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X-ray use in Cargo / Freight

We have seen a significant increase in enquires from the UK Cargo / Freight industries, particularly related to aviation, who require our Radiation Protection Adviser (RPA) services.  In some cases, this has been driven by visits from the Health and Safety Executive (HSE). Whilst the requirements for compliance have not changed significantly, the new Ionising Radiations Regulations 2017 (IRR17) appear to have driven more enforcement action. In actual fact the requirements for compliance with IRR17 are not that different from  IRR99 (the previous regulations, now repealed, in force from 1 January 2000 - 31 December 2017). 

Why the HSE interest now? 

The IRR17 regulations require new and current users of ionising radiation to formally make an application to HSE. Generally, for most Cargo / Freight x-ray users there will be a requirement to ‘register’ with the HSE, although for some users using more powerful x-ray accelerators there might be a requirement to obtain a ‘consent’. Regardless of application type, the new system provides  HSE with a database of radiation users (something they have not had before). We would not be surprised if the HSE have looked at this database and asked ‘where are all the Cargo / Freight users?’. 

So, if you are in the Cargo / Freight industry using x-ray systems what should you be doing? The short answer is consulting with a Radiation Protection Adviser (RPA). The longer (and more useful) answer follows below. Once you have read this feel free to get in touch with Ionactive (mark.ramsay@ionactive.co.uk  ) and we will help you achieve full compliance with IRR17.

What you need to know

Prior to 1 January 2018, the Ionising Radiations Regulations 1999 (IRR99) were in force. Under those regulations there was a requirement that users of ionising radiation equipment (e.g. x-ray security scanners) inform HSE before first use of that type equipment. There were always requirements for Local Rules, radiation risk assessment, the Radiation Protection Adviser (RPA) and the in-house appointment of a Radiation Protection Supervisor (RPS). In addition, there were requirements for contingency arrangements, adequate training and so on.

One significant change in the new IRR17 is the way that HSE are informed of an employer’s use of ionising radiation. There is now a risk-based approach which includes notify, register or consent (in increasing order of risk). For x-ray equipment typically used in cargo related industries, you are required to register with HSE. Regardless of what you had in place before (including any previous notification to HSE), all employers needed to comply with the new process by 6 February 2018. One of the significant differences in the new approach is that when you apply for the registration you need to ‘sign’ a declaration that you have various IRR17 matters in place. This includes those already noted above, and in particular, consultation with a RPA (who is appointed in writing by the employer). 

A basic set of requirements to have in place can be listed as follows. 

1) Appointment of RPA in writing
2) Radiation risk assessment
3) Local Rules for the equipment*
4) Radiation Protection Supervisor (RPS) for the equipment*
5) Training requirements for operators (radiation safety related)
6) Personal dosimetry  (not normally required)
7) Radiation monitoring around x-ray units
8) Contingency arrangements
9) Maintenance
10) Etc

* For larger x-ray equipment that you can physically walk through (not a good idea when x-rays are on!), Local Rules and a RPS are mandatory. In addition, the tunnel of the x-ray system will be treated as a Controlled Area (designated area).

Regardless of what you know about your own x-ray systems, or your service contractor, HSE will expect that that there is adequate cooperation between you and your contractor when they are on your site. In effect they will expect a formal handover of your x-ray equipment, and a formal hand-back once the service (or repair) is complete. This should be documented. 

Where you have contingency arrangements (e.g. for an x-ray machine failing to cease x-rays, or perhaps an overexposure of an employee), you need to demonstrate that these have been rehearsed. 

Whilst this might seem a lot of additional work – it is not (apart from the initial effort required to get everything in place). If you require an RPA to help you through this process then contact mark.ramsay@ionactive.co.uk  at Ionactive. 

Article Source:

Ionactive Radiation Protection Adviser (RPA) Service

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