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IRR99 Guidance - Part 6 - Control of Radioactive Substances

IRR99 (31) - Duties of Manufacturers etc.

Application

IRR99 (31)(1) extends the provisions of the Health & Safety at Work etc Act 1974 (HSWA) in relation to work involving ionising radiation, and IRR99 (31)(2) requires that an appropriate critical examination of equipment is undertaken after installation. This regulation applies to suppliers of material goods, i.e. ‘articles’ or  radioactive substances.

IRR99 (31)(1) does not apply to those undergoing a medical treatment or examination which involves ionising radiation.

Duties of manufacturer / supplier etc

The aim of this regulation is to ensure that due consideration if given to radiation protection throughout the supply chain, i.e

  • design
  • through to manufacture
  • during supply
  • at the point of installation.

The Radiation Protection Supervisor (RPS) and Radiation Protection Adviser (RPA) are likely to be involved, with the installer, during the critical examination.

For the purposes of this regulation, and its link with HSWA, a supplier can be defined as someone who supplies articles or substances by:

  • sale
  • lease
  • hire (regardless of being a principle or agent in the supply chain) 

In this context the supplier will include:

  • designers
  • manufactures
  • importers
  • installers
  • erectors

In addition, an article can be defined as something that is designed for use by a person at work and will include:

  • plant
  • machinery
  • equipment
  • any component of any article defined above

In the above definitions is should also be noted that an article will include equipment that produces adventitious radiation as well as intentional radiation.

Substances in the context of this regulation will mean:

  • a sealed source containing radioactive substances
  • an unsealed source containing radioactive substances
  • radioactive contamination within the article

The regulation requires that radiation protection considerations are incorporated into the design and construction stages of manufacture and are not left to the end user. Therefore, an RPS should not be put in a position of having to advise on radiation protection improvements for a new piece of 'off-the-shelf' equipment - if that equipment is of poor design.

Critical examinations

There is no legal requirement for the RPA (or RPS) to be directly involved in any critical examination. However, it is a requirement that the RPA:

  • advises on the nature, scope and extent of the critical examination
  • gives advice on the results of any examination; ensuring that the safety features and devices designed to restrict exposure are functioning as intended
  • advises on how the results should be presented and retained

In general when a new article arrives on site which emits ionising radiations (whether entirely contained or otherwise), the person installing shall where appropriate, undertake a critical examination of the way that it was erected or installed, for the purpose of ensuring in particular:

  • the safety features and warning devices operate correctly
  • there is sufficient protection for persons from exposure to ionising radiation
  • the article operates as intended (i.e. as designed)

The installer should consult with an RPA appointed by himself, or by the radiation employer (where the article is being installed), with regard to the nature and extent of the critical examination and the results of that examination.

The installer should also provide the employer (who will use the article) with:

  • adequate information about its proper use
  • the routine testing and maintenance required
  • a written record of the examination

In reality the RPS at the site when the equipment is being installed is very likely to be involved in the critical examination, if only to ‘supervise’ the work if it’s taking place in a designated area. Furthermore, in many cases the RPS is also the user of the article and so will have a personal interest in knowing that its has been installed and tested correctly.

The critical examination should test the article under the most extreme conditions likely to be encountered in normal usage and check that all safety features / interlocks / signs and signals are operative

This requirement for testing applies only to those aspects of the equipment that have a bearing upon radiological protection.  Where articles are supplied for use in work with ionising radiation that have wider areas of application, then unless specific contractual arrangements have been made regarding suitability, the responsibility for testing will reside with the employer who is the customer, rather than the supplier.

An example of this might be a fan motor which is used as part of a ventilation system which controls radioactive material in the workplace.



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