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