Difference between a Radiation Protection Adviser (RPA) and a Radioactive Waste Adviser (RWA)?

Radiation Protection Adviser (RPA) must not be confused with the role of the Radioactive Waste Adviser (RWA). Confusion may arise since the RPA had provided the role of an RWA, all but in name, prior to 2012. In fact, in many cases, your appointed RPA continues to do exactly what they did before (with respect to radioactive substances and waste disposal), but they will do this whilst wearing their specific ‘RWA’ hat. In addition, the Radioactive Waste Adviser should be appointed in writing – in most cases this can be added to the traditional RPA appointment letter (unless the roles of RPA and RWA are undertaken by different individuals).

Radiation Protection Adviser (RPA)

The Radiation Protection Adviser is a requirement of the Ionising Radiations Regulations 2017 (IRR17) which deals with the safe and compliant use of all sources of ionising radiation (sealed and unsealed radioactive sources and all forms of electrically generated ionising radiation). These regulations deal with employee and public safety, and this is primarily what the RPA provides advice on.

For users who work with radioactive sources (either sealed or unsealed) or radioactive waste, there is a requirement for having permits in place. These permits contain a number of conditions that the user must comply with. Traditionally the RPA has provided advice on compliance, and early permits (and the former Registrations and Authorisations) made reference to consulting an RPA or other suitable persons (Qualified Expert). At the EU level, there was never any distinction between an RPA or RWA – only the term Qualified Expert is recognised.

With the recent changes to radioactive legislation such as the Environmental Permitting (England and Wales) Regulations 2016 in England / Wales, and the Environmental Authorisations (Scotland) Regulations 2018, the role of the Radioactive Waste Adviser (RWA) has been formally adopted. An RPA can only act as an RWA if they have approval from the UK Environmental Agencies.

Radioactive Waste Adviser (RWA)

A Radioactive Waste Adviser (RWA) is a specialist in radioactive waste accumulation disposal, and environmental radiation protection. Through certification, they have demonstrated competence against an RWA syllabus which has been developed by the UK Environmental Agencies.

All users of radioactive material which leads to the potential or actual accumulation or dispose of radioactive waste need to appoint an RWA. Except in rare cases (i.e. where out-of-scope or exemption criteria applies), if you have a permit issued under the Environmental Permitting (England and Wales) Regulations 2016 or an Authorisation issued under the Environmental Authorisations (Scotland) Regulations 2018, then you must have an RWA in place, and appointed in writing.

Before appointing a RWA you should ensure that they are certificated to act as such. This is similar to ensuring that you check the RPA is competent to act in the role (e.g. via a RPA 2000 certificate). In both cases the certification only proves competence – the user / employer is responsible for ensuring that the RPA / RWA is suitable for a specific case.

Mandatory consultation of the RWA

The following matters are the subject of mandatory consultation with a RWA.

  • Achieving and maintaining an optimal level of protection of the environment and the population.
  • Checking the effectiveness of technical devices for protecting the environment and the population.
  • Accepting into service, from the point of view of surveillance of radiation protection, of equipment and procedures for measuring and assessing, as appropriate, exposure and radioactive contamination of the environment and the population.
  • Undertaking regular calibration of measuring instruments and regular checking that they are serviceable and correctly used;
  • Understanding the limitations of the advice that they are able to give and be able to recognise when further specialist advice is needed

In addition to the above, advice may be required on any aspect for compliance with environmental permits (inc registrations / authorisations etc). Furthermore, specific permits may required mandatory consultation on specific permit conditions.

Two things are infinite: the universe and human stupidity; and I'm not sure about the universe

– Albert Einstein -