Ionactive blog

The title of our latest blog article might appear cryptic upon first reading - this is deliberately so. This article considers a room which at first glance might appear to be an industrial radiography facility, complete with x-ray tube, active signage, last person out buttons, e-stops and an interlocked shielding door. If it is what it appears to be, then a consent from HSE is required. However, as far as the Ionising Radiations Regulations IRR17 (IRR17) are concerned, what the facility looks like (or what features it contains), does not necessarily determine if a registration or consent is required - it's use determines this (or more precisely the practice being undertaken).

This article will show that whilst the facility may have a certain level of radiation risk (influenced by how it might be operated and the type of x-ray tube and dose rates present ), its use may require a registration and not a consent. A quirk of the regulations perhaps? Whatever the case, over regulation is neither desirable or needed, but there might be cases where certain uses lead to under regulation.

The article will extend the discussion to consider diagnostic x-ray (medical exposures), veterinary use of x-rays, uses of portable x-ray systems and similar.

You have a lush Ionactive banana smoothie filling a 1L (1000 ml) drinking glass. You also have a drinking glass with 1L of Fukushima Daiichi aqueous tritiated (H-3) waste water (at the maximum radioactive concentration of 1500 Bq/L). Which delivers the highest ionising radiation dose, and why? This article contains a short summary statement and a longer explanation (reader choice!). It shows that comparing radioactivity (Bq) between the two choices does not provide the full (or correct) picture (much of the media has got this wrong). Instead we need to compare radiation dose uptake - this is what matters!

An article outlining the new registration system for users of ionising radiation in the UK. Thoughts from Ionactive plus a summary of the main points from the 'The New Consent and Registration Processes (HSE RPA Workshop 13th June 2023)'. This blog entry brings these up and coming changes to the widest audience possible and reveals that it is not only consent holders that will have to supply more information to the UK regulator (HSE). The changes to the registration process are for radiation generators (x-ray systems), and not radioactive substances. The substantive changes are that the regulator will require details of total number of generators, number of premises where they are used, whether they are mobile, and their purpose (e.g. security, quality assurance etc). For medical purposes the changes go further, if generators are used for non-dental purposes then additional details of the modality are required (e.g. numbers of CT systems, mammography, DEXA and so on). None of this information is available to HSE at the moment under the current registration system - the changes will provide the HSE with data to undertake targeted sector specific inspections since they will now know the scale of the work, the locations, and the purpose of the work.

You may have a consent from HSE (a requirement of the Ionising Radiations Regulations 2017) for specified practices in order to work with ionising radiation in the UK (e.g accelerators). You may have multiple uses of ionising radiation which may also require a registration for 'certain practices' (e.g. use of artificial radioactive materials). So everything appears to be in order - or is it? Not all sectors working with ionising radiation are likely to be affected by the subject matter of this article, but perhaps more so by 'default' rather than a conscious decision in some cases. For others, the examples given in this article might encourage you to review what you are working with - just to make sure!

Recently a private school was prosecuted and fined by HSE for exposure to radon gas : "Boarding school fined £50,000 after pupils overexposed to radon radioactive gas". There is a lot of information online regarding radon exposure, so this article does not intend to describe radon from start to finish. Instead we take a look at what we know from the HSE statement and information found in the press, and undertake some exposure / radon concentration estimations. Furthermore, we highlight some particular issues that schools and other workplaces should consider - one is that even where you have a radon potential of < 1% (lowest category), depending on your specific circumstances you could still have a radon exposure problem and you may need to carry out a risk assessment and radon monitoring.

[Main article updated October 2023]. At the time of writing (mid July 2023), ONR have released their guidance on the new IRR17 consent process. We are now awaiting HSE to do the same before October 2023, but our understanding is that ONR / HSE guidance will be practically identical. So Ionactive has been looking at the ONR guidance, and following some interesting comments on various radiotherapy related forums, we are drawn towards the accelerator guidance (safety assessment form). In particular the phrase 'estimates must show that dose rates do not exceed 7.5 micro Sv h^-1 outside any shielded enclosure'. The correct interpretation of this phrase is critical.