IRR17 (3) - Application
Published: Sept 29, 2021
Source: Ionactive Radiation Protection Resource
The regulations apply to employers, employees, self-employed persons and trainees engaged in:
- any practice,
- any work other than a practice, that is carried out in an atmosphere containing radon gas at an annual average activity concentration in air exceeding 300Bq/m3
- any work with any substance containing naturally occurring radioactive materials (which is a defined practice under IRR17). Note this is a practice under IRR17 but we have separated for clarity.
'Work in a radon atmosphere' would include work in mines or any other premises where these is insufficient ventilation (natural or forced) to keep the concentrations below the levels specified.
This regulation is also used to disapply certain regulations for particular circumstances. For example:
Radon Atmosphere: There is no requirement for 'Accident Dosimetry' IRR17(24), or a need to 'account for radioactive materials' IRR17 (28-31).
For persons undergoing a 'medical exposure' there is no need to carry out a prior risk assessment IRR17 (8), or follow the duties to restrict exposure IRR17 (9) for that person. These issues are covered in the Ionising Radiations (Medical Exposures) Regulations 2017 - but note they have a different meaning.
Note that some medical related matters have now been transferred over to the Ionising Radiations (Medical Exposures) Regulations 2017 (IRMER 2017). In IRR17 the following has been inserted into this regulation:
- 'carers and comforters” means individuals knowingly and willingly incurring an exposure to ionising radiation by helping, other than as part of their occupation, in the support and comfort of individuals undergoing or having undergone a medical exposure (other than as a carer and comforter). Exposures to those providing comfort and care are treated as medical exposures and are regulated under IRMER 2017.
Further Ionactive resource
The following additional Ionactive resource may help to highlight how "IRR17 (3) - Application" can work in practice. Note that some of the resources may contain Ionactive 'opinion' which can diverge from what is written in this guidance so far.
Radon
Occupational exposure to naturally occurring radon gas in the workplace is a hot topic. It applies to all workplaces, including those where there is no intention to work with ionising radiation (e.g. NOT using x-ray units / working with artificial radioactive materials etc). There is an expectation from the UK regulators (HSE / ONR) that those undertaking work involving a registration [IRR17 (6)] or consent [IRR17 (7)] should have assessed radon risk. This expectation extends to all other workplaces - although it is not practicable for all of these places to be regulated in the same way.
Radon gas in schools (and other workplaces) - blog article which analyses a school prosecution, where the employer had staff and pupils who were exposed to radon gas. The article then details radon exposure more generally - it is a useful primer for all who need to be aware of radon risk in their workplace.
Practice
As you will see shortly: certain work [IRR17 (05)], certain practices [IRR17 (6)] and specified practices [IRR17 (7)] are covered in IRR17. An example of a specified practice is industrial radiography (placed at the high end of radiation risk potential, so requires a consent). Here is an Ionactive blog link to a comprehensive article on industrial radiography : Potential occupational, non-occupational and accidental radiation exposures in industrial radiography using radioactive sources.