New UK Registration process for users of Ionising Radiation (as of August 2023)
Published: Aug 04, 2023
Prelim
Many readers will be aware we have released several blog articles on the new consent process which will be in place (for non-nuclear sites) from October 2023. These articles are worth a read even if you are only concerned with registrations, since the background to why changes are being made (e.g. driven by the IAEA Integrated Regulatory Review Service (IRRS) mission in 2019) are discussed in some detail. In particular we have reviewed the background to how and why notifications, registrations and consents came about - appearing in the Ionising Radiations Regulations 2017 (IRR17) from 2018. If you would like the background to all this before reading further into the specific changes for registrations (for certain practices detailed in IRR17), then please visit the following:
New UK Consent process for users of Ionising Radiation (as of February 2023, updated May 2023). This link will open in a new tab.
The IRR17 registration process (pre October 2023)
The information below will not include details of how to obtain a registration, if in doubt you may seek advice from a Radiation Protection Adviser (RPA). In addition, there are links and guidance at the following HSE link: Using ionising radiation (Apply to notify, register or get consent) - will open in a new tab.
The current application process is quite simple, with relatively little information required of the employer. Once you have decided you need a registration (i.e. not a notification or a consent), then the three groups you may apply for are:
- Working with radiation generators.
- Working with artificial radionuclides and/or naturally occurring radionuclides which are processed for their radioactive, fissile or fertile properties.
- Working with naturally occurring radionuclides which are not processed for their radioactive, fissile or fertile properties.
In terms of specifics, selecting one or more from the list above is all you do. The regulator has no further information on what you are doing or why (i.e. they do not have a scale of the work you do, the locations of the work or why you need to do the work). More generic questions asked before you get to choose your registration type include:
- Type of employer (e.g. LTD, charity etc).
- Company / charity (etc) number (i.e. to establish legal entity).
- Number of employees (banded into groups).
- Number of classified employees.
- Whether the employer transports radioactive material.
- If the employer uses portable ionising radiation sources (radioactive and x-ray based) at sites belonging to other employers.
- How many fixed sites does the employer have in the UK.
That is about it for the generic information that applies to any application for a notification, registration or consent.
So far as the registration process is concerned, once you have successfully submitted the generic information you are straight in to selecting the type of registration (i.e. choosing one or more of the three choices available as detailed above). Following this you then need to confirm that you have a number of important IRR17 matters in place. These include:
- Radiation risk assessment.
- Undertaken measures to estimate employee exposures.
- Practice restriction of exposure (inc. ALARP).
- Contingency plans are in place for reasonably foreseeable radiation accidents.
- Radiation Protection Adviser (RPA) appointed and consulted.
- Information, instruction and training given to all employees working with or affected by ionising radiation.
- Controlled or supervised areas in place (suitably demarcated etc).
- Local rule and Radiation Protection Supervisors (RPS).
Apart from paying the fee at the end of the application (currently £25) - this is the process for gaining a registration under the current scheme (i.e. pre October 2023). Note that HSE have no idea what the employer is doing and the scope of that work. It is true that if the company were called 'Cargo Screening LTD' then there is a good chance that the company is using radiation generators (x-ray units), but this is not a certainty.
We will now look at the changes to the IRR17 registration process from October 2023 this year.
The new IRR17 registration process from October 2023
[Note that this is based on HSE information at recent RPA update events, handouts and discussions with colleagues etc, therefore things could still change further. At the time of writing (August 2023) there is no official guidance on this process (we understand draft guidance is being reviewed by SRP and IPEM].
As mentioned at the beginning of this article, the IAEA Integrated Regulatory Review Service (IRRS) mission in 2019 made some recommendations, the most significant of which relate to the IRR17 consent process which has already been discussed by Ionactive (blog article link given above). A significant observation affecting the current registration process is that the regulator (HSE for non-nuclear) does not have a 'register of sources' with respect to any particular employer who works with ionising radiation, or as a whole (i.e. for all registerable work in the UK). This observation only relates to radiation generators, since the UK (through its devolved administrations) has well developed environmental legislation and regulators with a permit / authorisation process providing adequate information on radioactive sources held. You may wish to visit our guide on such matters: UK Environmental Permitting Regulations (radioactive material and waste).
At the time of writing be thankful that it appears HSE have not adopted, for example, the UAEA (FANR) approach to regulating x-ray generators where the kV, mA and serial number of each and every x-ray generator has to be reported by the employer. The new UK HSE approach to IRR17 registrations is as follows.
- Complete the common information template (i.e. information required as outline above).
- Question - Are you in the medical / dental sector (yes or no). For the moment we will select "no".
Not in the medical / dental sector
For employers not in the medical or dental sector, the following information is to be collected.
- Total number of radiation generators in the company (will probably be number bands).
- Total number of premises where generators are used (it is not clear yet if this will include postcode data, i.e. exact locations).
- A question - does the employer use mobile radiation generators (Y or N).
- A description of the main purpose(s) for using the radiation generators (e.g. aviation security, cargo and freight screening, food quality control, XRF including portable handheld devices, XRD, non medical CT, patent defect (in a cabinet that cannot be entered so that the work is not classed as industrial radiography), and so on.
- A declaration for a new registration, or an updated declaration for a current registration with the new information added.
Working in the medical / dental sector
For employers who only use radiation generators for dental purposes, the following information is to be collected.
- Approximate total number of premises where radiation generators are used (may require postcode, not sure presently).
- Approximate total number of radiation generators (x-ray dental devices)
- A declaration for a new registration, or an updated declaration for a current registration with the new information added.
For employers who work in the medical sector (who may also use radiation generators for dental purposes), the following information is to be collected.
- Approximate total number of premises where radiation generators may be used (may include request for postcodes, not confirmed presently).
- Approximate total number of radiation generators used for general radiography.
- Approximate total number of CT scanners (of this number, what proportion are used in connection with radiotherapy).
- Approximate total number of radiation generators used for mammography.
- Approximate total number of radiation generators used in interventional x-ray and cardiology.
- Approximate total number of radiation generators used in DEXA units.
- Approximate total number of radiation generators used in dental x-ray procedures.
- A declaration for a new registration, or an updated declaration for a current registration with the new information added.
As you can see, this is a fair amount of new information which the HSE will require from new or current registration holders. It is understood that existing registration holders will be contacted before 1 April 2024 to supply this addition information.
What about medical x-ray equipment suppliers, installers and service engineers?
The above data is relatively easy to obtain from the end user of radiation generators in sector specific areas (cargo, QA, food screening etc), and in medical or dental modalities. At this stage it is assumed that the word 'approximate' in the preceding sections is deliberate. This would make sense as equipment suppliers, installers, and service engineers (etc) will never have exact numbers, and this data will change on a weekly / monthly and annual basis. It looks likely that banding or good approximations will suffice. It is impractical for this group to provide details of where they work, other than to provide details of production factories and similar (and perhaps a general description of typical customer sites).