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