IRR17 (5) - Notification of certain work
Published: Sep 29, 2021
Regulations 5-7 under the new IRR17 introduces a risk-based approach for informing the HSE (the UK regulator for IRR17) about the work you undertake using ionising radiation. Regulation 5 is for notification of certain work that falls at the lower end of the risk spectrum.
Regardless of what type of work you do involving ionising radiation, you will be required to make an application to HSE via their website portal at the following address:
Notification applies to work except work
- arising from a practice that needs to be registered under Regulation 6, or a specified practice that needs a consent under Regulation 7.
- work specified under Schedule 1
- work on a nuclear licensed site
- work involving items contaminated with radioactive materials, where that material has been deemed by a UK environment agency to be outside of regulatory control (e.g. following a permitted disposal/release to the environment)
For almost all cases involving X-ray generators, you will need to at least register. If your x-ray generator falls into work specified under Schedule 1, then you will not need to register or notify. However – care is required! You need to carefully read the clauses in Schedule 1. It might well appear that your x-ray equipment complies – however, Schedule 1 will only apply to x-ray equipment if it is ‘a type approved by the Executive’. During the time of IRR99 (January 2000 to December 2017) no x-ray equipment was approved by the executive (HSE). The HSE has no plans to type approve equipment in the future.
The Exemption flowcharts in Schedule 1 of IRR17 are useful but care needs to be taken in their interpretation – if in doubt seek advice from an Ionactive Radiation Protection Adviser.
The bottom line is that very few ‘users’ are likely to notify as the thresholds are so low. Most will either register (Regulation 6) or require consent (Regulation 7)
The site you are working on uses up to 50 MBq of P-32 at any one time for research processes. The volume/mass of the material is low (<< 1000 kg). The work is using radioactive material for its radioactive properties (tracer analysis). You need to look up Flow Chart 1 and the data for P-32 from Schedule 7 of IRR17 (extracts of these follow below after the text). Following chart 1, and looking up P-32 from Schedule 7 we have the following:
- Column 2 is 1000 Bq/g. Our 50 MBq will exceed this (specific activity 'Bq per ml/g' will be much higher). So, the work is NOT exempt.
- Column 3 is 10,000 Bq. Our 50 MBq exceeds this. So, the work is again not exempt.
- Is the quantity of material < 1000 Kg? Yes it is.
- Column 4 is 1000 Bq/g. Our 50 MBq will exceed this (specific activity 'Bq per ml/g' will be much higher). So, a registration IS required (a notification will not suffice)
The diagram and data below are taken from the Ionising Radiations Regulations 2017 (IRR17) - ACoP.