Ionising Radiations Regulations 2017 (IRR17) Guidance - Part 5 - Classification & Monitoring of Persons

An employer is required to designate a person as being classified if that person is likely to receive an effective (whole body) dose in excess of 6mSv/y, or more than three-tenths of the dose limit to the extremities (150 mSv/y). Furthermore, classified worker status will be required where 75% of the dose limit to the lens of the eye is likely to be exceeded (15mSv/y). Designation will be based on external exposure, internal exposure or both depending on the nature of the ionising radiation source.

Designation should be justified solely on the basis of an assessment of potential dose and not on the basis of previous dose history. Furthermore, medical exposure history should not be taken into account.

In deciding what is likely, the employer needs to consider routine occupational radiation exposures, as well as exposures from reasonably foreseeable incidents. This requires a careful assessment of the radiation work, likely exposures should be recorded in the radiation risk assessment, see IRR17 (8) Radiations Risk Assessment.

High hazard radiation sources

Anyone working with high hazard sources of ionising radiation, e.g. capable of delivering an effective dose greater than 20 mSv, or an equivalent dose in excess of a dose limit (e.g. > 500 mSv to the hands) within a few minutes, should be designated as classified. This should be on the basis that this occurrence is a reasonably foreseeable radiation incident.

Site industrial radiographers would for example be designated as Classified Persons as a matter of course since such persons have the potential to receive a significant exposure very rapidly should an incident occur which is incorrectly dealt with.

Example (1)

An industrial radiographer is undertaking site radiography using a 740 GBq (20 Ci) Ir-192 source. The source becomes detached from its control wire and the individual uses poor practice by grabbing the source briefly and placing it into an emergency lead pot. The dose rate at 1cm from the source will be of the order of 233 mSv/second, so is a good approximation of hand (extremity) dose rate. Therefore, just over 2 seconds of exposure will lead to an extremity dose exceeding 500 mSv. Whilst this is an extreme example, and no trained radiographer should be expected to do this, it is reasonably foreseeable, and that individual should be a classified person.

Example (2)

A hospital uses a linear accelerator (linac) in a concrete bunker for the purposes of cancer treatment (radiotherapy). The headline dose rate from the linac is 6Gy/min at 1m. For the purposes of this example, this is equivalent to 6 Sv/min at 1m.

The hospital and their RPA need to determine if the radiotherapy staff setting up patients and operating the linac from the control room need to be classified. Exposures outside the bunker are so close to background as to be ignored. To leave the bunker the hospital staff need to press a ‘last person out’ button and then confirm exit when leaving the bunker (via a maze or shielding door). This procedure, active signage (e.g. “Beam On) inside the bunker, and emergency-off buttons are designed to ensure no person, other than a patient undergoing treatment, could be exposed. However, suppose despite all these features, a staff member is left inside the bunker and the linac starts producing radiation? It is not reasonably foreseeable that a trained operator would align themselves with the collimated linac beam. It is, at a push, reasonably foreseeable that they might be elsewhere in the bunker and receive an exposure for a short duration (say 5 seconds) before pushing an emergency stop.

Dose rates within the bunker, outside the confines of the primary beam, will be in the order of 100’s micro Sv/h to 100 mSv/h. Taking the 100 mSv/h as an upper case, that is around 2mSv/ minute. Even at this high dose rate, it is not foreseeable that a person would remain in this area for more than a few seconds before stopping the linac and / or leaving the bunker (which would break interlocks and stop the linac). Therefore, it is common practice in this work sector that radiotherapy staff are not classified radiation workers since:

(a) Routine exposures will be very near background exposures.

(b) Reasonably foreseeable incident exposures will not breach the classified worker limits (see above), and in any case, would not deliver a radiation dose approaching an annual dose limit over the short period of an exposure.

Others reasons for classified persons

Some radiation employers tend to classify certain employees based on their position in the company (e.g. RPS), or for reassurance purposes. There is nothing particularly wrong in this, but it should be remembered that like designated areas, the administrative burden is much higher (formal dose records, health reviews etc).

Classified persons requirements

For a person to be designated as a classified person they must be at least 18 years old, and a relevant doctor (Appointed Doctor) needs to make an entry into the person's health record stating they are ‘fit’ to be classified.

Employees must be notified immediately on designation and cessation of designation (in writing). Cessation is only permitted at the end of a calendar year unless:

• an Appointed Doctor requires this
• the employee is employed for the remainder of the year, but in a capacity not likely to result in significant exposure (i.e. > 1mSv year)

Other matters which need to be considered include:

• Employees or other persons who are not classified may only enter a controlled area under written arrangements (these will normally be included in the local rules).
• Where female employees are involved, the employer should be aware of the special restrictions or potential changes to working practice once pregnancy is declared, and if breastfeeding (where unsealed radioactive materials are involved). This should be specified in local rules.
• The employer should be aware that their classified employees will require pass books to enter the Controlled Areas of another employer (where they will be designated classified outside workers). This is particularly relevant for cyclotron service engineers who will be classified person (although if they take the controlled area over during service they are not outside workers).

Dose assessment and recording is much more complicated than many employers expect. In order to keep this guidance concise will will only deal with the legislative aspects of dose assessment here, but will produce some future practical guidance on dosimeter selection, wearing correctly and local management of record keeping.

This guidance will firstly consider dosimetry for classified persons - see IRR17 (21) - Designation of Classified Persons for guidance on whether an employee needs to be classified. We will then look at dose assessment for non-classified persons which make up the majority of radiation users in the UK (outside of the nuclear industry).

Dosimetry for Classified Persons

An employer must ensure that, for each classified person, an assessment is made of all significant doses received and that such assessments are recorded. For this purpose, they are required to make arrangements with an Approved Dosimetry Service (ADS). Some examples of UK based ADS are given in our links section: dosimetry links.

Dose records must be kept for each classified person, until they are (or would have been) 75 years of age, but in any case for 30 years from the the record was first made. The ADS will provide the employer with dose summaries and ‘termination’ records. They will also send summaries to HSE.

Dose summaries - the ADS will normally provide monthly or 3-monthly dose entry reports to the employer (depending on wear period of the employee - usually monthly for most classified persons). The ADS will also provide a quarterly dose summary and an annual summary (normally annual exposures for last five years will also be included). The employer must ensure that their classified persons have access to their dose record.

Termination records - these are provided by the ADS to the employer (for onward delivery to the employee) when the employee classified person status is removed (where the employee remains with the company), or where the employee moves to a new employer and remains a classified worker.

Classified outside workers

For classified outside workers the ADS will provide a current radiation passbook. An employer must ensure that entries in a passbook are kept up to date and only made by people authorised by the ADS or the appropriate employer. Arrangements for this should include written instructions as to who does what and when. The RPS will normally carry out this administrative function. The passbook will contain relevant dose information (e.g. exposures in the calendar year to date, previous annual dose data, and a declaration by the appointed doctor indicating that the worker is 'fit').

This regulation applies to Classified Persons, non-classified employees who have received an over exposure and any employee subject to conditions imposed by the relevant doctor (Appointed Doctor or Employment Medical Advisor).

The employer has a duty to ensure that each of their employees to whom this regulation applies, is under adequate medical surveillance. This should include:

• A medical examination before being designated.
• A periodic review of health (i.e. annually).
• Special surveillance when a relevant dose limit has been exceeded, including a medical examination if any limit has been exceeded by a factor of two or more.
• Determination of whether specific conditions are necessary.
• A review of health after the cessation of work if this is necessary to safeguard health.

The particulars to be kept in a Health Record are given in Schedule 6 of IRR17.

An entry in the Dose Record is valid for 12 months, or such shorter time as may be specified by the Appointed Doctor or the Employment Medical Adviser, or unless cancelled by either of them.

As mentioned previously, some employers designate their employees as Classified Persons for reasons other than just predicted radiation exposure. One reason is that this then requires an annual review of health (which is considered a reward or company ‘perk’ by many). However in more recent times the 'review' (for that is what it is) has moved away from what many feel was an otherwise value medical.

Where an employer suspects that any person may have received an overexposure, as a result of work that he has undertaken, they must make an immediate investigation to determine beyond reasonable doubt that no overexposure could have occurred.

Unless this is shown to be so, the employer must:

• notify the overexposure to HSE
• where the employee is from another employer, notify that employer, and,
• in the case of his own employee, inform relevant doctor (appointed doctor)

The employer must arrange for an investigation of the circumstances and determine the measures to be taken to avoid a recurrence. They must notify their own employee of the results of the investigation, and in the case of a person not being their employee, notify them of his overexposure.

Records of the immediate investigation must be kept for at least 2 years, and of the full investigation, until the person involved has or would have reached the age of 75, but not less than 30 years.

Whilst an RPS would be expected to be involved in this investigation, they would do so in consultation with the Radiation Protection Adviser.

It must never be assumed that an overexposure is not a real occurrence, however more often that not it is shown to be false. The following picture depicts a typical scenario where a personal exposure did not actually occur.