IRR17 (16) - Co-operation between employers

The basic requirement for co-operation between employers sharing a workplace is contained in Regulation 9 and 12 of the Management of Health and Safety at Work Regulations 1999. This is required under IRR17 (16), where work with ionising radiation undertaken by one employer is likely to give rise to the exposure to ionising radiations of the employee of another employer.

The employers concerned are required to co-operate by the exchange of information to ensure that each is able to comply with the requirements of IRR17. In this context their ability to comply relates only to that which depends on the co-operation. Note that IRR17 has now removed the designation 'radiation employer' - it is now up to both employers to determine where compliance is required and how it is achieved - by cooperation.

Typically, this regulation may affect an employer in one of the following ways:

  • Contractors who work on another employers site
  • Employees working at other sites where ionising radiations are being used
  • Employees who have several employers

The first situation may be conveniently managed by a Permit to Work system and careful supervision by the RPS to ensure that local rules are complied with.

If contractors are required to work in the vicinity of controlled or supervised areas - see IRR17 Regulation 17 - this regulation requires that sufficient training be given to the contractors so that they understand the potential hazards and residual risks. Such training and understanding may also be necessary in the reverse situation, for example when industrial radiography is to take place on the employer's site. The degree of training required will depend on the extent, duration and complexity of the work being undertaken (as well as the degree of supervision).

The second situation highlighted above is often more difficult to manage and it is in these circumstances where sufficient co-operation is vital. The employer needs to ensure that they have procedures which require their employees to report to a responsible person as soon as they arrive on the other employer’s site. It is likely that the RPS’s from each site will need to communicate and this may also extend to the respective Radiation Protection Advisers. For classified outside workers (see below), formal provision of dose information and fitness will be required.

Outside workers

Cooperation is especially important with respect to outside workers. IRR17 has extended the definition of outside workers to include non-classified workers (under IRR99 they were only classified workers who worked in a designated area, other than one managed by their own employer). Now all workers, who undertake work in another employers designated area, (i.e. classified outside workers, and non-classified outside workers), are owed specific duties regarding adequate information, instruction and training. The extent of this, and the degree of cooperation required, will depend on the nature of the radiation hazards. Here are some matters to consider:

(a) the detail of the work to be carried out (method statements etc will help here)

(b) the type of likely radiation exposure (the risk assessment will describe radiation sources and likely exposures)

(c) an estimate of the total dose likely to arise from the work

(d) the work procedures that will be required to keep doses as low as reasonably practicable (including any use of special protective equipment)

(e) the risks associated with the work and the precautions that should be taken (induction training may be important here)

(f) any local restrictions that will be applied (understanding the nature of the work area and local rules is vital)

(g) the local rules that apply in the other employer's site (including emergency arrangements and contingency plans)

(h) radiation protection supervisors - RPS (who they are, contact details, their onsite availability etc)

(i) any relevant dose constraints and associated local investigation levels (specified in the local rules and method statements)

The definition of 'safe' is not strictly an engineering term; it's a societal term. Does it mean absolutely no loss of life? Does it mean absolutely no contamination with radiation? What exactly does 'safe' mean?

– Henry Petroski -