Welcome to the sixth edition of the newsletter. RPA News is now a well-established source of information and non-statutory advice.
We are still dealing with the comments made by those who replied to the questionnaire included with the fourth issue. Once again, some of the topics in this issue reflect comments made by readers. Future issues will contain information on other topics mentioned in the questionnaires returned.
As the newsletter is aimed at RPAs appointed under IRR85 and others concerned with ionising radiations, we have no plans to include items on non-ionising electromagnetic radiation. If you want more information on this topic please contact your local HSE Area Office inspector, or Environmental Health Officer as appropriate.
For those who asked very specific questions about exposure to ionising radiation, we will try to answer these in future editions. A number of readers supported a 'letters section'; I would welcome any letters, up to 200 words, on any issue relevant to readers.
I look forward to receiving your contributions - by early January please. Issue 7 will be published in May 1995.
Please send your queries and comments to:
The Editor, RPA Newsletter
Health and Safety Executive
Level 3, North Wing
London SE1 9HS
As reported in Issue 5 of RPA News, most organisations with responsibilities under the Ionising Radiations (Outside Workers) Regulations 1993 (OWR) seem to have made suitable arrangements to comply with these Regulations. However, there are still some difficulties.
Inadequate co-operation between outside undertaking (OU) and operators seems to have caused most of the problems. OUs do not always make sure that outside workers have properly completed passbooks and relevant training before they arrive at site to carry out work. Also, the operator's arrangements for dose estimation may not cover 'silent hours'. The operator and the OU must exchange information, before the work starts, about the radiological risk arising from that work and the arrangements in place to provide additional training; also, it is sensible to include the arrangements for recording estimates of dose.
In some cases, contractors' employees are being classified unnecessarily. The RPA should advise the OU, and the operator if necessary, where classification is not required (through a person who has already been classified this year cannot be 'declassified' until the end of the year - (regulation 9, IRR85). Also, the RPA can advise the operator, where it is appropriate on radiological grounds, to hand over control of areas, for example to maintenance contractors; in such cases OWR would not apply. If an area is handed over to an OU and the operator's employees need to enter that area, then the OWR do apply.
OUs who employ workers on short-term contracts have experienced administrative problems. These individuals may work for various employers during the year and so they have been issued with a number of passbooks. OWR do not permit the continued use of one passbook in these circumstances: each employer has to issue the outside worker with a passbook and return that passbook to their Approved Dosimetry Service (ADS) when the employee leaves that employment. However, HSE accepts that the employer should arrange for their ADS to ensure that up to date information is transferred to the passbook, including details of the latest dose assessment under the Ionising Radiations Regulations 1985 (IRR85). The ADS should be able to find out the most recent dose information by phone from the previous ADS (who will be known to HSE CIDI).
Other issues on which advice has been sought are:
We hope this advice is helpful; it does not supersede the published HSE guidance. HSE will be evaluating the Regulations in 1995 to assess their impact, and any significant difficulties they have caused. In the meantime, we would appreciate any comments you have on OWR - whether they are favourable or not.
HSE's Central Index of Dose Information (CIDI) statistical summary of data reported for 1992 was published in July 1994 (ISBN 0 7176 0757 7, available from HSE Books; tel: 01787 881165).
The 1992 figures show only small changes compared with the 1991 statistical summary. However, they are consistent with the continuing downward trend in reported whole body doses since 1986. In 1992 143 people were reported as having received a dose in excess of 15 mSv, which is the level at which an employer must carry out an investigation to see if exposure to radiation is being kept as low as is reasonably practicable (ALARP) (regulation 28(1) IRR85). The corresponding figure for 1986 was 1911 and for 1991, 147.
HSE has published guidance on safety in the design and use of gamma and electron irradiation facilities (Safety in the design and use of gamma and electron radiation facilities, HS(G)94) available from HSE Books, ISBN 0 7176 0647 3). This guidance advises on the main requirements for the safe design, control and operation of irradiation facilities, emphasising the importance of hazard analysis and formal risk assessment techniques.
The document takes account of current international views regarding safety at such facilities and explains the legislative framework for the operation of irradiation facilities as set out in IRR85. The guidance on concepts of safe design and formal risk assessment techniques are also appropriate for other applications of large sources of ionising radiation. This document complements earlier guidance referred to in Issue 1 of RPA News.
A final draft of the six-agency Basic Safety Standards was expected to be put to the September Board of Governors meeting.
Press reports of the death of an industrial radiographer, referred to in Issue 5, caused a good deal of concern both at ministerial level and elsewhere. As a consequence of the earlier fatal accident inquiry into this death HSE has reviewed certain aspects of current guidance on IRR85, including medical surveillance and the wearing of dosemeters. HSE plans revised guidance in due course and has contacted appointed doctors about the case.
There have been a number of developments specifically concerning industrial radiography. HSE staff have met representatives of the Service Inspection Group of the British Institute of Non-Destructive Testing to consider the need for action, particularly in the commitment of the industry to the ALARP principle and appropriate radiation protection training. Also, we have been involved in discussions about training standards at NRPB Chilton with representatives of Personnel in Non-Destructive Testing Ltd.
IRR85 regulations 13(3)(f), 28 and 29 require action to be taken in cases where assessed doses exceed certain levels; in most cases the .action includes a thorough investigation. Part 4 of the ACOP (ACOP part 4) supporting IRR85 also provides for an investigation when an individual's cumulative exposure reaches 75 mSv in five consecutive years. HSE expects these investigations to be carried out promptly and for the RPA to be closely involved. The investigation should normally include a review of relevant working practices and control measures to ensure that exposures are ALARP (regulation 6, IRR85). The promptness with which arrangements for an investigation are made serves to demonstrate an employer's commitment to keeping exposures ALARP.
HSE recently prosecuted an employer for failing to carry out an immediate investigation into the circumstances of an over-exposure to a classified worker. More than seven weeks after being notified by the ADS of the over-exposure the employer had still not carried out an investigation. The firm was convicted of a contravention of regulation 29 (1).
The roles of the RPA and RPS are quite separate and require, in most cases, different qualities and experience. If an employer proposed to appoint a person as an RPA under regulation 10, IRR85, they would have to show that the person had relevant qualifications and experience in line with those given in paragraph 71, ACOP Part 1. The RPS, on the other hand, does not need to have the same depth of knowledge, or breadth of experience, as the RPA, in order to fulfil the supervisory role. Paragraph 83 of ACOP Part 1 gives details.
In most cases the same person would not combine the two roles. The system envisaged by the Department of Education is that the senior science teacher at the school should be the RPS and that an outside consultant (for Local Education Authority Schools, the LEA science inspector) should be the RPA. An independent school can appoint a consultant (eg from the Institute of Physics) as RPA and a junior science teacher as RPS, provided, of course, that their qualifications conform to the relevant paragraphs in the ACOP. However, there is no legal bar to the RPA and the RPS being the same person. There could be cases where an individual possesses the appropriate qualifications and experience for both roles and IRR85 do not prevent that.
In August HSE published a review of the results of its original study reported in Issue 4.
HSE's review (ISBN 0 7176 0833 6, price 2.75, available from HSE Books) looked at particular aspects of the methodology used in the original study for the treatment of anomalies, ie gaps and double entries in radiation dose records used in the investigation. HSE modified two of the findings in the original report, which were both heavily influenced by doses estimated for particular individuals.
The review confirmed the main conclusions of the original report. It tends to weaken still further any support for Professor Gardner's reported association between fathers' radiation exposure before conception and the increased risk of leukaemia and non-Hodgkins lymphoma in their children.
This is an outline of some of the more important legal requirements covering radioactive waste management. Accumulation and disposal of radioactive waste are subject to the requirements of the Radioactive Substances Act 1993 (RSA93) enforced by FWIP and HMIPI. Many of the duties imposed on employers are also encompassed within IRR85, enforced by HSE.
RSA93 controls both the keeping and use of radioactive substances and their subsequent disposal by a series of registration and authorisation certificates. A number of exemptions are provided for different categories of radioactive substances or types of use. The certificates of authorisation for accumulation and disposal may detail conditions to be met such as activity limits, maximum volume, period of accumulation and disposal route. Where it is safe to do so, conventional methods of waste disposal such as discharge to sewers, use of refuse landfills or incineration are advocated.
IRR85 defines work with ionising radiations as including the holding, storage, transport or disposal of any radioactive substance. Specific regulations which you may need to consider include: regulation 19 - accounting; regulation 20 - storage, and regulation 6 - restriction of exposure. The adequacy of the steps taken may need to be periodically confirmed by radiation and/or contamination monitoring of the store and its contents.
HSE priced and free publications are available by mail order from:
PO Box 1999,
Suffolk C010 6FS;
tel: 01787 881165;
fax: 01787 313995.
An article in Issue 5 dealt with the practical application of QA to radiation protection. The meeting on 19 January of the Society for Radiological Protection will be devoted to this issue and will include an HSE speaker. The venue is the Commonwealth Institute, London.
Published for internet 15/12/97