This page is about the designation of workers as ‘classified persons’ under the Ionising Radiations Regulations 2017 (IRR17).
The information will be of interest to both:
- those employers who routinely work with ionising radiation
- those employers (including the self-employed) whose employees occasionally work where sources of ionising radiation are present, such as contractors working temporarily on licensed nuclear sites
When classification is appropriate
Radiation employers (those who in the course of a trade, business or other undertaking carrying out work with ionising radiation) are required, under IRR17, to designate as classified persons those employees who are:
- likely to receive an effective dose in excess of 6mSv per year, or
- an equivalent dose in excess of 3/10ths of any relevant dose limit ( of IRR17)
Where this is the case, relevant employees will be made subject to medical surveillance and have their doses appropriately assessed and recorded.
The employee's own employer is responsible for determining whether classification is appropriate. However, duties imposed on the employer are also imposed on the holder of a nuclear site licence so far as those duties relate to the licensed site. In such cases it is important that there is co-operation between employers as required by IRR99.
In determining the need for classification, the employer is likely to need to consider a number of factors and may also consult other parties, including a radiation protection adviser (RPA), to obtain sufficient information to decide whether classification is necessary.
The overarching duty under IRR17 is to restrict exposure so far as is reasonably practicable. Designation of individuals as classified persons should be considered when, despite all reasonable steps having been taken, there remains a likelihood that the dose criteria specified in IRR17 will be reached.
You can find more guidance in Work with ionising radiation: Approved Code of Practice and guidance (L121).
Employees may be required to enter controlled areas as part of their work. Where this is the case, such entry is only permitted to those designated as classified persons or those working in accordance with suitable written arrangements. Written arrangements must ensure that working practices are planned to ensure that radiation doses to individuals are below those levels that would require them to be designated as classified persons.
In accordance with IRR, personal dose monitoring or monitoring by other suitable means is required to demonstrate appropriate restriction of exposure.
Classification should not be used to avoid the work involved in preparing suitable written arrangements.
Considerations
The decision as to who needs to be designated as a classified person should be relatively straightforward where work with ionising radiation is done by employees with a single employer and where exposure of any other employer's employees is unlikely.
The radiation employer should, in consultation with their RPA, carry out an assessment of the risk associated with the proposed work in accordance with IRR17 or regulation 3 of the Management of Health and Safety at Work Regulations (MHSWR).
The output of the risk assessment should be the key to the decision-making process and the need to designate certain employees as classified persons is likely to be one outcome.
You can find more guidance on prior risk assessment in Work with ionising radiation: Approved Code of Practice and guidance (L121).
If an assessment of the potential exposure shows that the work could be done by employees who are not classified persons, HSE would normally expect entry into controlled areas to be allowed under suitable written arrangements.
However, if the assessment of potential exposure shows that restriction of their doses below the levels specified in IRR17 could not reasonably be ensured even with written arrangements, people working in the area should be classified. Entry under suitable written arrangements should not involve a system of work sharing simply to avoid classifying the people working in the controlled area.
Cooperation between employers
You can find more guidance in Work with ionising radiation: Approved Code of Practice and guidance (L121) on the cooperation needed:
- when employers share the same workplace
- if an employee has more than one employer
Exposure caused by other employers' work
If it is likely that an employee will be exposed to ionising radiation in another employer's work area, or as a consequence of another employer's work, then the 2 employers must exchange enough information to allow each to comply with their statutory duties under IRR17 and regulation 12 of MHSWR).
Information regarding both potential and likely exposure to ionising radiation should be shared, along with details of any controlled areas that have been designated on sites to which access is required. This helps employers to judge whether they should classify their workers.
You can find examples of classification where there is more than one employer under dose monitoring.
Employees having multiple employers
Where an employee has several employers, cooperation will be necessary to ensure that relevant information, typically relating to exposure, is shared.
For example, where an interventional radiologist works for both an NHS trust and a private hospital, both employers have a duty to share information in relation to the total dose the employee is likely to receive, to determine whether classification is appropriate. This cooperation should begin in advance of work, because classification relates to projected doses before exposure is incurred.
Checklist for classification
Should the employer decide that designation as a classified person is appropriate, the actions outlined in the checklist should be taken. A periodic review of the continuing need for classification should be caried out.
- Is the employee 18 or over?
- Has an a ppointed doctor (or employment medical adviser) certified the employee fit for proposed work?
- Has the employee been informed that they are a classified person?
- Have suitable arrangements for dose assessment and record keeping been made with the Approved Dosimetry Service?
- Is a radiation passbook required and, if so, has it been provided?
- Has appropriate training been given?