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Radiation Safety Advice - Do I need a RPA? Do I need Local Rules or a RPS?

Difference between a Radiation Protection Adviser (RPA) and a Radioactive Waste Adviser (RWA)?

The post of Radioactive Waste Adviser (RWA) must not be confused with the role of the Radiation Protection Adviser (RPA). Confusion may arise since the RPA had provided the role of a RWA – all but in name, prior to 2012. In fact, in many cases your appointed RPA continues to do exactly what they did before (with respect to radioactive substances and waste disposal), but they will do this whilst wearing their specific ‘RWA’ hat. In addition, the Radioactive Waste Adviser should be appointed in writing – in most cases this can be added to the traditional RPA appointment letter (unless the roles of RPA and RWA are undertaken by different individuals).

Radiation Protection Adviser (RPA)

The Radiation Protection Adviser is a requirement of the Ionising Radiations Regulations 2017 (IRR17) which deals with the safe and compliant use of all sources of ionising radiation (sealed and unsealed radioactive sources and all forms of electrically generated ionising radiation). These regulations deal with employee and public safety, and this is primarily what the RPA provides advice on.

For users who work with radioactive sources (either sealed or unsealed) or radioactive waste, there is a requirement for have permits in place. These permits contain a number of conditions that the user must comply with. Traditionally the RPA has provided advice on compliance, and early permits (and the former Registrations and Authorisations) made reference to consulting a RPA or other suitable person (Qualified Expert). Indeed at the EU level there was never any distinction between a RPA or RWA – only the term Qualified Expert is recognised.

With the recent changes to radioactive legislation in the UK i.e. retention of the Radioactive Substances Act 1993 (RSA 93) in Scotland, and the Environmental Permitting (England and Wales) Regulations 2016 in England and Wales, the role of the Radioactive Waste Adviser (RWA) has been formally adopted. A RPA can only now act as a RWA if they have approval from the UK Environmental Agencies.

Radioactive Waste Adviser (RWA)

A Radioactive Waste Adviser (RWA) is a specialist in radioactive waste disposal and environmental radiation protection. Through certification they have demonstrated competence against a Radioactive Waste Adviser syllabus which has been developed by the UK Environmental Agencies.

All users of radioactive material which leads to the actual or potential accumulation or dispose of radioactive waste need to appoint a RWA. Except in rare cases (i.e. where out-of-scope or exemption criteria applies), if you have a permit issued under the Environmental Permitting (England and Wales) Regulations 2016 or an Authorisation issued under the Radioactive Substances Act 1993 (Scotland), then you must have a RWA in place, and appointed in writing.

Before appointing a RWA you should ensure that they are certificated to act as such. This is a similar process to ensuring that you check the RPA is competent to act in the role (e.g. via a RPA 2000 certificate). In both cases the certification only proves competence – the user / employer is responsible for ensuring that the RPA / RWA is suitable for a specific case.



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