Answer: Within the Ionising Radiation Regulations 1999 (IRR) there is a schedule of activities that are exempt from the full requirements of the IRR regarding authorisation, notification, and the appointment of a radiation protection advisor (RPA). There is a separate schedule of radionuclide emission thresholds, below which, again, you are exempt. The full Regulations, including Schedules 1 and 8, are available here. When explicit information about the active particles is not known, it is not possible to comment fully on the extent to which the Regulations apply and, therefore, whether the services of an RPA are needed (under reg.13), or whether it is a notifiable process (under reg.6). The best initial course of action would be to contact the manufacturers/importers of the equipment and get them to verify that the equipment is a sealed source (as defined in the IRR), or that it falls below the threshold limits stipulated in Schedule 8, and that therefore an exemption from Schedule 1 is applicable. As has been indicated, with the equipment being a sealed source there should be a straightforward exemption under Schedule 1(c)(ii) – again the manufacturer can confirm this. An RPA is not needed under reg.13 (3) when “the only work with ionising radiation is specified in Schedule 1”. Where there is no need for the services of an RPA, a suitable assessment must still be undertaken, and adequate training and information provided for all employees. The process should be protected from impacts and collisions, adverse environmental conditions, and from misuse. Appropriate training should be provided for the operators of the process and all supervisors within the area. In addition to usual operating procedures the assessment should consider any maintenance or servicing activities associated with the equipment, and an emergency procedure in the event of damage. With it being a sealed source there should be no need for any intrusive maintenance activities, but it is likely that there will be servicing requirements; information about performing this safely should be provided by the manufacturer. There is a guidance statement within the ACoP (L 121) that the services of an RPA could be used, even if not explicitly required under the IRR, in order to verify the suitability of the company’s arrangements. To take this additional step would be clear evidence that the employer has exercised due diligence. The best indicator as to whether this additional step is required should again be the information from the manufacturers. DISCLAIMER
Every care is taken in the preparation of these questions and answers, which are supplied by Croner Consulting, a trading division of WoltersKluwer(UK) Ltd. Any advice or guidance contained herein is not to be taken as the official advice or guidance of IOSH or SHP/UBM. The information is correct at the time the answer was formulated and posted. However, the answers given can only address the general principles involved. Professional advice must be sought on any specific query or problem your business has relating to any issue or area raised.
