IRR17 (29) - Accounting for Radioactive Material

An employer must keep records of the quantity and location of radioactive substances and sources. They must be kept for at least 2 years after they were made and for at least 2 years after disposal of the radioactive material.

The records should be in a format that will allow loss of any significant quantity of radioactive material to be readily identified. Frequency of checking will depend on likely movements of material and how they are used (e.g. dilutions in laboratories and similar).

The IRR17 ACoP states that for static sources attached to machines, the interval between checks may be up to 1 month and for portable sources checks should be made daily.

IRR17 ACoP paragraph 579 is useful . This paragraph has the legal status of ‘guidance’ and therefore following it can be assumed to be acceptable, if not best practice. It states that employers who are subject to the requirements of the environmental permitting legislation may use a single system of accounting which satisfies both sets of legal requirements. For the UK the relevant legislation is as follows:

• England and Wales: Environment Permitting (England and Wales) Regulations 2017 (as amended 2018)
• Scotland: Environmental Authorisations (Scotland) Regulations 2018
• Northern Ireland: Radioactive Substances Act 1993 (amended 2011)

Many employers utilise the RPS to ensure that accounting under IRR17 and the environmental legislation is compliant. This is one reason an RPS will be appointed regardless of the legal need to do so (i.e. where these is no legal need to designate an area as Supervised or Controlled).

It should be noted that none of three sets of legislation above define the RPS (only IRR17 does this). Therefore, whilst the RPS may take on a role assisting with the compliance of radioactive substances environmental legislation, it is NOT within the specific remit of the RPS (other than for compliance with IRR17 which may not go as far as the environmental legislation). Modern legislation like EPR2016 specifies the requirement for competent persons - this could be the RPS if suitably experienced.