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L121 has gone blur-ple!

Those of you who have recently ordered a copy of ‘Work with ionising radiation' (L121) which includes the Ionising Radiations Regulations 1999, the Approved Code of Practice (ACOP), and supporting non-statutory guidance may have noticed a change in cover to this publication. The photographs of a range of ionising radiation applications which used to adorn the front cover of L121 are no more, replaced by something best described as blurry and purple. Rest assured that the front and back covers are the only changes, with the actual content of L121 remaining as it was. What drove the change? Well, original L121 stocks were running low so a re-print was necessary and along with the reprint came HSE's current style of branding and formatting for its publications. Enough said.


Complacency leads to accidents: MONITOR

HSE has recently completed an investigation of the loss of control of a high activity caesium-137 radioactive source, which was dropped during transfer from a transport container into a tool. The failed transfer went unnoticed for several hours because key workers did not carry out source location confirmation checks using radiation monitoring instruments. They therefore had no way of knowing that the radioactive source had been safely transferred.

It was fortunate for the Company and employees who might otherwise have been grievously exposed to radiation, that the source was found and recovered in a relatively short period of time. Radiation fields around the source posed a risk of deterministic injuries being sustained by workers in the vicinity if it had not been identified and recovered very quickly.

Source location confirmatory monitoring during source movements and relocation are fundamentally important elements of any safe system-of-work for these tasks and must always be carried out at key stages during their completion: high-activity source location should never be assumed but rather confirmed, where practicable, by radiological measurement.

HSE would like to remind all users who work with mobile radioactive sources that they should not become complacent when carrying out routine operations and, in particular, carrying out confirmation checks and surveys with radiation monitoring instruments.


Nuclear Safeguards Reporting for UK ‘Small Users'  

The aim of international safeguards in the UK is to ensure that civil nuclear materials (uranium in all its forms, plutonium and thorium) are not diverted from their declared peaceful uses. The basic components of the safeguards regime are the provision of information to the safeguards inspectorates of the European Commission and/or the International Atomic Energy Agency (IAEA), and inspections by those bodies to verify the completeness and correctness of the information reported to them.

Safeguards requirements for small users of nuclear material in the UK (i.e. outside the major nuclear facilities) are set out in the Treaty Establishing the European Atomic Energy community (the Euratom Treaty) 1957, with the reporting requirements amplified in Commission Regulation (Euratom) No 302/2005. Article 19 of the latter provides for reduced ('derogated') reporting, in a simplified format and at reduced frequency compared with the full requirements of the regulation, by certain small users. This means, in essence, that once the European Commission has granted a derogation, a straightforward annual report (according to the format of Annex X to Regulation 302/2005) should be all that is required unless material is transferred into or out of the European Union.

Nuclear materials accounts that show how much nuclear material is where, are fundamental to safeguards reporting, and such reporting should be a relatively straightforward product of the nuclear materials accountancy arrangements which should already be in place to meet UK domestic requirements (e.g. as set-out in respect of the Ionising Radiation Regulations 1999 and the Radioactive Substances Act 1993). The European Commission has, moreover, developed the Euratom Nuclear Material Accountancy System (ENMAS) Light software application for ‘Small Users' which can be used to create the reports required by Regulation 302/2005.

The European Commission safeguards inspectorate also has the power to perform on-site inspections to confirm (‘verify') the information reported to it. Such inspections for small users in the UK are infrequent however (e.g. a total of 6 in 2007) and will normally be accompanied by a representative from the HSE UK Safeguards Office (UKSO).

HSE(UKSO)'s role includes working with UK organisations subject to safeguards requirements and the international safeguards inspectorates of the European Commission (and the IAEA), so that safeguards obligations for the UK are met in a proportionate manner.  

All reports and correspondence to the European Commission should be sent via the HSE (UKSO) at 7th Floor North Wing, Rose Court, 2 Southwark Bridge, London  SE1 9HS. For further information view the website.


REPPIR - A Reminder

The Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) came into force on 20 September 2001 and was amended in 2007 removing transportation by rail from the requirements of the regulations.

REPPIR requires operators of premises where work with ionising radiation is carried out and those who transport radioactive sources through public places (other than by standard forms of transport) which involves handling more than specified quantities of radioactive substances, to carry out a hazard identification and risk evaluation (HIRE). The purpose of this is to determine whether a ‘radiation emergency' is reasonably foreseeable. A radiation emergency is a radiation accident in which a person, not present on the premises where the radiation emergency occurred and who is not involved in any intervention activity, could receive an effective dose of 5mSv within a year of the emergency. Where radiation emergencies are reasonably foreseeable there are requirements for the development of emergency plans (including off-site emergency plans prepared by local authorities), for review and testing of these plans, and for consultation.

To determine whether REPPIR applies to your work or transport activities you should check your holdings of radioactive material to ensure that the quantities do not exceed the application levels for the regulations. This must also include radioactive materials which are being stored temporarily for example at ports or airports. If the regulations apply you will need to carry out a HIRE to determine whether or not a radiation emergency is possible.

There is also an ongoing requirement for those organisations who have submitted a HIRE to carry out a review at three yearly intervals. If there are no substantive changes a declaration to that effect must be sent to HSE. In addition if any material changes to the work with ionising radiation to which the HIRE relates is planned, then a further assessment must be carried out and a report of the assessment must be sent to HSE 28 days prior to the implementation of the material change.

So, to recap:


EC proposal to Recast the Basic Safety Standards (and other Euratom) Directives 

i. Participating in development of the UK influencing strategy and negotiating position

As described in the RP News article of 22 September 2008, the European Commission (EC) intends to bring forward a formal proposal for a new Euratom Basic Safety Standard Directive which will be based on a recast and consolidation of the following five existing Directives and one Recommendation:

Account will also be taken of the International Atomic Energy Agency Basic Safety Standards (currently being revised) and the latest International Commission on Radiological Protection (ICRP) recommendations.

The EC Working Party (WP) of its Article 31 (A31) Group of Scientific Experts hopes to complete a new draft Directive by November 2009.

Since current Euratom Directives are implemented in the UK by a range of regulations enforced by HSE and other government departments, HSE has convened a cross-Government group to co-ordinate the UK Response. The HSE team will be working with this group and are keen to engage all UK stakeholders to ensure that a breadth of interested parties views inform the development of the UK influencing strategy and negotiating position.

ii. EC consultation on natural radiation sources

The EC is consulting on proposals for the new BSS regarding naturally occurring radioactive material. The Commission have published a document which sets out Commission Services views on reports from an A31 (Natural Sources) Working Party. The document covers: ‘present requirements for radiation sources and suggested amendments'; ‘Radon in dwellings'; and ‘building materials containing natural radioactivity'.

The consultation will provide background material for the ongoing process of recasting the BSS (Euratom) Directives, and one recommendation. The Commission will report the results of the consultation to the A31 Group of Experts, and reflect them in an Impact Assessment in due course.

The consultation is now in progress. HSE will be coordinating cross Government comments for submission to the European Commission. Individual stakeholders may send their comments directly to the Commission at
TREN-LUX-H4-BSSRECAST@ec.europa.eu

The consultation period ends on the 20 April 2009.


Accessing information on international nuclear and radiological events and learning lessons

The Nuclear Events Web-based System (NEWS) is a joint project of the International Atomic Energy Agency (IAEA), the OECD/NEA (Nuclear Energy Agency within the Organisation for Economic Co-operation and Development) and WANO (World Association of Nuclear Operators) that provides fast, flexible and authoritative information on the occurrence of nuclear and radiological events (rated using the INES scale) that are of interest to the international community.

Reading the NEWS Event Detail(by logging in as a guest user) is worthwhile for RPAs, training providers, dutyholders and radiation users and usually provides a stark reminder of what can and does go wrong when effective measures are not in place to manage radiation work. Recent non-nuclear events include a failure to monitor effectively during site radiography resulting in a dose of 110mSv to an individual, and in a separate event, a skin overexposure to a workers' hand of between 1.2 and 1.9 Sv during radiopharmaceutical preparation. The latter is understood to have occurred when ‘the employee unknowingly came into contact with a contaminated item during his pre-production preparation.' The report comments that the wearing of gloves was not required for this task at the time.


Other offerings from HSE

Now that you are familiar with HSE's eBulletin system, you may be interested in signing up to other HSE eBulletin offerings, radiation-related or otherwise. Worthy of particular mention to this readership are the two nuclear eBulletins, which cover all nuclear safety, security and new reactor build issues.

Updated 2015-06-22