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Health and Safety Executive Ionising Radiations Regulations 2017 New Provisions etc. James Taylor Principal Specialist Inspector (Radiation) Tel: 07879 661820 email: [email protected]

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Health and Safety Executive

Ionising Radiations Regulations

2017

New Provisions etc.

James Taylor

Principal Specialist Inspector (Radiation)

Tel: 07879 661820

email: [email protected]

Graded Approach

• Reg 5: Notification of certain work

• Reg 6: Registration of certain practices

• Reg 7: Consent to carry specified

practices

Practice

• “practice” means work involving—

• (a) the production, processing, handling,

disposal, use, storage, holding or transport

of radioactive substances; or

• (b) the operation of any electrical

equipment emitting ionising radiation and

containing components operating at a

potential difference of more than 5kV,

– which can increase the exposure of

individuals to ionising radiation

IRR17 Notification

• Small quantities of radioactive material

• Radon

• Simple electronic system

• Who, what, where

• Transitional arrangement

– Will have until Feb 2018 to notify

HSE Registration

• the operation of radiation generators or

accelerators or radioactive sources for medical

exposures or for non-medical imaging purposes

• the operation of radiation generators or

accelerators, except electron microscopes, or

radioactive sources for purposes not covered by

point (a).

• This will cover the majority of practices –

approximately 28,000 dutyholders

• Only one registration required for multiple

practices

IRR17 Registration

• Electronic system with £25 fee

• Require submission of information/confirmation –

on the basis of around 8-10 questions.

• Give assurance to HSE that permission can be

granted – determine risk profile to inform

inspection

• Conditions of registration

– 1. Notify HSE of material change

– 2. Comply with the IRR17

• Must be registered by Feb 2018

Registration: Indicative Questions

• Confirmation that you have completed a risk

assessment to identify the main radiological risks

associated with your work and identified any

reasonably foreseeable radiation accident ?

• Confirmation that you have identified and

completed actions that will restrict your

employees’ and other persons exposure to

ionising radiation to a level which is as low as

reasonably practicable?

• Confirmation that you have drawn up

contingency plans for any reasonably

foreseeable radiation accident?

• Confirmation that you have provided

adequate training to those of your

employees engaged in work with ionising

radiation and those likely to be affected

by that work?

• Confirmation that you have, where legally

required, designated and demarcated

controlled and supervised areas?

• Confirmation that you have taken steps to

measure and/or estimate your employees’

exposure to ionising radiation?

• Confirmation that you have, where legally

required, drawn up written local rules and

appointed radiation protection

supervisor(s)?

• Confirmation that you have consulted an

RPA as to the observance of the IRR17?

IRR17 Consent

Occupational exposure aspects of:

• the deliberate administration of

radioactive substances to persons and, in

so far as the radiation protection of

human beings is concerned, animals for

the purpose of medical or veterinary

diagnosis, treatment or research

• the deliberate addition of radioactive substances

in the production or manufacture of consumer

products or other products, including medicinal

products, and the import of such products

• any practice involving a high-activity

sealed source;

• the operation, decommissioning and

closure of any facility for the long term

storage or disposal of radioactive waste,

including facilities managing radioactive

waste for this purpose;

• practices discharging significant amounts

of radioactive material with airborne or

liquid effluent into the environment.

• IRR17 also requires consent for

– Industrial radiography

– Work with particle accelerators

– Industrial irradiation.

IRR17 Consent

• Digital/electronic with £25 fee

• Require submission of information/confirmation –

on the basis of around 20 questions

• Separate consents for each practice

• Conditions of consent

– 1. Notify HSE of material change

– 2. Comply with the IRR17

• Employers will have to gain consent by Feb 2018

Consent: Indicative Questions

• Confirmation that the overall

management, planning, organising,

controlling and reviewing of this radiation

risk have been considered

• Confirmation that they have appointed

and consulted with a suitable radiation

protection adviser (RPA)

• Confirmation that those engaged in the

practice have received appropriate

training in radiological protection

• Confirmation that those engaged in the

practice have been informed of the

radiological risks to their health from the

practice and the precautions that should

be taken

• Confirmation that those engaged in the

practice will receive regular

updates/refresher training in radiological

protection

• Confirmation that those employees not

engaged in work with ionising radiation

but who are likely to be affected by it have

received appropriate training in

radiological protection.

• Confirmation that the design features;

engineering controls; and safety features

of the facility and the radiation sources

are such that exposures to radiation will

be as low as reasonably practicable

(ALARP)

• The maximum anticipated total annual

effective dose( in mSv) to an employee

engaged in the practice

The maximum anticipated total annual dose

equivalent (in mSv) to an employee

engaged in the practice for:

(i)Lens of the eye

(ii)Extremities

(iii)Single organ or tissue

• The maximum anticipated total annual

effective dose (in mSv) to an employee

not directly engaged in the practice

• The maximum anticipated total annual

effective dose (in mSv) to a member of

the public

Confirmation that a prior risk assessment has been completed

that has identified:

(i) ways in which potential exposures or accidental and

unintended medical exposures could occur;

(ii)the probabilities and magnitude of potential exposures

to the extent practicable

(iii)the quality and extent of protection and safety

provisions, including engineering features, as well as

administrative procedures required to all exposures

ALARP;

(iv)the operational limits and conditions of operation

• Confirmation that contingency plans for all

reasonably foreseeable radiation accident

have been drawn up and that they are

rehearsed at suitable intervals

• Confirmation that the applicability of

REPPIR has been

considered……..subsidiary questions

• Confirmation that a maintenance, testing,

inspection and servicing regime is in

place which ensures that the radiation

source and the facility continue to meet

the design requirements, operational

limits and conditions of operation

throughout their lifetime

• Confirmation that the management of any

radioactive waste will ensure that

exposures to employees will be ALARP

• Confirmation that the management of any

disused source or radiation generators

will ensure that exposures to employees

will be ALARP

• Confirmation that where appropriate

suitable and sufficient quality assurance

regimes are in place

IRR17 Reg 13(2)(d)

• if circumstances arise where it is necessary for some or all

of the arrangements in the (contingency) plan to be carried

out:

– the cause of those circumstances is analysed to

determine, so far as is reasonably practicable, the

measures, if any, required to prevent a recurrence of

such circumstances;

– a record of such analysis is made and kept for at least

2 years from the date on which it was made; and,

– any exposure which occurs due to the above

circumstances is noted on any relevant dose record.

IRR17 Reg 12: New Eye Dose

Limit

• From 150mSv to 20mSv per year with

classification level at 15mSv

• Probable increase in the number of

classified persons in the medical sector

– Limited increase in costs due to current

dosimetry arrangements

• Greater demand for personal eye

dosemeters

Radon

• Radon

– Reference/notification level changes

from 400Bqm-3 over any 24 hour period

to 300 Bqm-3 annual average

– In effect, no significant change

• GB will need Radon National Action Plan

– PHE lead

• Notification required at or above this level.

Carers and Comforters

• Remains in final version of IRR17

• May change if HSE Senior Managers give

consent for carer and comforter issues to

be moved to new IR(ME)R

– Need assurance that DoH and DAs

have the resources, expertise and

viries.

Unlikely before December 2017

Equipment used for medical

exposure

• Reg 32 IRR99 (now Reg 33 IRR17)

retained in final version of IRR17

• May change if HSE Senior Managers give

consent for Reg 33 IRR17 to be moved to

new IR(ME)R

– Need assurance that DoH and DAs

have the resources, expertise and

viries.

Unlikely before December 2017

Other changes

• IRR99 referred to a radiation employer

• IRR17 refers to an employer or an a

employer engaged in work with ionising

radiation

– Thus in some cases IRR17 apply to an

employer even though they are not

engaged in work with ionising radiation

• “non-classified outside worker” means a

person who is not a classified person who

carries out services in the supervised or,

pursuant to regulation 19(2)(c)(i),

controlled area of any employer (other

than the supervised or controlled area of

their own employer);

• “outside worker” means a classified

outside worker and a non-classified

outside worker

Reg 15 Information, instruction

and training

• (i) the risks to health created by exposure to

ionising radiation as a result of their work;

• (ii) the general and specific radiation protection

procedures and precautions which should be

taken in connection with the work with ionising

radiation to which they may be assigned; and

• (iii) the importance of complying with the

medical, technical and administrative

requirements of these Regulations;

• Those working in a controlled area must

be given specific training in connection

with the characteristics of the workplace

and the activities within it.

• The giving of training and information

under this regulation must be repeated at

appropriate intervals and documented by

the employer

Reg 18: Local rules and radiation

protection supervisors

• An employer must provide the means

necessary for the radiation protection

supervisor to perform their role