IRR17 (8) – Radiation risk assessments

Regulation 8 (risk assessment) is the "hub" for everything else you need to do to work safely with ionising radiation. Ionactive spent much time with new clients in Q3 and Q4 of 2018 dealing with HSE improvement notices, and in all cases a huge weakness was insufficient risk assessments. Ionactive strongly believes that the simple 'matrix' approach to workplaces risk assessments are generally inadequate for all but the most simple uses of ionising radiation.

The IRR17 ACoP for Regulation 8 states in paragraph 72 "When conducting a radiation risk assessment, employers must consult a radiation protection adviser (RPA) about the matters to be considered". Ensuring this consultation is in place early will enable the employer to comply with the rest of IRR17 in a timely fashion.

Before an employer commences any new activity, they must make a suitable and sufficient assessment of the risk to any employee, or other person, to allow appropriate controls to be established. The assessment must demonstrate:

  • all hazards with the potential to cause a radiation accident are identified
  • the nature and magnitude of risks to the above persons are identified
  • where risks from a radiation accident are identified, steps are taken to prevent the accident, to limit its consequences, and provide employees with the information, instruction, and training to restrict their exposure

Paragraphs 70 and 71 of the IRR17 ACoP provide a very useful set of risk assessment considerations. These now form part of every Ionactive radiation risk assessment. There is no such thing as "non-applicable" - a statement that explains why you 'do not need to do something' is as important as a statement that describes when you 'do need to do something'. If you believe you do not need external dosimetry, or you do not need classified workers, then your risk assessment should explain why.

Whilst IRR17 allows for risk assessment to be proportional to the radiation hazard, our advice is that if you consider each and every risk element shown below (writing a short statement for the reasons why you do or do not need to consider a risk element ), then you cannot go far wrong.

Using IRR17 ACoP - Regulation 8

ACoP Paragraph 70

Ensure you have an answer/statement for each of the following:

(a) the nature of the sources of ionising radiation to be used, or likely to be present, including accumulation of radon in the working environment

(b) estimated radiation dose rates to which anyone can be exposed

(c) the likelihood of contamination arising and being spread

(d) the results of any previous personal dosimetry or area monitoring relevant to the proposed work

(e) advice from the manufacturer or supplier of equipment about its safe use and maintenance

(f) engineering control measures and design features already in place, or planned

(g) any planned systems of work

(h) estimated levels of airborne and surface contamination likely to be encountered

(i) the effectiveness and the suitability of PPE to be provided

(j) the extent of unrestricted access to working areas where dose rates or contamination levels are likely to be significant

(k) reasonably foreseeable accident situations, their likelihood and potential severity

(l) the consequences of reasonably foreseeable failures of control measures – such as electrical interlocks, ventilation systems and warning devices – or systems of work

(m) steps to prevent possible accidents, or limit their consequences

ACoP Paragraph 71

Once you have completed an entry for each of the risk assessment elements above, you will be able to provide information for the questions presented below:

(a) the action needed to make sure the radiation exposure of all people is kept as low as reasonably practicable (regulation 9(1))

(b) the steps necessary to achieve this control of exposure by the use of engineering controls, design features, safety devices and warning devices (regulation 9(2)(a)) and, in addition, to develop systems of work (regulation 9(2)(b))

(c) whether it is appropriate to provide PPE, and if so, what type is adequate and suitable (regulation 9(2)(c))

(d) whether it is appropriate to establish any dose constraints for planning or design purposes and if so, what values will be used (regulation 9(4))

(e) the need to alter the working conditions of any employee who declares they are pregnant or breastfeeding (regulation 9(6))

(f) an appropriate investigation level to check that exposures are being restricted as far as reasonably practicable (regulation 9(8))

(g) the maintenance and testing schedules required for the control measures selected (regulation 11)

(h) what contingency plans are necessary to address reasonably foreseeable accidents (regulation 13)

(i) the training needs of classified and non-classified employees (regulation 15)

(j) the need to designate specific areas as controlled or supervised areas and to specify local rules (regulations 17 and 18)

(k) the actions needed to make sure access is restricted and other specific measures are put in place in controlled or supervised areas (regulation 19)

(l) the need to designate certain employees as classified persons (regulation 21)

(m) the content of a suitable programme of dose assessment for employees designated as classified persons, and for others who enter controlled areas (regulations 19 and 22)

(n) the requirements for the leak testing of radioactive sources (regulation 28)

(o) the responsibilities of managers and workers (including outside workers) for ensuring compliance with these regulations

(p) an appropriate programme of monitoring or auditing of arrangements to check the requirements of these regulations are being met.

You should consult with a Radiation Protection Adviser (RPA) in order to ensure your risk assessment is suitable and sufficient. The extract that follows provides an example of a risk assessment for an x-ray machine used in the cargo and freight sector. Note the level of detail.

Risk assessment examples

Risk assessment example 1

Radiation risk assessment - Example 1

Risk assessment example 2

Radiation risk assessment example 2

There are children playing in the street who could solve some of my top problems in physics, because they have modes of sensory perception that I lost long ago.

– J. Robert Oppenheimer -