Industrial radiography

Replacement Regulations

On 1 January 2018 the Ionising Radiations Regulations 2017 (IRR17) replaced the Ionising Radiations Regulations 1999 (IRR99).

You can find details of legal requirements in Ionising Radiation Regulations 2017 Approved Code of Practice and guidance.

The main concerns were that a significant number of non-destructive testing contractors were failing to adopt routine working practices capable of keeping radiation exposures of employees as low as reasonably practicable: this is the main requirement of the Ionising Radiations Regulations 2017 (IRR17).

Incidents occur because of:

• poor job planning (most notably with site radiography)
• failure to use adequate local source shielding (collimation), or
• inadequate systems of work

To help dutyholders manage radiation protection, there is an information sheet: Industrial radiography - managing radiation risks' Ionising Radiation Protection sheet IRP1.

Industrial radiography cabinets

Regulation 2(1) of IRR17 defines industrial radiography as: ‘the use of ionising radiation for non-destructive testing purposes where an image of the item under test is formed (but excluding any such testing which is carried out in a cabinet which a person cannot enter)’.

There are two key questions here:

• Is an image being taken?
• Can a person enter the cabinet?

To answer the first question, if you are forming an image of the item under test to check the efficacy or look for defects then you are carrying out non-destructive testing.

The second question has been open to interpretation and the decision ultimately decides whether a dutyholder requires registration or consent under IRR17:

• where a person can enter a radiography cabinet, consent for industrial radiography would be required under IRR17 Regulation 7(1)
• where a person cannot enter a radiography cabinet, registration for work with radiation generators would be required under IRR17 Regulation 6(1)

To help dutyholders, HSE defines someone being able to enter a radiography cabinet as:

‘A person being able to reasonably step into the cabinet and stand inside with the door closed. No crawling, shuffling or excessive contortion would be required for the person to get inside.’

This definition applies whether you intend for people to take the action described or not.

HSE have reviewed several radiography cabinets and the following table indicates where it has decided whether they would require consent or registration.

X-ray cabinets that would require consent or registration – September 2025

Site radiography contractors

Site radiography contractors must receive written notification of the radiography work from their client at least 7 days in advance of the work taking place. This is a condition of the radiography contractor's consent certificate (as required by Regulation 7 of IRR17).

This period of time is deemed necessary to enable consultations between client and contractor to take place, to review risk assessments and to allow any necessary variations to be incorporated into the local rules. These processes must be built into the planning of the job. There is no requirement to notify HSE of site radiography work if this 7 day advance notification can be met.

Waivers

If the client is not able to allow 7 days between notifying the site radiography contractor of the work and it is commencing, the site radiography contractor will need to apply to HSE for an emergency waiver. Considering a waiver request is a job carried out by a specifically trained HSE inspector and will only be granted if there is a genuine emergency.

Dutyholders can apply for 3 different types of waiver:

• emergency waiver
• embedded waiver
• periodic waiver

There is HSE guidance on site radiography waivers and their requirements.

Waivers requested during office working hours

If you need to request a waiver during office working hours (9am – 5pm, Monday to Friday), please send an email request to [email protected] with:

• a brief outline of the reason for the waiver request
• contact details for the client
• site radiography work location
• expected duration of work
• details of your industrial radiography consent certificate number

If you need further assistance during office working hours, queries can also be sent to [email protected]

Waivers requested out of office working hours

If you need to apply for a waiver for emergency work out of office hours and public holidays, there will be no appropriate HSE staff on duty to consider the request. In these circumstances only, you may commence work as long as you can satisfy both of the following:

• you liaise fully with your client and relevant authorities in control of the site regarding your arrival, the assessment of non-radiological risks present on site, the radiological risks associated with the proposed work, and restriction of access to your controlled area(s). Any further work not included in this notification will be subject to the usual 7-day notification requirement
• you ensure HSE is notified that the work has been carried out by sending an email with the required information about the work to [email protected].