IRR17 (7) – Consent to carry out specified practices

(February 2023) - whilst IRR17 is not being superseded, there are going to be significant changes to the way consents are applied for, and how new and on-going consents are regulated. The information below remains valid at the moment, but the reader may wish to visit our latest blog article on this subject: New UK Consent process for users of Ionising Radiation (as of February 2023). The remaining information in this section will be updated during 2023 after the regulators issue their formal guidance.

The following specified practices are considered to be higher risk than those allowable under notification (lowest risk - IRR17 Regulation 5) or registration (medium risk - IRR17 Regulation 6). If the employer undertakes one or more of the following, you need to gain consent from the HSE before you can start work. A consent is required for each specified practice that you undertake. Failure to meet the conditions of the consent means you cannot start the work (or continue the work if already underway).

(a) the deliberate administration of radioactive substances to persons and, in so far as the radiation protection of persons is concerned, animals for the purpose of medical or veterinary diagnosis, treatment or research

(b) the exploitation and closure of uranium mines

(c) the deliberate addition of radioactive substances in the production or manufacture of consumer products or other products, including medicinal products

(d) the operation of an accelerator (except when operated as part of a practice within sub-paragraph (e) or (f) below and except an electron microscope);

(e) industrial radiography

(f) industrial irradiation

(g) any practice involving a high-activity sealed source (other than one within sub-paragraph (e) or (f) above);

(h) the operation, decommissioning or closure of any facility for the long-term storage or disposal of radioactive waste (including facilities managing radioactive waste for this purpose) but not any such facility situated on a site licensed under section 1 of the Nuclear Installations Act 1965

(i) practices discharging significant amounts of radioactive material with airborne or liquid effluent into the environment.

Although the 9 categories appear in IRR17, the UK does not have uranium mines. Therefore during the application process only 8 specified practices will be offered, uranium mines is not an option.

Upon successfully applying to HSE and receiving a consent, you will be served with a consent certificate which will contain a summary of the data submitted during the application process. The following extract from an actual consent highlights the confirmations that have been made. In addition to the rest of IRR17, it is most likely that during an HSE inspection the confirmations will be checked off against your IRR17 procedures and systems.

The ultimate paradox, of course, is that even though we're all going to die, we've all got to live in the meantime…

– Brian Cox -