RPA bodies recognised by HSE (IRR17). Is Ionactive an RPA body? No! Do we need to be? No!
Published: Jan 12, 2024
During December 2023 Ionactive had a query from a prospective client who was working with x-ray systems - could we give them some general advice and would we be able to offer RPA services? We provided a quote and all seemed OK - until the client came back to us and said 'You are not on the 'List of RPA bodies recognised by HSE'. The list they were talking about can be found here: 'List of RPA bodies recognised by HSE under IRR17' (opens in a new tab).
We answered 'No we are not!'
- Prospective client: 'Why are you not on the list?'
- Ionactive: 'Because we do not need or wish to be'
- Prospective client: 'But it sounds important, why would you not be on this list?'
- Ionactive: 'Because anyone from Ionactive that visits you as your RPA - is an RPA!'
- Prospective client: 'That seems reasonable, so what is the list about then?'
- Ionactive: 'It allows individuals to visit your site, and provide "RPA like advice", but they may not be qualified as a RPA'
- Prospective client: 'Wow that seems strange, I am paying for an RPA service, should I not see a qualified RPA?'
- Ionactive: 'Well you do really, an "RPA Body" gives you this, and this is what the list is about'
- Prospective client 'Ok, so tell me more - what does the list actually mean?'
You get the idea and Ionactive is now RPA for this client. But the query did prompt us to write this short blog article.
So let's explore this in a little more detail.
What comes first: 'Certificated RPA' or 'Recognised RPA body'?
Before we answer this, let's just expand the definitions a little.
- Certificated RPA - An individual RPA who has a valid certificate of core competence from an organisation recognised as an assessing body by HSE (e.g. RPA 2000).
- RPA Body - An RPA Body which is recognised as meeting the definition of an RPA as per IRR17.
The key requirements to be met by an RPA Body is that they have to satisfy the following:
- They have personnel who include a sufficient number of persons who satisfy the Criteria of Core Competence for individual RPAs.
- They have management systems and written quality assurance procedures to ensure that radiation protection advice given is consistent and traceable to one or more certificated RPAs.
So imagine the following structure of the RPA Body "RPA-R-US":
- Managing Director (and RPA)
- RPA No. 2
- Technician No.1
- Technician No.2
- Technician No.3
You appoint "RPA-R-US" as your RPA (RPA Body).
You are visited by Technician No.1 and No.2. They provide practical advice on working with ionising radiation during a site visit. Once back at the office they write you a RPA visit letter, a risk assessment and provide advice on the content and suitability of local rules.
How do you know that the advice is suitable and sufficient and appropriate for your needs? With the RPA body you rely on the fact that the management systems and quality assurance procedures are robust such that the advice (etc) from Technician No.1 and No.2 has been reviewed and endorsed by a certificated RPA.
So - what comes first?
The certificated RPA comes first, without them the RPA Body will not exist.
What do you choose. An RPA or RPA Body?
Absolutely your choice!
Is Ionactive against the principles of a RPA Body? Absolutely not. For larger RPA companies an RPA Body is a great way to train new prospective RPAs. It allows them to train on the job gaining practical experience and this will help them create a portfolio of evidence that they will need to submit to the assessing bodies (e.g. RPA 2000). This is the way they will gain a certificate of competence (to act individually as a RPA) - so aiding personal development.
The management systems and written quality assurance procedures which HSE require for a RPA body are not assessing a certificated RPA's competency. They are only assessing the ability of an RPA Body to provide suitable and sufficient RPA advice regardless of the specific individuals who provide that advice.
So what do you get if you choose an RPA rather than a RPA Body? You get RPA advice directly from a certificated RPA.
Why might you choose to be an RPA Body if all your RPAs are certificated anyway? You might wish to appear on the list so that you have the ability to train non-certificated (trainee) RPAs, and send them out into the workplace. You might also want to be on the list, because it is a list issued by HSE (so may provide the impression that the RPA Body is endorsed by the HSE). Actually - endorsed, accredited, approved (etc) are not what this is about - only recognition as outlined above.
How do you know if your RPA is certificated?
You will want to know this if you choose an RPA who is not part of an RPA Body. In addition, if you select an RPA Body you might also be interested to know if the individual they send to visit you is a certificated RPA (or technician etc).
You can find out by following this link. Radiation Protection Adviser Certificate Holders (opens in a new tab, from RPA 2000). When you visit this link you will then need to select the first option. We have not provided a direct link as the PDF records are dated and the link address will change from time to time. As of January 2024 there are about 450 certificated RPAs. Sounds a lot, but remember many of these will be found in the nuclear industry and the NHS and private medical sector. There is a much smaller group of RPAs who predominantly serve under specific contracts to a variety of radiation users.
Using the above link you will note that our record will reads:
Mark Ramsay, 2232 (certificate number), 31/10/2026 (expiry date)
Mark Ramsay
Radiation Protection Adviser (RPA)
Chartered Radiation Protection Professional
January 12, 2024