The main concerns are that a significant number of non-destructive testing contractors fail 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. HSE is taking forward a number of initiatives aimed at improving this sectors performance at managing radiation protection. This includes a free information sheet 'Industrial radiography - managing radiation risks' Ionising Radiation Protection sheet IRP1 and an inspection and advice programme.
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.
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 undertaken by a specifically trained HSE Inspector and will only be granted if there is a genuine emergency.
Duty holders can apply for three different types of waiver: emergency waiver, embedded waiver and periodic waiver. Detailed guidance on the three types of waivers and their requirements can be found here: HSE Guidance on Site Radiography Waivers
Waivers requested during office working hours
If you need to request a waiver during office working hours (ie 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, and ONLY in these circumstances, you may commence work as long as you can satisfy both of the following:
[a] 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.
[b] 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].