- IRR17 (14) - Radiation Protection Adviser (RPA)
- IRR17 (15) - Information, instruction and training
- IRR17 (16) - Co-operation between employers
IRR17 (14) - Radiation Protection Adviser (RPA)
Every employer carrying out work with ionising radiation, (i.e. work which does not meet the criteria in Schedule 1 of IRR17), must consult with a suitable Radiation Protection Advisers (RPA) as is necessary to secure compliance. This requirement extends to all areas of IRR17. Generally, if you have to register (IRR17 – Regulation 6), or gain consent (IRR17 – Regulation 7), then you will need to consult with a RPA and appoint in writing. This requirement in practice would also extend to notification (IRR17 – Regulation 5) and interpreting the use of Schedule 1.
If you need an Radiation Protection Adviser service right now, then jump straight to the Ionactive RPA Services page.
Mandatory consultation is required with regards to the following matters (specified in IRR17 – Schedule 4).
Schedule 4 Matters in respect of which a radiation protection adviser must be consulted
(1) The implementation of requirements for controlled and supervised areas.
(2) The prior examination of plans for installations and the acceptance into service of new or modified sources of ionising radiation in relation to any engineering controls, design features, safety features and warning devices provided to restrict exposure to ionising radiation.
(3) The regular calibration of equipment provided for monitoring levels of ionising radiation and the regular checking that such equipment is serviceable and correctly used.
(4) The periodic examination and testing of engineering controls, design features, safety features and warning devices and regular checking of systems of work provided to restrict exposure to ionising radiation.
In addition to the items noted above the following are also examples of matters for RPA consultation.
(a) the radiation risk assessment required by regulation 8
(b) the designation of controlled and supervised areas as required by regulation 17
(c) the handling of the various investigations required by the regulations
(d) the drawing up of contingency plans required by regulation 13
(e) the dose assessment and recording required by regulation 22
(f) the quality assurance programme in respect of medical equipment or apparatus required by regulation 33
(g) the practical implementation of radiation protection and ALARP.
Seeking RPA advice (the importance of risk assessment)
In our view, the single biggest weakness in radiation protection is the risk assessment (IRR17 - Regulation 8). In almost all cases the traditional maxtrix approach to risk assessment will not be adequate when evaluating radiation safety. The risk assessment is the hub to which everything else you do originates from - seeking RPA advice when producing a risk assessment is highly recommended. In fact, this is made clear in the ACoP to IRR17 as already stated in our Regulation 8 resource, paragraph 72 states "When conducting a radiation risk assessment, employers must consult a radiation protection adviser (RPA) about the matters to be considered"
What advice should I expect from my Radiation Protection Adviser (RPA)
In addition to all the matters so far mentioned, an employer should expect to ask the RPA for advice regarding one or more of the following:
(a) using ALARP and defining appropriate dose constraints
(b) installation of new sources of radiation, or modification of existing sources (including engineering features and controls, safety systems, design etc)
(c) choosing to define controlled and supervised areas
(d) classification of workers
(e) defining outside workers and considering their training needs
(f) the use of PPE (including selection, training and maintenance)
(g) workplace monitoring and personnel monitoring programmes
(h) selection of radiation monitoring instrumentation (if need) and subsequence training and annual testing
(i) quality assurance of the radiation safety system, monitors, records and similar
(j) contingency arrangements for prevention of accidents and incidents
(k) training and refresher courses for those working with ionising radiation, awareness training for others
(l) investigation of accidents and incidents and appropriate remedial actions
(m) suitable arrangements for pregnant and breastfeeding employees
(n) preparation of documentation such as risk assessments, local rules and contingency arrangements.
IRR17 (15) - Information, instruction and training
Employers must ensure that employees working with radiation are given suitable and sufficient training in radiation protection. The training must be suitable to allow them to know:
- the key risks to health caused by exposure to ionising radiation
- the precautions which should be taken (e.g. time, distance, shielding and PPE - and when to use them)
- the control measures that are required
- the importance of the medical, technical and administrative requirements of the Regulations (e.g. local rules and the RPS)
- what to do (or not do) if things go wrong
The scope of training should generally be derived from the risk assessment (IRR17 - Regulation 8).
Apart from the largest users of ionising radiation who may run in-house training, most employers will send certain employees on Radiation Protection Supervisor (RPS) training courses. If you need such training imminently then jump straight to the Ionactive RPS Training Course page. The RPS has an important role in radiation safety, supervising the safe use of ionising radiation in compliance with local rules. Find out more about the the RPS and local rules in IRR17 - Regulation 18. We have also produced some specific guidance here: Do i need local rules or a RPS?
The local rules contain mandatory information as specified in IRR17 - Regulation 18. They contain the essential information and instructions for restricting exposure to ionising radiation. The local rules should be read and understood by all those working with sources of radiation and a signed declaration maintained (...i have read, understood and will comply with these local rules...).
HASS (High Activity Sealed Sources) have special mention in IRR17. HASS sources have the potential to deliver significant radiation exposures when used incorrectly - exceeding dose limits in a matter of minutes. In severe cases of over exposure HASS sources are capable of delivering radiation doses leading to deterministic effects (e.g. radiation burns or sickness ) or even death.
HASS training requirements include:
(a) the safe management and control of HASS sources for routine use, and any reasonably foreseeable radiation accident
(b) emphasis on the necessary safety requirements in connection with HASS sources (e.g shielding, security, monitoring etc)
(c) specific information on the possible consequences of the loss of adequate control of HASS sources (and avoiding this)
HASS source training requirements
The HASS training requirements may contain one or more of the following matters:
(a) training and instruction on the radiation safety measures required when working with HASS sources
(b) training and instruction for those undertaking maintenance , including leak tests (IRR17 - Regulation 28)
(c) training and instruction in fire prevention (e.g. suitable storage locations, fire detection and mitigation)
(d) training in management procedures for coping with any lost, loose or detached sources
(e) training and instruction in the emergency procedures for reasonably foreseeable accidents (e.g. fire, source recovery etc)
(f) information on the radiation risks to anyone who comes too close to an unshielded HASS source, particularly if the source is damaged
(g) information on the possible serious consequences of the loss of adequate control of HASS sources
(h) training and instruction in contingency arrangements which must be followed in the event of loss, theft or unauthorised use of HASS
Other persons (not directly / routinely working with ionising radiation)
Adequate information (and / or instruction and training) must be given to other persons not directly working with ionising radiation. This point is often forgotten. For example, the following may need some degree of training:
- ‘Goods In’ personnel who may handle radioactive packages.
- ‘Despatch’ personnel who may deal with the consignment of radioactive packages
- An electrical engineer who is required to work on interlocks of an x-ray facility
- A theatre nurse responsible for handling discarded instruments used in radio-diagnostic procedures
- A cleaner who enters supervised or controlled areas
- Those required to implement contingency arrangements (e.g. security personnel at a nuclear site)
In the above examples each could be ‘working with ionising’ radiation – even though their primary role is not specifically ‘radiation related’.
IRR17 has expanded the definition of outside workers. All outside workers are employees of a particular employer (A) who work in a designated (controlled or supervised) area of employer (B). Outside workers are then split into classified outside workers, and non-classified outside workers. IRR17 adds non-classified outside workers which were not recognised under the previous IRR99. In combination with IRR17 Regulation 16 (cooperation between employers), Regulation 15 requires that outside workers are given sufficient information, instruction and training in order to work safely and compliantly in designated areas for which they may have little prior knowledge of. Depending on the levels of complexity and radiation risks in the work area, this may be achieved by a briefing, short meeting, reading local rules or an induction training session.
Where appropriate, and presented in the local rules, specific information and instruction may be given to female employees who work with ionising radiation. Female employees must be informed of the possible risk to the foetus and to a nursing infant (if they are using unsealed sources of ionising radiation). To mitigate these risks, the importance of informing their employer in writing at the earliest opportunity, of either pregnancy or breast feeding must be emphasised. If this is required, given regard to the type of radiation work involved, then this must be clearly stated in local rules.
IRR17 (16) - Co-operation between employers
The basic requirement for co-operation between employers sharing a workplace is contained in Regulation 9 and 12 of the Management of Health and Safety at Work Regulations 1999. This is required under IRR17 (16), where work with ionising radiation undertaken by one employer is likely to give rise to the exposure to ionising radiations of the employee of another employer.
The employers concerned are required to co-operate by the exchange of information to ensure that each is able to comply with the requirements of IRR17. In this context their ability to comply relates only to that which depends on the co-operation. Note that IRR17 has now removed the designation 'radiation employer' - it is now up to both employers to determine where compliance is required and how it is achieved - by cooperation.
Typically, this regulation may affect an employer in one of the following ways:
- Contractors who work on another employers site
- Employees working at other sites where ionising radiations are being used
- Employees who have several employers
The first situation may be conveniently managed by a Permit to Work system and careful supervision by the RPS to ensure that local rules are complied with.
If contractors are required to work in the vicinity of controlled or supervised areas - see IRR17 Regulation 17 - this regulation requires that sufficient training be given to the contractors so that they understand the potential hazards and residual risks. Such training and understanding may also be necessary in the reverse situation, for example when industrial radiography is to take place on the employer's site. The degree of training required will depend on the extent, duration and complexity of the work being undertaken (as well as the degree of supervision).
The second situation highlighted above is often more difficult to manage and it is in these circumstances where sufficient co-operation is vital. The employer needs to ensure that they have procedures which require their employees to report to a responsible person as soon as they arrive on the other employer’s site. It is likely that the RPS’s from each site will need to communicate and this may also extend to the respective Radiation Protection Advisers. For classified outside workers (see below), formal provision of dose information and fitness will be required.
Cooperation is especially important with respect to outside workers. IRR17 has extended the definition of outside workers to include non-classified workers (under IRR99 they were only classified workers who worked in a designated area, other than one managed by their own employer). Now all workers, who undertake work in another employers designated area, (i.e. classified outside workers, and non-classified outside workers), are owed specific duties regarding adequate information, instruction and training. The extent of this, and the degree of cooperation required, will depend on the nature of the radiation hazards. Here are some matters to consider:
(a) the detail of the work to be carried out (method statements etc will help here)
(b) the type of likely radiation exposure (the risk assessment will describe radiation sources and likely exposures)
(c) an estimate of the total dose likely to arise from the work
(d) the work procedures that will be required to keep doses as low as reasonably practicable (including any use of special protective equipment)
(e) the risks associated with the work and the precautions that should be taken (induction training may be important here)
(f) any local restrictions that will be applied (understanding the nature of the work area and local rules is vital)
(g) the local rules that apply in the other employer's site (including emergency arrangements and contingency plans)
(h) radiation protection supervisors - RPS (who they are, contact details, their onsite availability etc)
(i) any relevant dose constraints and associated local investigation levels (specified in the local rules and method statements)