For action: Notification: registration - request for further information (re-register your work with radiation generators)

Published: Dec 15, 2023

    Tags:
  • HSE
  • Registration
  • Re-registration
  • radiation generators
  • RADAN
  • x-ray systems
  • Ionising Radiations Regulations 2017
  • IRR17

Notify, registration or consent for work with ionising radiation

There is a new platform from HSE (Health and Safety Executive) for the purposes of notifying, or obtaining a registration or consent for work involving ionising radiation in Great Britain. This process, which went live October 3rd (2023) also covers the provision of further information which might be requested from HSE. So you would use the new service to:

  • Notify, or apply for a registration or consent for the first time.
  • Add additional information which might be requested by HSE.

Nowhere on the HSE website does it ask current users (who have notified or already have a registration or consent) to do anything with new system UNLESS they have been contacted by HSE first. This has already lead to some confusion with users since the second paragraph of the HSE request email (for more information regarding radiation generators) contains the line 'Any users registered with BSSD now need to create a new account and re-register through RADAN'. Our understanding is that this is not the case unless the following apply:

  1. You are an employer using radiation generators AND you have been written to by HSE and asked to re-register your work with radiation generators) and / or
  2. You have a consent for a specified practice (e.g. industrial radiography, operation of an accelerator etc) AND you have been asked to supply more information (including a safety assessment).

[Ionactive note: Whilst the above is 'true', our advice is to contact a Radiation Protection Adviser (RPA) if unsure (as advised throughout this article). The reasoning is that the RPA will know what is expected and this could include circumstances where work with radiation generators should be re-registered, but HSE have not been able to contact the company relevant person to ask for this to be actioned].

Whereas use of the RADAN system for radiation generators simply involves supplying more information (for the new registration), the consent process on RADAN involves a whole new level of regulation (supplying a safety assessment, submitting local rules and contingency arrangements, and 'hosting' HSE during a site inspection).

Some of the history and reasoning for these changes can be found in two earlier Ionactive blog articles - the links are as follows:

New UK Registration process for users of Ionising Radiation (as of August 2023)

New UK Consent process for users of Ionising Radiation (as of February 2023, updated October 2023)

The reader of this article does not need to visit the above links to seek all the information they need - but if you want all the background then feel free to read the linked articles and then come back here.

[Ionactive Note: Since Ionactive is based in England, and we do not generally provide advice to nuclear licensed sites (not since the Imperial College Consort reactor was decommissioned), we have made this article relevant to the HSE process. Nuclear licensed sites will deal with the Office for Nuclear Regulation (ONR) whilst ionising radiation users in Northern Ireland are regulated by the Health and Safety Executive for Northern Ireland (HSENI) . Essentially the advice and guidance is still the same regardless].

Getting onto the RADAN system

General information can be found on the following HSE page : Notify, registration or consent for work with ionising radiation (will open in a new window).

Personally we think it might have been clearer for users if this page had been split - to deal with those employers who need to re-register work with radiation generators, those who are being asked to undertake the new consent upgrade process, and everyone else (notifying, or applying for a registration or consent for the first time). It could then be changed back to something simpler in perhaps 12 months.

Once on the above page you can then click the 'start now' button which takes you into the RADAN system. the link to the system is here: Start Now (will open in a new window). If all goes well you will see the following.

Ionactive HSE Registration Blog 1 sign in

HSE RADAN - entry page

A couple of things to note:

  • The email address (field should really be called username), and password combination, are not the same as for the older BSSD HSE system. Even if you plan to use the same email and password as before, you need to set up a new account the first time you use the system.
  • Beware (!) a few users have found that their browser has autocompleted the fields (with data used for the BSSD system) and so have assumed this was all correct, only to find they could not login.

Setting up an account requires use of a valid email and phone number (for queries etc). So have think about who is the correct person to do this - perhaps a generic email such as [email protected] might be better than an account from a named individual (the same goes for a contact telephone number).

Request for further information (re-register your work with radiation generators)

Ionactive believes that all requests have now been issued by HSE (we are happy to be corrected).

The request email will have gone to the person who used the BSSD system (from 2018 onwards) when the new Ionising Radiation Regulations 2017 (IRR17) came into effect. This is not terribly reliable as employees change their job role, their employment, their email address, and companies change their names, and IT departments change their security and so on.

HSE may have tried to make alterative contact (email to general company address) or perhaps written to the Managing Director or equivalent. However, if in doubt we recommend you contact your Radiation Protection Adviser (RPA) for advice (and this is what HSE expect too).

At the time of writing this blog HSE have not issued any requests to update information relating to:

  • Notifications (e.g. for radon).
  • Registrations (artificial radioactivity).
  • Registrations (natural occurring radioactivity).

The HSE request to re-register work with radiation generators will have come by email with the following wording / format (only an extract is shown graphically).

Ionactive HSE Registration Blog 2 email

HSE email extract - re-register your work with radiation generators

Note the following:

  • The headline reads 'Notification: registration - request for further information'.
  • The email subject line (not shown above) reads 'FOR ACTION: Please Create a new account with HSE and re-register your work with radiation generators'.
  • The second paragraph of the email extract shown above (and highlighted) reads 'RADAN is the new digital platform to replace BSSD from October 2nd, 2023. Any users registered with BSSD now need to create a new account and re-register through RADAN'.

The highlighted text in the above graphic has lead to some users re-registering their radioactive material use (not required or asked for), and in at least one case a user tried to upgrade their consent without being requested to do so! Given there is some work involved in the new consent process, and fees (£1000's), and an HSE inspection, it is not something an employer wants to undertake until asked to by HSE.

Also note that the email headline is a notification for a registration (Notification: registration), but don't confuse notification as used in the email with 'notify' in the RADAN system (they are not the same).

Other highlights of the wording included are as follows.

Our records show that XXX Limited applied for and was granted a registration for the use of radiation generators and were issued with a certificate. The registration number was DEC-XXXX-XXXXXX-XXXX.

[Ionactive: The above text personalises the HSE email to the relevant employer, notes they use a radiation generator (i.e. relates to the email subject line) and specifies the registration number].

Please be advised, if you are now part of a wider practice, contact them first to ascertain if registration has been completed (only one registration is required per legal entity).

[Ionactive: The above text is important and this has always been the case; it is the legal entity which is registered and not the premises. The re-registration process does not ask for addresses of each premises where x-ray generators are used, but does ask for total number of premises and total number of radiation generators in use].

If you have any questions or queries, please reach out to your Radiation Protection Advisor as our operational support team are unable to reply to technical questions.

[Ionactive: We advise employers using ionising radiation to seek advice from their RPA].

By virtue of the powers granted to it under Regulation 6(4)(b) of the Ionising Radiations Regulations 2017 (IRR17), the Health and Safety Executive (HSE) now require you to provide additional information detailed in the appendix to this notification.
You must submit this information using HSE’s RADAN online service within 3 months from the date of this notification. Failure to do so may result in your registration being revoked under Regulation 6(5) of IRR17.
Once you have submitted the information, you will receive a new certificate of registration.

[Ionactive: The above text sets out the legal basis for the information required and the submission deadline (i.e. 3 months from the date of notification). As noted earlier, the use of notification in this letter is for 'HSE notification', and nothing to do with the notification which might be required within the RADAN system].

A full application is required

You are not adding information to an existing registration (which then kicks out a new updated registration). You are completing a full application for a registration. So be prepared to have the following information to hand.

  • Company registration number (i.e. from companies house) - the easy option if you have the number as full address will be added (do check for accuracy).
  • Company name - second best option, if the system has the company on the database it will populate the likely address (again, check for accuracy).
  • If both of the above fail, then you have the option to manually enter the company information. The system may advise that this might cause a delay in issuing a certificate whilst the details are manually checked.

You will also be asked some generic questions (i.e will apply to all types of application), so have this information to hand too.

  • Total number of employees in the company (in bands).
  • Total number of employees in the company working with ionising radiation (in bands).
  • Number of employees who are classified persons (in bands).

[Ionactive note: In many cases employers using radiation generators under a registration will not need their staff designated as classified persons - a risk assessment and RPA advice will determine this. There are exceptions, for example, the use of x-ray fluoroscopy in the medical sector may require classified persons due to potential eye exposure. Don't guess or answer 'yes', seek RPA advice].

When the generic information is successfully added to the system, it will then let you select an application type - and for the purposes of this article you are looking for use of radiation generators under the registration category. It should not be assumed that 'radiation generator' is the obvious choice for all users who make an application (hence the need for RPA advice). A radiation generator means (in most cases) 'x-ray generator / X-ray unit / X-ray cabinet' or similar. However, this could also mean a generator which produces neutrons, electrons or other charged particles. Note that this does not include a radiation accelerator which IRR17 defines as 'apparatus or installation in which particles are accelerated and which emits ionising radiation with an energy higher than 1 MeV'. If required, consider visiting the Ionactive IRR17 resource 'Ionactive guidance: Ionising Radiations Regulations 2017 (IRR17)'.

Appendix - Registration information that must be provided

The appendix to the HSE notification email noted above contains a useful list of information required (i.e. over and above that which was requested for original applications made on the BSSD system). The wording provided is detailed in the list below. This is essentially the same as information contained in our blog article: New UK Registration process for users of Ionising Radiation (as of August 2023) referenced earlier.

Non-Medical Uses

  1. Approximate number (within bands) of radiation generators.
  2. Premises at which the generators are used (number of).

Whether or not any of the radiation generators are mobile.

The main purpose(s) within the following categories for which the generators are used:

  • Baggage or freight inspection
  • Veterinary uses
  • Agriculture or food
  • Security
  • Research
  • Education
  • The examination of objects, antiquities, art or paintings (other than for non-destructive testing purposes)
  • The analysis of items or materials
  • Foreign body detection
  • Level, density or flow gauging
  • Non-medical imaging using medical equipment
  • Other (please state)

[Ionactive comment: Mobile really does mean mobile! An x-ray unit which can be wheeled around a workshop is mobile. The same goes for a handheld portable x-ray device. However, a desktop x-ray cabinet for research or an x-ray screening unit at an airport are not classed as mobile (even if they can be physically moved with some effort) ].

[Ionactive comment: None of the categories noted above should be too difficult to choose from, but if in doubt talk to your RPA or make use of the 'other' category. Note that veterinary users of x-ray equipment should choose 'Non-medical imaging using medical equipment' - since most of the equipment they use will be exactly the same as found in a hospital, but the imaging of non-human patients is not considered a medical exposure].

Medical and Dental Uses

If you use radiation generators only for dental purposes.

Approximate number (within bands) of:

  1. Radiation generators.
  2. Premises at which the generators are used (numbers of).

If you use radiation generators for other medical purposes (which may include dental purposes).

Approximate total number (within bands) of:

  1. Premises at which generators are used (numbers of)
  2. Computed Tomography (CT) scanners
  3. CT Scanners used in connection with radiotherapy
  4. Generators used for general radiography
  5. Generators used for dental purposes
  6. Generators used for mammography
  7. Dual Energy X-ray absorptiometry (DEXA) devices
  8. Generators used in interventional and cardiology procedures

Mark Ramsay

Radiation Protection Adviser for Ionactive Consulting Limited.

Chartered Radiation Protection Professional.

December 2023.

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