X-ray Industrial radiography cabinet vs X-ray radiography cabinet which you can (or cannot) enter – is there a difference, and does it matter? / Are you undertaking industrial radiography (NDT), radiography, x-ray inspection or something else?
Published: Mar 01, 2025
Prelim
In this article we will outline why 'X-ray Industrial radiography cabinet vs X-ray radiography cabinet' matters to you – if you use these systems in the UK. Then we will provide the latest HSE interpretation and information regarding access to cabinets (and what this means to the operator in terms of regulatory burden). Then, in true Ionactive fashion, we will be a little fussy and suggest that terminology could be tighter (i.e. the featured regulator information includes terms such as ‘X-ray cabinets’, ‘industrial radiography’, and ‘radiography cabinet’ - not all of these are defined in IRR17, and they are not necessarily comparable.
We then consider what industrial radiography (NDT) is, and why we feel the term ‘radiography cabinet’ could lead to some confusion (with regards to the Ionising Radiations Regulations 2017 - IRR17 - and the requirements for a registration or consent). This article is somewhat complementary to our other articles such as 'When is an 'industrial radiography walk-in enclosure' not an industrial radiography enclosure (and therefore does not require an HSE consent)?'. However, the linked article considers an enclosure (or room) which very obviously can (and must) be entered in order to set up an object ready for x-raying.
Industrial radiography x-ray cabinets – the issue (access)
Let’s start with some interpretation (definitions) in IRR17.
Industrial radiography IRR17 (2)(1) - ‘… means the use of ionising radiation for non-destructive testing purposes where an image of the item under test is formed (but excluding any such testing which is carried out in a cabinet which a person cannot enter)…’
Note in this definition the following important terms:
- Non-destructive testing (NDT) – so industrial radiography is a form of NDT.
- Item under test – this reinforces the NDT aspect of the definition (it involves testing something).
- It provides an exclusion from the definition i.e. ‘...such testing which is carried out in a cabinet which a person cannot enter...’
As far as the latest HSE interpretation is concerned, (coming up below), it is the last point which matters. The issue is (was) that the above definition (IRR17 interpretation) uses the phrase ‘...which a person cannot enter...’ rather than, for example, ‘… which a person cannot enter, so far as is reasonably practicable …’. This meant that HSE could consider any cabinet, which is used for industrial radiography, which could be entered (regardless of how difficult, uncomfortable or unlikely), as coming under the above definition. And why does that matter? It matters because if you undertake industrial radiography in the UK, it is a specified practice and you need a consent under IRR17-(7). The consent is the highest-risk tier in IRR17 and requires the following (in addition to all the other compliance aspects):
- Application for a consent (made on the RADAN system).
- Creation of a Safety Assessment (SA) – using the HSE application sheets (specified practice specific).
- Submission to HSE: Local rules, SA, contingency plan.
- Inspection of the specified practice (i.e. industrial radiography in this case), assuming the document submission review (by HSE) is successful.
- Payment of fees (£1000’s).
- Issue of consent.
By contrast, an application for a registration for radiation generators (medium-risk tier) takes about 15 minutes and £26 (this assumes you have everything else in place – RPA, RPS, risk assessment, local rules, contingency etc.).
So you can see that moving from a registration to a consent, based on accessibility into an x-ray cabinet, used for industrial radiography, is a big deal – hence the HSE latest interpretation on this very point.
The HSE statement – April 2024 (SRP)
Ionactive first found this statement issued in the SRP (Society for Radiological Protection) weekly update email (Ref: Weekly Update #569, The SRP Members' Newsletter - 10 April 2024). This is reproduced below as issued at the time.
Industrial radiography NDT cabinets
Following meetings with government legal advisers, the HSE radiation team have been authorised to change their interpretation of industrial radiography with respect to cabinets and the requirement to gain consent under the Ionising Radiations Regulations 2017 (IRR17), Regulation 7. It is felt that the new interpretation is now more proportionate and targeted.
IRR17 definition: The IRR17 Regulation 2(1) states: “industrial radiography” means the use of ionising radiation for non-destructive testing purposes where an image of the item under test is formed (but excluding any such testing which is carried out in a cabinet which a person cannot enter).
New interpretation regarding cabinets used for NDT that require consent: “a person being able to enter a radiography cabinet means a person being able to reasonably step into the cabinet and stand inside with the door closed. No crawling or shuffling or excessive contortion would be required to get inside.” Should you wish to contact HSE’s radiation team about this matter please email [email protected] .
[Ionactive comment: Note that the heading is specifically “Industrial radiography NDT cabinets” – we will assume this is the heading chosen by HSE, and not an editorial decision by SRP.]
The above statement is clearly useful to operators of x-ray cabinets which are used for industrial radiography – so a big thanks to HSE for releasing this. There still may be a differing opinion between the regulator and operator on reasonable access etc, but at least that discussion can now be had, whereas before, the older definition of industrial radiography provided little room for such discussion.
IRR17 Reg 2(1) Application for X-ray cabinets – Consent vs Registration Decisions
We will now move onto additional information released by the regulator ‘IRR17 Reg 2(1) Application for X-ray cabinets – Consent vs Registration Decisions @ 7/01/25 (previous issue 30/7/24)’.
[Ionactive comment: Please keep in mind when looking at the information provided below that this is intended to relate to the definition of industrial radiography - the specified practice which needs a consent where you can enter an industrial radiography cabinet – entry now being more usefully defined as stated above. In this comment we have specifically and deliberately used the phrase ‘industrial radiography cabinet’.]
An image of the Consent vs Registration Decisions document is presented below.
IRR17 Reg 2(1) Application for X-ray cabinets – Consent vs Registration Decisions @ 7/01/25 (previous issue 30/7/24)
For ease of reading we have reproduced the text before the table below – the only thing we have enhanced is some of the text (bolded), since we think it is important to note these. You can also download a copy if you wish.
IRR17 Reg 2(1) Application for X-ray cabinets – Consent vs Registration Decisions @ 7/01/25
(previous issue 30/7/24)
IRR17 Regulation 2(1) defines: “industrial radiography” means the use of ionising radiation for non-destructive testing purposes where an image of the item under test is formed (but excluding any such testing which is carried out in a cabinet which a person cannot enter);
HSE interpretation:
“a person being able to enter a radiography cabinet means a person being able to reasonably step into the cabinet and stand inside with the door closed. No crawling or shuffling or excessive contortion would be required to get inside.”
Where a person can enter a radiography cabinet, consent would be required under IRR17 Reg 7.
Where a person cannot enter a radiography cabinet, registration would be required under IRR17 Reg 6.
Ionactive comment on the Consent vs Registration Decisions
Firstly, and importantly with respect to industrial radiography carried out in a cabinet, the table is useful. Our assumption here is that HSE have either carried out a desktop study using supplier information, attended sites and examined the cabinets first hand, or perhaps both.
There are however some things that come to mind with this resource.
- The interchangeable use of ‘x-ray cabinets’, ‘industrial radiography’ and 'radiography cabinet'. We are sure the intention is that they are all pointing towards industrial radiography – but the terms could be tighter or a statement could be included above the table – something like ‘The Consent vs Registration Decisions table applies specifically to the specified practice of industrial radiography'. We will explore this more in a moment.
- A few of Consent vs Registration Decisions in the table seem to be at odds with the new interpretation of industrial radiography. The following examples below could be on the list because there is a rear door we cannot see (from our own supplier brochure review), or a different model number exists (with easier access), or access does not sufficiently meet ‘…crawling or shuffling or excessive contortion would be required to get inside..’ (although this might be subject to what equipment is fitted into the cabinet, as we have seen some examples of the same cabinet with different configurations making access difficult). We will look at some examples now.
Consider the following cabinets from the above table:
- Nikon XT V 130C
- Nikon XT V 160
- Waygate Technologies / Micromex M300
- Waygate Technologies Phoenix V|tome|x M Neo (borderline access perhaps...)
Pictures of the first three units are shown in the slider below. It seems highly unlikely that that either of the Nikon units will meet the definition of industrial radiography (if used for that purpose). With the Micromex M300, you appear to need to climb up and into the cabinet, rather than walk into it.
The Phoenix V|tome|x M Neo is interesting – it has a full length door allowing potential access – have a look at the slider below – it contains some screen sheets from a Waygate Technologies promotional video Do you think this meets the latest HSE interpretation of industrial radiography (assuming that this specified practice is taking place)? Could you enter this cabinet without crawling or shuffling or excessive contortion?
Discussion on what is industrial radiography (and why this matters)
We have considered this before in other blog articles as noted earlier. It seems appropriate to revisit again.
We start by sharing a particular search result for “Siefert DP435”, this being on the list above as a radiography cabinet requiring a consent. On the first page of google we find:
The opening summary of this article is particularly insightful – “…Visualizing the internal structure of museum objects is a crucial step in acquiring knowledge about the origin, state, and composition of cultural heritage artifacts. Among the most powerful techniques for exposing the interior of museum objects is computed tomography (CT) …”. We have said similar in our other related blog articles, although not as succinctly. No mention of testing, NDT or industrial radiography. Because it is clearly not industrial radiography. CT radiography and x-ray radiography is mentioned frequently – since it comes under the wider definition of radiography.
There is no one single definition of radiography, and many are particularly biased towards medical applications. A quick look on line provided the following examples:
- Wikipedia “…Radiography is an imaging technique using X-rays, gamma rays, or similar ionizing radiation and non-ionizing radiation to view the internal form of an object. Applications of radiography include medical ("diagnostic" radiography and "therapeutic radiography") and industrial radiography…”
- Cambridge dictionary “…the use of radiation (= a form of energy), especially X-rays, either to produce a picture of the inside of people or objects, or for the treatment of disease…”
- Collins dictionary “…the production of radiographs of opaque objects for use in medicine, surgery, industry ..”
You get the idea – radiography is a definition far and wide, of which industrial radiography is just one use.
Let’s now turn to NDT (non destructive testing), since this (and ‘testing’) is embedded in the definition of industrial radiography. For this, we can turn to the HSE website which helpfully has mass of useful information on NDT. The webpage can be found here: Inspection/Non Destructive Testing. It’s a long read and applies to COMAH sites, but here are a few things we picked out.
- Non-Destructive Testing (NDT) is the application of measurement techniques in order to identify damage and irregularities in materials. [1.0].
- NDT is a measurement of a physical property or effect from which the presence of damage or irregularity can be inferred. [1.0]
- NDT is a primary recovery mechanism for errors in design, construction and operational activities. [1.0]
- NDT personnel are trained and certified under either a central certification scheme (e.g. PCN) or an employer based scheme (e.g. ASNT) [5.2].
- Reference is made to Information for the procurement and conduct of NDT. In section 4.6 of the document it is stated “Radiographic interpreters should also be qualified through a recognised scheme such as those complying with BS EN 473”..
- Site NDT should be under the supervision and support of a Level 3 operator and NDT procedures should be approved by Level 3 personnel, or equivalent.
In our opinion the following techniques using x-ray cabinets (deliberate emphasis), do not meet the definition of NDT, and cannot (generally) meet the definitions and requirements noted above in the HSE document.
- The inspection of museum specimens of any type.
- The inspection of electronic components. We are not aware of any cases where an NDT level 1-3 operator, suitably trained to above referenced standards, is used to inspect electronic boards in any of the cabinets featured in the above list.
- Confirmation of product quality assurance (outside of obvious NDT procedures for pipe welds, other structural welds, casting and similar – where PCN qualified personnel would be used to interpret the results). Examples might include: checking that a 3d printed object matches its technical drawing, component counting, counterfeit electronic component investigation, fuse wires in a military countermeasures explosives, PMI (Positive Material Identification) using x-rays (usually XRF), level gauges for process control (i.e. where a vessel may constitute an x-ray cabinet filled with something), etc
[Ionactive comment: it is already accepted that the screening of objects for aviation security etc in x-ray cabinets is not NDT (i.e. not industrial radiography). They only require a registration for radiation generators, despite the fact that larger cabinets can be literally walked through - from one end to the other - with no interlocked door, and with radiation exposures of 0.5-2 mSv per pass (for the CT models)]
So... registration or consent?
Here is where things might get a bit tricky (!). Where does the above table stand where industrial radiography (NDT) – as defined in IRR17 – is NOT taking place in any of the radiography cabinets (HSE emphasise) noted above? Furthermore, how is the consent column interpreted? Our view, based on the definitions, discussion, and the facts provided; is that none of the radiography cabinets featured in the tabulated list, nor those not on the list (but of a similar nature) require a consent, they only require a registration.
If this is the case then we are caught in an IRR17 trap. Interpretation (or definition), leading to the graded approach (notification < registration < consent), is given more weight than radiation risk assessment. Every radiography cabinet (or x-ray cabinet, or x-ray inspection cabinet, or whatever you want to call it) should be treated the same way – either registration (for radiation generator) or consent (for specified practice – industrial radiography).
On a radiation risk assessment basis, it would make more sense for any radiography cabinet, which can be entered (using the updated HSE interpretation), to require a consent. This would annoy many operators (safety assessment, HSE inspection, consent fees etc) – but it is hard to argue this differently. Unless… you risk assess the radiography cabinet and do not believe that access meets the updated interpretation … indicating only a registration is required. We are then back to interpretation / opinion between the regulator, operator and perhaps the RPA.
And what about aviation security screening cabinets? In our last blog we calculated the dose rate from large CT model being something like 1.8 Gy/h (highly collimated). Whilst much less than expected dose rates from a 300 kV, 10mA industrial radiography x-ray generator in a small cabinet, a radiation risk assessment comparing the two might be quite revealing in terms of overall likely exposure risk.
Until such time as any IRR17 updates (which would need parliamentary time etc), or further HSE decisions are made, we would be advising operators along the lines suggested in this article – if it’s not industrial radiography (NDT), and even if access to the cabinet is readily achievable, it needs a registration for a radiation generator and not a consent. We would then suggest the operator asks HSE for an opinion - after all, the RPA can only advise on what is stated in IRR17. As RPA, we would be seeking to ensure that any operator of any x-ray cabinet, regardless of use, achieves the same level of radiation protection whether a registration or consent is required - after all, their engineered features for radiation protection don't change with the level of paperwork required.
Mark Ramsay
Radiation Protection Adviser
Chartered Radiation Protection professional
(c) Ionactive Consulting Limited - March 2025