IRR17 (18) - Local rules and radiation protection supervisors part 1

Introduction

The strict legal requirements under IRR17 for local rules are focused on Controlled Areas. However, the regulations also allow for their adoption – where appropriate – in Supervised Areas.

For the purpose of enabling work to be carried out in accordance with IRR17, every radiation employer should make and set down in writing local rules that are appropriate to the radiation risk and the nature of the work. The radiation employer must then take all reasonable steps to see that they are brought to the attention of relevant persons and are observed.

To assist the employer with this duty, the radiation employer needs to appoint one or more suitable Radiation Protection Supervisors (RPSs) and include the names of such individuals in the local rules.

As we have already noted in IRR17 - Regulation 17 (controlled and supervised areas), there are some valid reasons why an employer will designate an area even where expected doses might suggest otherwise. There are equally good reasons - and legislative requirements – for appointing a ‘RPS Type of Individual’ even where the legally defined Radiation Protection Supervisor role is not strictly necessary. Examples include:

• Appointing an RPS to ensure that general duties under the Management of Health and Safety at Work Regulations 1999 (MHSW99) (e.g. implementing health and safety arrangements) are in place – with respect to radiation safety and therefore IRR17 compliance
• Appointing a RPS for the purposes of achieving radiation material accountancy and security (e.g. for the Environmental Permitting (England / Wales) Regulations 2016)
  
• Appointing a RPS to act as the eyes and ears of the employer – in addition to any statutory role they may have
• Appointing a RPS to ensure that specific IRR17 regulations are complied with (e.g. risk assessment, training, maintenance and similar).

The last bullet point is particularly important since regardless of the need (or not) for local rules and the RPS, the requirement to comply with all relevant sections of IRR17 remain.

It will be recognised as good practice for all employers who utilize ionising radiation, to appoint one or more RPSs and use local rules to assist in meeting compliance with IRR17 (and the ALARP principle). However, where the RPS and local rules are not strictly required under IRR17 Regulation 18, the employer (with advice from a Radiation Protection Adviser) can make provisions for an RPS and local rules which are proportional to the radiation risk (but may not comply absolutely with the requirements set out below).

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Local rules

Before we look at local rules in some detail it is worth considering the following general points:

• Local rules must be readable. Although their length and complexity is obviously going to be related to the radiation risk, if they are too long and complicated they will not be read at all.

• Local rules need to be obvious and on display, and those persons who are working in radiation areas need to be prompted to read them. Many employers require that new workers read the rules and then sign a declaration that they have ‘read and understood the local rules and will abide by them’. There are advantages to this, but it does not obligate the need for suitable and sufficient supervision. IRR17 indicates that local rules can be stored on electronic systems – but should be readily available.

• Local rules should not be treated as a radiation protection manual. We have seen too many local rules that take up a whole A4 binder. Local rules are not designed to explain the merits of one radiation monitor over another – they are there to simply state you need to undertake monitoring (e.g. where, how often and with what). If necessary, the local rules can reference to more detailed document (e.g. code of practice, procedure or similar) which contains all the detailed reference information.

• Local rules are for the Ionising Radiations Regulations 2017! They should not detail chemical safety, health and welfare issues or other safety information not related to ionising radiation. If they do the message is often diluted and they lose their impact. The exception to this is where radioactive materials are present (as opposed to x-ray generators) – then it is permissible to include accountancy and waste management issues required by the Environmental Legislation. However these should be no more than ‘rules’ – the detail should be included elsewhere otherwise the local rules become too bulky and will not be read.

• Local rules are not required where no designated areas exist. However, most employers continue to use them to ensure that all areas of IRR17 are complied with and to meet best practice. Ionactive recommends all its clients to have in place local rules for all sources of ionising radiation present in the workplace.

A typical set of local rules should contain the following:

• Management & Supervision – details of the management and supervision of the work

• Information, instruction and training – procedures for ensuring staff have received sufficient information, instruction and training

• Dose investigation level – 15mSv (or lower as specified by the radiation employer) [IRR17 (9)(8)]

• Contingency arrangements (where a risk assessment under IRR99 (8) has identified a reasonably foreseeable radiation accident).[IRR17(13)(2)]

• Name of the appointed RPS for the area (contact details etc). [IRR17 (18)(5)]

• Identification and description of the designated area (and details of designation – supervised or controlled). [IRR17 (19)(1)]

• Arrangements / working instructions etc aimed at restricting exposures (to include arrangements for allowing non-classified radiation workers to enter the controlled area). [IRR17 (19)(3)]

If local rules are only being used to meet best practice (i.e. there is no designated area) then you may not need to include, for example, the dose investigation level, since you annual dose limit will need to be below 1mSv (and you will probably not be using dosimetry either).

The above ‘mandatory’ items can then be supplemented (if required) by any or all of the following (depending on nature of the work).

(a) testing and maintenance of engineering controls and design features, safety features and warning devices (i.e planned routine tests)

(b) radiation and contamination monitoring

(c) examination and testing of radiation monitoring equipment

(d) personal dosimetry (the distribution and collection, what to do if dosimetry is lost etc)

(e) arrangements for pregnant and breastfeeding staff

(f) details of significant findings of the risk assessment, or where it can be found (including a copy or risk assessment reference is good practice)

(g) a programme for reviewing whether doses are being kept ALARP and local rules remain effective

(h) procedures for initiating investigations etc

(i) procedures for contacting and consulting the appointed RPA ( often left out, as this is not a mandatory inclusion. Ionactive thinks it should be).

Proceed to IRR17 (18) - Local rules and radiation protection supervisors part 2 to consider the role of the RPS.