Welcome to the eighth edition of the Radiation Protection Adviser. Thank you to those who responded to our request for views - we have included extracts from these letters. We hope you continue to write to us with your reactions to articles in the newsletter. In this issue, we are particularly interested in your comments on the issues raised in the article on the use of derived levels.
Apologies to those of you who did not receive Issue 7 at the end of May: we used a different distribution system and this was not entirely successful. We have taken steps to make sure those problems don't happen again.
This is a special 'bumper' edition - eight pages so we can give you as much information as possible about a wide variety of topics.
We want to ensure that our mailing list remains accurate and current. With this in mind, could you please check that we have got your details right. If not, please contact the Editor at the address shown, in writing or by fax, before February 1996. Please include your job title in the details.
Please send your comments, queries and mailing list details
Anne Loach, The Editor RPA, Newsletter
Health and Safety Executive,
Level 6, North Wing, Rose Court
2 Southwark Bridge,
London SE1 9HS
In 1992 the Health and Safety Commission started a fundamental review of its policy and activity on 10 occupational issues, including ionising radiation. As a result of that review, HSE produced a statement summarising the main strategic recommendations arising from the review and action plans to deal with each of the 10 health risk areas.
In May 1995, following on from the review, HSE launched the 'Good Health is Good Business' campaign. This is a major 3-4 year campaign aimed at helping to improve industry's health risk management. The main objectives of the campaign are:
Each stage of the campaign will focus on specific health risks: 1995/96 the campaign is concentrating on musculoskeletal risks, noise and respiratory sensitisers. We will keep you informed about the progress of the campaign.
The ionising radiation risk review drew on several sources of information, but especially the statistical data generated by HSE's Central Index of Dose Information (CIDI), and published in October 1993, as Occupational exposure to ionising radiation 1986-1991: analysis of doses reported to CIDI. This showed a sustained downward trend in doses except in the sectors of industrial radiography and non-coal mining.
In 1994, all 10 summaries were published in the Occupational Health Review. Each risk area will be reviewed annually against the action plan, and we are currently updating the ionising radiations risk review and action plan. Our initial examination of the ionising radiations risk review resulted in the publication of the information sheet on industrial radiography (free copies available from the Editor).
Over the past year HSE and the National Radiological Protection Board (NRPB) have set up an Ionising Radiations Incidents Database (IRID) to bring together information about radiation incidents in an anonymous form. The database, which will be operated by NRPB, will contain details of radiological incidents covering occupational and public exposure. Nuclear and transport accidents will be excluded as they are covered by existing arrangements. Initially the database will contain details of incidents investigated either by HSE inspectors or NRPB RPA staff. Neither the employer nor any persons affected by an incident will be identified.
The purpose of IRID is to share lessons learnt as a result of past incidents; in time it should be possible to analyse the data for trends. A draft first report has been prepared and other organisations are being approached about joining HSE and NRPB as partners in operating the database; HM Inspectorate of Pollution has already agreed in principle to becoming a partner. The first report, scheduled for publication in 1996, will describe the operation of the database and include examples of incidents with schematic illustrations.
The database will not only include incidents resulting in significant doses, but will also include 'near misses' from which we can learn. An example of the latter is given below:
An industrial radiographer was observed working in a shielded enclosure with the door open and the 'X-rays ON' warning light illuminated. The equipment was immediately shut down and taken out of service. The dose received by the TLD dosemeter worn by the radiographer was assessed and a sample of his blood was analysed. Both indicated that he had not received a measurable exposure to ionising radiation. Extensive investigation revealed that an intermittent fault in the X-ray control panel resulted in a failure of the control circuit so that operation of the 'OFF' button did not stop the X-ray generator from producing X-rays. However, in this case the electrical interlock fitted to the enclosure door was still operational and the opening of this door had terminated the exposure.
The Ionising Radiations (Protection of Persons Undergoing Medical Examination and Treatment) Regulations 1988 (POPUMET) are concerned with ensuring that medical exposures to ionising radiations are kept as low as reasonably practicable in accordance with accepted diagnostic or therapeutic practice. They require, among other things, that such medical exposures are carried out by trained personnel, and expert advice is available to employers for patients who are undergoing treatment or being administered with radioactive medicinal products.
When these Regulations were made, HSE was given responsibility for enforcing most of them, except in relation to the administration of radioactive medicinal products. The Health and Safety Commission has now made an agency agreement with Health Ministers under the Health and Safety at Work etc Act 1974 to extend HSE's enforcement responsibilities to include this area, except for issues of clinical judgement and other matters under Regulation 4. This agreement came into force from 14 August 1995.
This change means that HSE inspectors can now consider issues of training and access to expert advice across the whole spectrum of uses of ionising radiations in health care. It does not, however, affect the Medicines (Administration of Radioactive Substances) Regulations 1978 (MARS), which require persons administering radioactive substances to hold an authorisation certificate issued by the Health Ministers. Nor does it affect enforcement of regulation 4 of POPUMET, which remains with inspectors appointed by the relevant Secretaries of State.
We are reviewing the information in HSE Guidance Note PM77 as part of a general review of HSE guidance. We have, for some time, been considering giving additional advice on the investigations required under regulation 33(2) IRR85, when a person receives a medical exposure much greater than intended as a result of an equipment malfunction or defect. Our aim is to consult interested parties about a revision to PM77 early in 1996.
In May 1995, experts on the Euratom Article 31 Group considered a proposal to revise Council Directive 84/466/Euratom (Patient Protection Directive). The proposed revision had been prepared by a working party at Article 31 Group under the chairmanship of Mrs Zuur, a Dutch expert on the group. From September 1994 the working party included Dr Penny Allisy-Roberts, a UK member of Article 31 Group.
The proposal attracted extensive comments and the draft will need to be revised. It is difficult, at this stage, to predict when this will be published as a formal proposal by the European Commission; however, it is in the Commission's 1995 legislative programme.
We will keep you informed of any developments.
In September, HSE published the 1993 CIDI statistical summary of dose data. This was delayed mainly because of problems in obtaining complete data from a few Approved Dosimetry Services (ADS). The annual returns from ADS to CIDI were much improved for 1994 dose data. We now expect to be able to publish CIDI statistics for 1994 in November and to maintain this publication timetable for CIDI statistics in future years.
The statistical summary for 1993 shows that doses were reported for 56 740 workers with a mean whole-body dose, after standard corrections, of 0.9 mSv. The corresponding figures for 1986 were 56 043 people and a mean dose of 2.3 mSv. In 1993, there were 136 classified persons with a reported annual whole-body dose above the principal investigation level of 15 mSv, excluding 'notional doses'; in 1986 the corresponding figure was 1911. As in previous years, the occupational group with the highest average annual dose in 1993 was non-coal mining underground, with an average annual dose of 14.4 mSv, excluding 'notional doses'.
Copies of the 1993 CIDI statistics (ref number HSE/CIDI/1993) are available from the Editor, who can also supply copies of previous statistical summaries.
From time to time, Approved Dosimetry Services (ADSs) send employers personal dose reports which are unexpectedly high, or the ADS reports a dosemeter as unreadable. An investigation may well be required (IRR85, regulation 28 or 29, or regulation 13(7) or (8) may apply), and HSE would expect the RPA to be involved in that investigation.
In these cases, the ADS can often provide valuable information. It is almost always worth asking them for help. With film dosemeters, and others that provide a permanent record, the ADS can re-examine the dosemeter for signs of damage, contamination etc, or for evidence of the nature of the radiation source involved. ADSs employing thermoluminescent dosemeters can sometimes re-read a dosemeter using a special technique involving ultraviolet light; and they may also have a record of the 'glowcurve' produced when the device was read - this will show whether or nor there was a fault with the device or the reader.
Personal air sampler filters can be autoradiographed to show qualitatively the numbers and sizes of particles they carry.
Some investigations have pointed to alleged faults occurring at the ADS itself. In these cases, it is especially important to alert the ADS, and seek their opinion. An employer should not close an investigation report by alleging that the ADS was at fault without taking the matter up with the Service, although this has happened in some cases. If genuine problems exist at an ADS, the staff there will be anxious to identify them and to put matters right, otherwise other clients could be affected. In the unlikely event of an ADS giving an unreliable service, HSE would want to be made aware of the problem, because it may affect the continued approved status of the service.
Issue 3 of the Radiation Protection Adviser included a short article dealing with dosemeters accidentally irradiated while not being worn. It gave advice about how to avoid incorrect doses being recorded in the dose record of a classified person following such an incident. If such doses are recorded accidentally, the employer should apply to HSE for a special entry in the individual's dose record. Issues 2 and 4 of the newsletter included advice about special entries. Copies of all these articles may be obtained from the Editor.
Recently, we have become aware of some concerns regarding the appointment of medical physicists as RPAs to industrial radiography companies.
Clearly, the quality of advice from RPAs is an important factor in helping to achieve better control of the exposure of industrial radiographers to ionising radiation. The employer should, for example, be consulting the RPA about the provision and maintenance of engineering controls and systems of work to restrict exposure so far as reasonably practicable. The RPA also has a significant role to play in the training of personnel.
In principle, there is no reason why a medical physicist should not act as an RPA in the industrial radiography sector. However, the individual concerned should possess the relevant qualifications, experience and qualities set out in paragraph 71, of Part 1 of the Approved Code of Practice supporting the Ionising Radiations Regulations 1985. In particular, he or she should have an understanding and detailed knowledge of the working practices used by that employer, together with relevant guidance material and a general knowledge of working practices used by other industrial radiography companies.
The current British Standard for industrial gamma site radiography apparatus is BS5650:1978. Paragraph 69, Section 7, Part 2 of the Approved Code of Practice supporting the Ionising Radiations Regulations 1985 (IRR85) advises that exposure containers should comply with this standard so far as reasonably practicable. This British Standard derives from the International Standards Organisation (ISO) document ISO 3999.
Over the last few years, ISO has been revising ISO 3999. This work is now approaching completion. The revised standard will identify technological advances that will improve radiation protection by reducing the risk of accidental exposure during site radiography. We will let you know when the revised ISO standard is published.
We have received a few letters suggesting there may be some confusion about the way in which doctors are appointed for the purposes of regulation 16 of IRR85.
Under the Regulation, employers have a statutory responsibility to provide health surveillance for classified workers. The role of the Employment Medical Advisory Service (EMAS) is to ensure quality control and to collect national statistics.
It is for the employer to identify a doctor to provide the necessary health surveillance for workers, while EMAS is responsible for confirming the suitability of the doctor. The appointment to carry out the work is for a specified period of time.
HSE is currently revising its guidance to Appointed Doctors for example, deciding on the need for a medical examination or a paper review of records at the time of the Statutory Annual Review. The publicity surrounding the death of an industrial radiographer highlighted the need for Appointed Doctors to consider the type of work done and the chances of receiving large doses of ionising radiation.
The revised guidance is likely to include:
If you wish to comment on these proposed revisions, please write to the Editor.
Adverse trends in radiation doses received by industrial radiographers have been discussed in past issues of this newsletter (see issues 4-6). The training received by industrial radiographers, and particularly those who work as site radiographers, is of paramount importance, since working conditions can change with each job, and the work can often be during unsociable hours.
Over the last year, HSE has been working with the National Radiological Protection Board (NRPB), Personnel Certification in Non-Destructive Testing Ltd (PCN) and the North Atlantic Section of the American Society for Non-Destructive Testing (ASNT) to assess the adequacy of radiation safety training for industrial radiographers. We will keep you informed of developments.
The EC held a meeting in Luxembourg at the end of March to review implementation of the Outside Workers Directive. It revealed that the UK was the only EU Member State to have made national legislation by the due date for implementation. However, Ireland, Germany, Denmark and the Netherlands have now joined us, with Italy and Spain apparently not too far behind.
The French representative at the meeting could not say how dose information would be exchanged if a French outside worker came here, or a British outside worker went to France, because of their belief that dose information can only be given to doctors. Fortunately, this particular problem does not seem to exist in other Member States. DGXI of the Commission is looking at ways of resolving this problem.
The circumstances surrounding the death of an industrial radiographer - which was heavily reported in the press last year- suggested that some classified persons may not always wear their dosemeters when they should. In response, HSE is about to publish a pocket card and associated poster, giving guidance to classified persons on wearing and looking after dosemeters (available from HSE Books), IND(G)205(C), 5.00 for a pack of 20 pocket cards and 1 poster). At the same time HSE will be publishing a more detailed information sheet for managers explaining the requirements for the assessment and recording of doses (free copies available from the Editor).
The general requirement to restrict exposure to ionising radiation so far as reasonably practicable extends to the minimisation of surface contamination (regulation 6(2) of IRR85). How do we know whether our efforts to keep the working environment free from such contamination have gone far enough?
The traditional answer to this question has been to refer to derived levels of surface contamination. Indeed, in the days before IRR85 came into effect, we had "maximum permissible levels of contamination" (Schedule 2 of the Ionising Radiations (Unsealed Radioactive Substances) Regulations 1968). No such values appear in IRR85, so a different approach was needed.
Part 1, paragraph 17 of the Approved Code of Practice (ACOP) tells us that there is no level of contamination specified as acceptable. The aim should be to achieve the lowest level that meets the requirements of regulation 6(2). But how low is that?
In 1979, NRPB published a report entitled Derived limits for surface contamination (NRPB-DL2, together with a Supplement published in 1982). The report brought up to date the old maximum permissible levels of contamination, taking into account new ICRP Recommendations (ICRP Publication 26, and in the Supplement, ICRP Publication 30). They were no longer regarded as maximum permissible levels, but rather guideline figures that should not normally be exceeded in the workplace. The authors used cautious models of exposure to derive the levels from the primary dose limits. The models were for inhalation of resuspended material, for direct irradiation of the skin, and for ingestion of material transferred from the hands to the mouth.
IRR85 require employers to carry out monitoring for surface contamination, and ACOP Part 1, paragraph 146 indicates the matters to take into account in developing a monitoring programme. These matters include reference levels, and the action to be taken if these are exceeded. HSE has sometimes referred to the values in NRPB-DL2 and its Supplement when advising on appropriate reference levels.
Occasionally, employers have taken as reference levels the values in Column 4 of Schedule 2 of IRR85. Although these values were originally based on figures in NRPB-DL2, they are only meant to provide a basis for deciding whether or not an area needs to be designated as a controlled or supervised area because of the ingestion pathway of exposure. For radionuclides that present greater risks from skin irradiation or from inhalation (eg 35S, 90Y, 239Pu), the figures in Column 4 of Schedule 2 are inappropriate as reference values for monitoring of surface contamination.
Now that we are starting to look ahead to revised Ionising Radiations Regulations (see later article below on BSS) we need to consider whether revised tables of derived levels for surface contamination are needed. How much use do you make of the present tables in NRPB-DL2? Would you welcome the issue of new derived levels? Or in practice do you find that your clients prefer to decontaminate surfaces down to levels which are not measurable? Please write in and give us your opinions and experience.
Revision of the 1980 Euratom BSS Directive on radiation protection may be about to speed up. The EC's Atomic Questions Working Group has completed its second reading of the Commission's proposals (and the third reading is in progress) submitted in July 1993 and amended in July 1994. There has been encouraging progress on several important issues. For instance, the current working drafts (which have been changing from meeting to meeting) would allow us to continue to classify workers according to their likely dose, rather than where they work, and to continue our present approach to monitoring and record-keeping for non-classified workers.
The thorny issues of natural radiation and intervention have now been successfully addressed.
Adoption this year begins to seem a real possibility, and is the stated aim of the Spanish Presidency. We are organising a meeting with representatives of interested parties (sorry, we can't invite you all) on 19 October to review progress and discuss our preliminary plans for revision of IRR85. Member States are likely to have four years to implement the revised Directive, once adopted - giving perhaps IRR1999 or even IRR2000?! As usual, HSE will formally consult all interested parties during the implementation phase. We will also continue to keep you in the picture through this newsletter.
Issue 7 included a letter from a reader who advocated certifying safety competence for RPAs, RPSs and classified workers. We received several letters in response to the article. Some extracts are shown below.
"HSE should continue to promote a policy of awareness through training and experience, rather than adopt prescriptive accreditation and examination criteria for classified workers, RPAs and RPSs. When solving radiation protection problems, my clients put more value on my practical experience gained than my science degree."
Mr I D Jackson, Nuclear Safety Consultant
"In addition to the normal apprenticeship of at least 5 years with an established Health Physicist, we set an onerous self tuition system backed up by local tutorials. With the growing financial constraints and consequent loss of so many of our most knowledgeable Health Physicists, such training is now slipping. I consider that the 'certification' of Health Physicists must have some formal standardisation, but not necessarily by examination."
Mr D P Hanlon
"I think the suggestion that RPAs ought somehow to be licensed has a great deal of merit. However, I cannot think of any sensible way to achieve a scrutiny system that avoids human error, misjudgement or incompetence. The work of an RPA is very subjective: it can range from giving simple advice on the use of very small sealed sources to advising on practices in the forefront of sciences often not related to the individual's scientific discipline. The grasp of science, law and plain common sense would be extremely difficult to evaluate effectively. In short, I do not think that the HSE should consider licensing RPAs without very serious consideration as to whether or not there would be any real gain in safety standards."
Mr T Geer, Radiation Safety Officer
"While there is a superficial attraction in having a specified training course, such training should be specific to the working circumstances. This means either the statutory training course proposed needs to be very detailed in an attempt to cover all types of work, or it addresses the minimum requirement. I am concerned about possible lowering of standards. Some guidance on training requirements for RPSs has been given by HSE and further guidance on classified workers and RPAs would be welcome."
Mr W J Kean
"Formal training and certification ensures that the safety officer has reached a level of competence for the job."
Mr N Logan
"It would be inappropriate (at least within the Health Service) to introduce examinable training or formal accreditation for classified workers and RPSs, but the requirement of IRR85 on employers to provide adequate training should be reinforced wherever possible. RPSs need good training; unfortunately this is not always carried out. The length and expense of existing formal training courses (albeit very good ones) may contribute to this. It would be very useful if a freely available 'foundation syllabus' for RPSs could be developed with additional 'specific skills' syllabuses for individual specialities. This would assist employers and RPAs in identifying cost effective training for individual RPSs. For RPAs there is a need to be able to demonstrate their competence to practise. Voluntary certification schemes exist, and a move to a portfolio based demonstration of experience gained would be welcome; this is in line with the NVQ approach for Occupational Health and Safety Practitioners. Formal accreditation is desirable but the routes should be flexible."
The Radiation Protection Topic Group of the Institute of Physical Sciences in Medicine
"Competence should be assessed in a positive and professional manner; it is not sufficient to assume that an individual is competent solely on the basis of academic knowledge and period of experience. The employer could be assisted in making sound appointments by looking for qualifications awarded by suitable and reputable bodies. The Society for Radiological Protection jointly with the Institute of Physical Sciences in Medicine is an awarding and assessing body for the Certificate of Competence to Practise and Advise in Radiation Protection... We must emphasise that we see no evidence to suggest that the present system of ensuring competence is failing and there is nothing to justify imposing such a resource-intensive system upon industry as suggested. It would, however, be helpful to recognise the various routes by which competence might be demonstrated and assessed by mention in, say, an Approved Code of Practice. Furthermore, the situation should be kept under review by the regulatory authorities as well as the professional bodies."
Mr P Beaver, Qualifications and Professional Standards Committee, The Society for Radiological Protection
In Issue 7 we gave details of a successful prosecution under Reg 11 of IRR85, and many readers wrote in with comments.
"The implications of the reported prosecutions are of serious concern. The ACOP describes Local Rules as the '...general principles and description...'; a format which we support. Local Rules should aim at simplicity and clarity. The inclusion of a large number of detailed procedures would be counter-productive. A procedure manual may be a separate document to which the Local Rules refer. The requirement to provide written procedures for any specific tasks should be based on an assessment of the hazard involved and the experience/training of the person(s) who will carry out the task, otherwise effort may be diverted into the production of minutely detailed procedures and away from more productive areas of safety."
The Radiation Protection Topic Group of the Institute of Physical Sciences in Medicine
"The dilemma is between making the rules inclusive and concise enough to be displayed close to an event and getting them read. More advice from HSE would be invaluable."
Mr A R Denman, Head of Medical Physics/RPA
"The general advice in the ACOP could be clearer but there is a risk of making it too prescriptive and unworkable in practice."
Dr J G Austin
"It is not reasonable to argue that they should include detailed instructions - this is not what the ACOP is asking for. It would be a retrograde step if such procedures and detailed rules were to have the force of law. I would be alarmed at the resource implications of such a step being taken."
Mr D H Twiss, RPA
"It would be going too far to specifically include general handover in the local rules. The ACOP should be expanded either with more examples of what local rules should contain or a strongly worded section indicating that the local rules need to be more comprehensive."
Mr W J Kean
The Radiation Protection Adviser reaches out across the world! One of our readers in Western Australia has sent a newspaper cutting reporting that a local employer was fined after one of its employees held an x-ray machine in his hand while operating it, when he was supposed to stand at least 20 metres away.
The 18 January 1996 meeting of the Society for Radiological Protection (SRP) will be on radiological protection measurements- are they defensible in the courts? The meeting will be held at the Commonwealth Institute, London.
An article appeared in Issue 4 of the Radiation Protection Adviser about this Council Regulation. In Issue 7 we gave details of the competent authorities for Finland and Sweden. We now have the details of the relevant competent authority for Austria:
Bunderministerium fur Gesundheit und Konsumentenschutz,
HSE priced and free publications are available by mail order from: HSE Books, PO Box 1999, Sudbury, Suffolk CO10 6FS; tel: 01787 881165; fax 01787 313995.
Published for internet 20/11/97