I need a Radiation Protection Adviser (RPA) and Supervisor (RPS) 24/7! Do I really need this?
Published: Apr 26, 2025
Prelim
The idea for this blog article was prompted by a recent tender invitation (which we will outline - suitably sanitised). We have also come across this issue during other enquiries for Radiation Protection Adviser (RPA) services, and during regulator (HSE) inspections of employers working with ionising radiation. The RPA and Radiation Protection Supervisor (RPS) are important positions for compliance with the Ionising Radiations Regulations 2017 (IRR17) - so much so that each must be appointed by the employer (radiation user) in writing. However, neither replace the need for personnel within the company, who in some way work with ionising radiation, to have sufficient information, instruction and training, and this will include rehearsal of contingency plans - and implementing the plan if required.
Tender - A company in the Gulf requires an RPA to provide remote (desktop) advice 24/7. The potential client is working with multi-phase flow meters (typically containing Cs-137 radioactive sources in the GBq range), and also conducts some NDT type processes (using Ir-192 in the 10's GBq range). The RPA needs to be certificated by RPA2000, be a member of a professional institution (such as the Society for Radiological Protection - SRP), and have relevant experience with these types of radiation use.
Ionactive - We have offered 24/7 RPA cover on a case by case basis for a specific short term period (days - to perhaps a week, including time as an Emergency Controller for a nuclear licenced site) - for particular contracts, but we do not tend to offer an on-going 24/7 RPA response on an annual contract basis. Why not? There are two main reasons:
- 1 - We are not in a position to offer on-going 24/7 RPA cover (where advice / response is required at the end of the phone / email at any time) for multiple clients.
- 2 - There are very few uses of ionising radiation in the UK or beyond that need 24/7 access to the RPA. Some exception to this are given below, and in some parts of the world availability of 24/7 advice may be a legal requirement.
[Ionactive comment: Notwithstanding (1) above, the Ionactive mobile phone is permanently welded to the hand of it's user (Mark Ramsay), and RPA advice is likely to be available 24/7. However, this best endeavours support is not the same as being contracted to provide 24/7 advice.]
Obvious exceptions - There is a requirement to have SQEP (suitably qualified and experienced persons), including the RPA / RPS, on a 24/7 basis for UK nuclear licensed sites (typically nuclear power plants, fuel reprocessing, atomic weapons production and similar). Not only do these tend to operate 24/7 anyway, many will be subject to REPPIR (Radiation (Emergency Preparedness and Public Information) Regulations 2019) and therefore require an on-site and offsite response to a radiation emergency (requiring a SQEP team including the RPA and RPS). In addition some suppliers may specifically provide a 24/7 emergency response and recovery service (e.g. transport of radioactive consignments by road or nuclear weapon movements) - this may include continuous RPA / RPS support.
Notwithstanding the above exceptions, there are few uses of ionising radiation which we believe require access to an RPA (or RPS) 24/7. The argument for round-the-clock RPS access is stronger (assuming the use of ionising radiation is 24/7), but this is not absolute (in all cases) - as discussed later below. Ionactive is RPA to the biggest user of radioactive sources outside the UK nuclear industry - and their sites do not require 24/7 access to RPA advice. If they did - then something would be clearly wrong with their local rules, risk assessment, contingency plans and training.
So returning to the tender. We politely declined (if the company were UK based we might have given them some free advice to ponder). What follows is a breakdown of some of the issues raised, and other related matters.
RPA & RPS 24/7 - Do I really need this?
Role of the RPA and RPS
Before looking at need, frequency and availability of access, we will briefly summarise the two roles as far as the UK IRR17 is concerned. Ionactive has plenty of resource on these important appointments for radiation protection, so we will point you towards further information if you would benefit from a deeper review.
Role of the RPA
The Radiation Protection Adviser (RPA) is appointed in writing by most UK users of ionising radiation - as required by IRR17. The RPA is required to provide formal advice to the employer. Mandatory consultation is required for the following matters (IRR17 - schedule 4):
- Advice on controlled and supervised areas.
- Advice on new or modified radiation sources, and associated plant and equipment.
- Advice on the use and calibration of radiation / contamination monitoring equipment.
- Advice on the examination, maintenance, investigation and testing of engineering controls (interlocks, warning features and design aspects) for restriction of exposure to ionising radiation.
In addition to the mandatory consultation outlined above, advice may also be sought on any matter of IRR17 including radiation risk assessment, local rules, restriction of exposure (ALARP) and the development and rehearsal of contingency plans.
Normally the delivery of advice based on the above matters be by arrangement (e.g. visit / telephone / email). For some of the larger radiation users (e.g. nuclear industry / NHS / Universities) the RPA will often be employed directly, otherwise the RPA will be an external consultant appointment under contract. Regardless of any formal agreement or schedule where the RPA may be consulted, there is usually provision to provide ad hoc advice as and when required.
Additional details on the RPA can be found at the following Ionactive links (will open in a new window):
- What is an RPA (Radiation Protection Adviser)?
- Do I need a RPA (Radiation Protection Adviser)?
- IRR17 (14) - Radiation Protection Adviser (RPA) (Ionactive IRR17 guidance)
Role of the RPS
The primary role of the Radiation Protection Supervisor (RPS) is to assist the employer in ensuring that the arrangements set out in local rules are complied with. It follows that local rules will be in place (as a prerequisite for appointing the RPS). It further follows that local rules are required because the employer has one or more designated areas (principally controlled areas). [i.e. Controlled designated area → Local Rules → RPS].
The local rules will contain the following mandatory items:
- Details of the management and supervision of the work.
- Information, instruction and training requirements.
- Dose investigation level.
- Reference to the arrangements required by the contingency plan.
- Name of the appointed RPS for the area.
- Identification and description of the designated area.
- Arrangements / working instructions for restricting exposures.
[Ionactive comment: Over the last few years particularly, there has been a tendency to designated the interior of small cabinet x-ray systems- regardless of access potential when x-rays are being generated. This has been driven more by the regulators than the RPA. If a designated area exists, then all of the above (local rules / RPS etc) apply.]
With reference to the above list, and noting the next section coming up, the RPS should be aware of the contingency plan - including the actions to be taken in the event of a radiation accident. One of the supplementary roles of the RPS (the employer is ultimately responsible for this), is to ensure that those that need to read, understand and comply with the local rules, have done so. This will effectively include all those that work with ionising radiation in some way (so might also include contractors).
Note that IRR17 - 18(5) ACoP (para 350) of the guidance suggests that it 'may not always be necessary for an RPS to be present all the time' (the range, complexity, working shifts and similar can be taken into account when deciding on the number of RPSs, and where and when they will be present).
Additional details on the RPS can be found at the following Ionactive links (will open in a new window):
Why might you need (or assume) you need access to the RPA or RPS 24/7?
As noted above, the role of the RPA and RPS is quite clearly defined. Requiring access to either appointed person 24/7 is generally going to be driven by the assumption that they are needed in the event of a radiation accident or incident. These terms are defined as follows:
Radiation accident (IRR17 - 2) - 'means an accident where immediate action would be required to prevent or reduce the exposure to ionising radiation of employees or any other persons'. Note the wording here : immediate / prevent / reduce. Here are some Ionactive resources for a deeper consideration if required (will open in a new window):
Radiation incident - this is not defined in IRR17, but for the purposes of this blog article means an event which may be radiation safety related, but which does not meet the definition of a radiation accident as noted above.
It follows that where a radiation accident has been assessed as reasonably foreseeable in a radiation risk assessment, a contingency plan will be required : IRR17 (13) - Contingency plans (will open in a new window). Where a radiation accident is not reasonably foreseeable, but other radiation safety related incidents are identified, contingency arrangements (or whatever other term you wish to use - except "plan") should then be in place. The RPA (and usually the RPS) will be involved in the radiation risk assessment process to determine the above, and in the development and rehearsal of contingency plans (or arrangements).
Access to the RPA for periodic meetings / site review / radiation safety audits / general consultation can be made by planned appointments, written into an appointment letter or contract. Reasons to seek assistance from an RPS (other than for contingency) might be to help with a local rules review, workplace monitoring, issue and collection of dosimetry, updating radiation safety training, record keeping etc. These will tend to be written into the scope of the RPS appointment, and contact details will be available in the local rules, and normally at the entrance to controlled areas (e.g. on radiation safety signage).
The question is then... do you need 24/7 access to the RPA and / or the RPS? We have already noted reasonably foreseeable radiation accidents require immediate actions , as outlined in contingency plans. Do users of ionising radiation (operatives / plant employees / x-ray machine users / laboratory workers etc) need specific advice from the RPA and / or assistance from the RPS in order to implement the contingency plan or arrangements?
Let's look at a selection of reasonably foreseeable radiation accidents (and incidents) based on some examples of radiation use from various industries.
Examples of reasonable foreseeable radiation accidents and incidents
In this section we will outline some examples of radiation accidents and incidents for a number of different uses of ionising radiation. For each we will provide comment on the practical (and immediate) advice (or not) that could be required of the RPA or RPS.
For a deeper analysis of this subject you may also wish to visit our blog article: Radiation accident or radiation incident? When are IRR17 contingency plans appropriate? (Link will open in a new window).
[Ionactive comment: There is nothing to stop the employer specifying they want 24/7 RPA cover - if they can afford this, and if their chosen RPA is able to offer this service, regardless of the actual need for such cover. But aside from a general preference, the radiation risk assessment should establish if there is a need for 24/7 RPA cover. What we are pointing out below is where the employer expects 24/7 cover because they 'need RPA cover' vs 'having a preference' for 24/7 RPA cover. Similar comments can also be attributed to the RPS.]
Radiation accident examples
Industrial Radiography (open site radiography) - 370 GBq Ir-192 source fails to retract back into projector (shielded source storage container) - requires swift action to mitigate. This needs immediate action by following a contingency plan for radioactive source recovery. Failure to make the source safe could lead to unplanned exposures, which may be significant if the source recovery is not performed correctly (therefore this can be classed as a radiation accident). This radiation accident does not need 24/7 RPA cover (e.g. advice at the end of the phone prior to dealing with this accident). The radiography technicians should be sufficiently trained to adequately control exposures and make the radioactive source safe. Whilst the RPA will be involved in their training, developing the contingency plan & post accident investigation, requiring an RPA to be available 24/7 could indicate flaws in the risk assessment, planning and training. It is expected that at the very least one of the radiography technicians would be trained to RPS level - and be appointed as an RPS - since local rules will either detail the contingency plan, or make reference to it. [Note: this would also require reporting under the 'Reporting of Injuries, Diseases and Dangerous Occurrences Regulations' (RIDDOR).]
Hand contamination by a radiopharmaceutical - due to a break down in control measures; an employee contaminates the glove of their right hand with 1 GBq of F-18, capable of delivering 13 Gy/min over the area exposed. This is a radiation accident. Over 200 mGy/second delivery is possible and immediate actions are required (e.g. remove contaminated glove swiftly, but safely to avoid contamination spread), followed by careful hand washing and further monitoring. No time to call the RPA (or indeed the RPS if not present in the immediate work area). There is no immediate advantage in having access to the RPA 24/7 for this accident - workers need to be trained such that they are aware an accident has occurred (e.g. room radiation monitor alarms), and deal with it immediately (of course, engineered systems and work practices should avoid the accident occurring). If the operation is 24/7, there should be continuous RPS cover, but in this scenario reliance on the RPS is less important than the immediate actions of exposure control - there is no time for a conversation. Operatives should have adequate radioactive spill training to take the immediate actions required, without referral to anyone outside the immediate work area. The RPS will be involved post accident (e.g. perhaps minutes after the accident), and the RPA in the investigation (including dose assessments etc) in the hours / days afterwards.
- Medical physics staff are running up a linear accelerator (linac) for it's daily warm up prior to starting to treat patients. Despite using the search (last person out button) and confirm procedure (confirm button) an engineer is left behind the back of the linac in the technical room. Upon linac start-up, it is stopped soon afterwards by the engineer pressing an e-stop button on the wall of the technical room. This is a radiation accident. Dose rates within the region of the linac beam will be of the order of 6 Gy/min at iso-centre. The engineer is nowhere near the beam but dose rates will still be significant - perhaps of the order of 10's mSv/min depending on exact location. So a 5 second exposure (time taken to reach over and hit e-stop) might be within the range of 500-1000 micro Sv (probably less). Immediate actions were required by the engineer to reduce exposures. Whilst it is almost certain that an RPA would be near by, there is no immediate advantage in contacting them (i.e. immediate RPA 24/7 RPA response is not required). When a linear accelerator is operational there is an expectation that an RPS would be available (although in this example, the accident is mitigated without any specific reference to the RPS).
Radiation incident examples
Industrial Irradiation facility - a source rack containing 185 PBq of Co-60 source fails to return to the bottom of a water filled source storage pool (the water is shielding), instead it remains above the pool in the irradiation position. If this were to occur the facility would remain 'locked up' with no means of access into it (protection provided by multiple safety systems and interlocks). This is a serious and costly plant fault - but it is not a radiation accident, at most it is a radiation safety related incident (it could be argued it's not even radiation safety related, as there is no immediate radiation exposure potential). The site will need to plan a recovery method (possibly involving flooding the facility and working from above, perhaps using robotics, or manipulating control systems above the plant to try and encourage the source rack to enter the pool etc). The recovery planning will require input from plant engineers, external contractors and the company RPA - and this may be days or weeks of work. The facility radiation risk assessment / consent safety assessment will not require 24/7 RPA cover for the circumstances described. It is expected that if the plant is running 24/7 then there would also be RPS cover (someone on site). This would also need reporting via RIDDOR.
An airport checked baggage x-ray screening system is jammed - requiring person access into the x-ray screening tunnel to retrieve the item. This is not a radiation accident, and not really a radiation incident (there is no radiation exposure potential), but of the two options a radiation incident is the best category. Not withstanding the engineered features which are likely to stop the conveyor and x-ray generator in such circumstances, a simple e-stop and x-ray inhibit (e.g. removing system control key) will avoid any risk of radiation exposure whilst the item is retrieved. There is no need for 24/7 RPA cover. Furthermore, whilst an RPS may be present during times of baggage screening operation, they are not required for the purposes of jammed item retrieval - baggage screening operators should have the training required to inhibit the x-ray system whilst they make entry.
- A university researcher is performing some radiochemistry using 37 MBq of P-32, working on a yellow containment tray placed into a fume cupboard. During the transfer of activity from the stock solution to the experiment, about 10% of the solution (i.e. 10% total activity) drops onto the surface of the yellow tray. This is not a radiation accident, but could be considered a radiation safety related incident. Small radioactivity spills will occur from time to time - contamination has not spread into the wider environment and is contained on the tray within the cupboard. Some diligent monitoring using a nearby radiation monitoring (a GM based Mini Type EL) locates the contamination spot and it is removed with careful use of a blue tissue swab into a waste bin at the back. Further monitoring of the immediate work area, gloved hands and floor below verify absence of contamination. There is no need for 24/7 RPA cover, despite the fact that the RPA will probably be onsite during working hours (with the exception of vacations and other leave). A departmental RPS will probably be available, but they are unlikely to be consulted specifically during the clean up process - it is expected that the user undertaking the work will have been suitably trained to do this.
Radiation Protection Adviser (RPA) and Supervisor (RPS) 24/7! Do I really need this?
Do you need an RPA (and / or) RPS 24/7? More often than not the answer for the RPA is - no. For the RPS - it depends (perhaps depends more).
RPA - We have answered this (or more precisely given an opinion) in the section above on radiation accidents and incidents. It turns out that as important as the RPA role is, RPA advice is less important at the crucial moment of accident (or incident) mitigation, being mostly down to those doing the work - hence the importance of suitable and sufficient training (particular based around the contingency plan, or arrangements - and their rehearsal).
RPS - We have noted that the main (IRR17) role of the RPS is to supervise the work with ionising radiation, in compliance with local rules. Whilst supervision might imply 'continuous', practically speaking this is not always the case. Despite the role of the RPS being defined in IRR17, other legislation (such as UK permitting regulations for use of radioactive substances and accumulation and disposal of radioactive waste) may borrow the role and add to the RPS duties. These additional duties may require 24/7 supervision. However sticking with IRR17 we can look at a specific example:
- Consider the contingency arrangements for a total radiation shielding curtain failure on an airport x-ray security system (this is not a radiation accident in almost all circumstances, more than one layer of curtain is usually fitted - go and check the definitions above if needed). The action required (which could be immediate, but a delay will not lead to a significant radiation exposure) is to 'hit the emergency stop', followed by disabling the unit until the curtain is repaired. [Ionactive comment - a risk assessment might indicate the unit can continue to be used - this will be determined by the specific installation.] The point here is that an RPS need not be present (or available) in order for the operator of the unit to take the correct action. The x-ray unit operator training should be sufficient in order for them to push the e-stop upon recognising a shielding curtain failure. If the x-ray security operation is 24/7, and the curtain failure is at 0330 in the morning, the action to be taken does not require a RPS to be on site and readily available to attend the incident. To suggest that an RPS must be available indicates that the operator does not have sufficient training, for what is a simple action (switch off). Furthermore, it is unlikely there is any need to wake the RPS with a phone call to advise them of the actions just taken - that can wait till the morning. In the events described, there is no need to contact a RPA or have them on 24/7 cover to ensure that contingency is implemented.
Additional matters to consider
Writing this blog reminded us of some other related matters. A few years ago Ionactive was asked to provide a quote for RPA services for a fairly large user of x-ray security screening systems in central London. The prospective client provided a list of requirements which included 24/7 RPA cover (already discussed in this blog). One additional requirement was to provide a service for chromosomal aberration analysis (CAA) - this being a blood test for whole body exposures that generally exceed 100 mGy (dicentric chromosome assay). We suspected that the prospective client already had an RPA contract, with a provider who had included CAA as part of their service. We pointed out that CAA (as a service offered) was completely irrelevant for the operation of security x-ray equipment, where a risk assessment would show that it was not reasonably foreseeable for any exposures under any scenario to reach a level where CAA would be appropriate (partial or whole body exposure). Ionactive became their RPA after suitable advice was offered.
There are ionising radiation users out there in the UK - who have procured 24/7 RPA services, including the addition of CAA, which is not required given their particular circumstances of ionising radiation use.
Mark Ramsay
Radiation Protection Adviser
Chartered Radiation Protection professional
(c) Ionactive Consulting Limited - April 2025