visit to a Non-Destructive Testing (NDT) equipment supplier, an inspector found unsatisfactory arrangements for repair and servicing of X-ray equipment. A home-made lead-lined cabinet used for testing X-ray sets did not have an interlocked door and no warning devices were provided. The. company had no local rules for this work and no designated radiation protection supervisor. An immediate prohibition notice was served preventing further work with ionising radiations until the company resolved the deficiencies.
  2. A compactor vehicle ran over and crushed an unattended nuclear density gauge in a quarry landfill site. It was not company practice to use cones or warning beacons to identify the presence of gauges. There were no contingency plans for such an occurrence and it took several days to arrange for the removal of the remains of the device. The RPA did not have the necessary monitoring equipment to test for contamination or leakage of radioactive material from the gauge. The inspector found that employees using the gauge had not been adequately trained and nobody had been designated as a radiation protection supervisor.

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Accident and incident database

HSE has joined NRPB in a partnership to establish a non-nuclear radiation incident database. The database will contain anonymous information based incidents investigated by an HSE inspector or the NRPB RPA service. A joint publication is planned for this year to explain the database and its operation; and later we will publish periodic summaries and analyses of the data. It should help HSE and RPAs to advise employers on the identification of potential radiation incidents.

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Management of Radiation - a quality issue?

Total Quality Management (TQM), Quality Assurance (QA), Quality Management Systems (QMS), risk assessments, audits - have you ever wondered how they might be applied to radiation protection?. HSE's publication Successful health and safety management, HS(G)65 ISBN 0 7176 0425 X (available from HSE Books) tel: 0787 881165, is a practical guide for directors, managers and safety professionals on the key elements of policy, organising, planning, measuring performance, auditing and reviewing safety performance.

The advice given in the document has been put to a rigorous test during the recent HSE team review of safety management of the Atomic Weapons Establishments. It provided the framework for interviews, inspection and style of the final report that will be published later this year. We feel that HSE's document has passed the test.

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HSC'S Working Group on Ionising Radiations Report for 1991/92

In December 1993 the Health and Safety Commission published the latest biennial report (for 1991 and 1992) from its Working Group on Ionising Radiation (WGIR). Among the issues considered by WGIR during this period were:

UK policy on radiation protection (in response to a European Court of justice ruling that there could be situations that justified a Member State setting dose limits for radiation exposures that were lower than the specified limits in the current Euratom Directive);

implications of NRPB's first analysis of the National Registry for Radiation Workers;

HSE's studies following up research by Professor Martin Gardner into the incidence of childhood leukaemia in the vicinity of Sellafield.

Working Group on Ionising Radiations
Report to the Commission (1991 and 1992),
ISBN 0 7176 0686 4
is available from HSE Books, price 4.50.

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Outside Workers Regulations

The Ionising Radiations (Outside Workers) Regulations 1993 came into effect on 1 January 1994. After an initial hiccup over printing of the passbook, which led HSE to send temporary passbooks to Approved Dosimetry Services, most 'outside undertakings' and 'operators' now seem to be coping reasonably well with the requirements of the Regulations. Not surprisingly, there have been a few problems, many of which were anticipated and addressed in HSE's guidance book Protection of Outside Workers against Ionising Radiation ISBN 0 7176 0681 3, (available from HSE Books).

We have had a number of enquiries from puzzled contractors who have been told that their non-classified staff need radiation passbooks - they don't! The Regulations only apply when workers designated by their own employer as classified persons carry out working activities in the controlled areas of another employer. The Regulations do not require other workers to be issued with radiation passbooks.

Other questions have concerned:


Veterinary practice

Last year, the NRPB undertook a survey of radiation protection standards in veterinary practice on HSE's behalf. Fifty UK practices were selected at random. NRPB staff visited the 50 practices, sometimes jointly with HSE inspectors, and questionnaires were completed with the help of a partner in the practice. Staff carrying out radiography wore body and extremity dosemeters for a four week period.

Eighty per cent of the practices had appointed an RPA of whom 35% held a diploma in veterinary radiology. The remainder were either health physicists or X-ray equipment suppliers, and some of these had never, or not recently, visited the practice. Also, these RPAs tended to confine their advice to equipment QA; some vets had received little or no advice on proper procedures required for compliance with (IRR85).

Problems were also found with the standards of local rules: 15 of the 40 practices who had appointed RPAs either had no local rules or ones which were seriously defective. Many of the radiation protection supervisors who had been appointed were considered to have poor knowledge of IRR85. The survey also revealed some practices where manual restraint of animals was normally done, and others where film processing was poorly controlled.

The NRPB/HSE Guidance notes for the protection of persons against ionising radiations arising from veterinary use ISBN 0 85951 300 9 give useful advice on the do's and don'ts of veterinary radiology. Also issue 4 of this newsletter drew attention to training materials being produced for RPSs and others by the Royal Veterinary College. The second part of this package, consisting of a video and workbook about the role of the RPA in helping to improve veterinary radiology practice, has now been published.

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Dosimetry

HSE is revising its Requirements for the Approval of Dosimetry Services (RADS) Parts 1 to 3 and will be consulting ADSs shortly.

The 1992 statistical summary information on CIDI is about to be published.

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Revision of the EURATOM Basic Safety Dtandards directive

Issue 4 referred to the proposed revision by the European Commission (EC) on the Euratom Directive (80/836); the current Directive is largely implemented in the UK by IRR85. Negotiations on the proposals have been taking place over the last six months and interested parties in the UK have been (and will continue to be) consulted about any significant developments. The EC now intends to revise the draft proposals.

One area of disagreement concerns individual monitoring of 'exposed workers', ie workers who receive more than 1 msv a year. The EC sees only two types of 'exposed worker: category A (the classified person' in the UK) and category B. Under the current proposals category B workers would have to be individually monitored whenever they entered a controlled area'; dose records would then need to be kept for these individuals. The UK argues that this should not be necessary in many cases since an estimate of dose, perhaps based on a measurement of dose rate and occupancy, may be sufficient to demonstrate that such people do not require designation as category A.

However, the UK had no support from other Member States. We are not sure whether there is a real problem here for the UK: individual monitoring of category B workers is routinely carried out in hospitals, for example (but not long term record keeping). We would be interested to learn of any significant problems such a requirement might cause.

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STOP PRESS..................

Readers may have seen recent press coverage about gross overexposures of industrial radiographers; one of the cases is discussed on page 2. Proper planning and supervision of their work should restrict exposures to well below dose limits and prevent abuses of local rules, eg non-wearing of dosemeters. This coverage has highlighted the hazards industrial radiographers might face and reinforced HSE's push to bring about improved control in this sector.

Published for internet 19/11/97

Updated 2011-09-14