Health and Safety Executive IRR 17 The Graded
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Health and Safety Executive IRR 17: The Graded Approach James Taylor Principal Specialist Inspector (Radiation) Tel: 07879 661820 e. mail: james. taylor@hse. gov. uk
1. HSE Graded Approach • • Notification Registration Licensing ……of a practice – Practice means a human activity that can increase the exposure of individuals to radiation from a radiation source and is managed as a planned exposure situation;
2. HSE Notification • • Small quantities of radioactive material • Transitional arrangement Radon NORM Likely simple system – Digital/Electronic • Who, what, where – Will have until Feb 2018 to notify – May be able to pre-notify from Oct 2017
3. HSE Registration • the operation of radiation generators or accelerators or radioactive sources for medical exposures or for non-medical imaging purposes • the operation of radiation generators or accelerators, except electron microscopes, or radioactive sources for purposes not covered by point (a). • This will cover the majority of practices – approximately 28, 000 dutyholders • Each registerable practice will require separate application
4. HSE Registration • • Electronic system with possible small fee • Give assurance to HSE that permission can be granted – determine risk profile to inform inspection • Must be registered by Feb 2018 – May be able to pre-register from Oct 2017 Require submission of information/confirmation – on the basis of around 8 -10 questions.
5. Registraion: Indicative Questions • Confirmation that you have completed a risk assessment to identify the main radiological risks associated with your work and identified any reasonably foreseeable radiation accident ? • Confirmation that you have identified and completed actions that will restrict your employees’ and other persons exposure to ionising radiation to a level which is as low as reasonably practicable?
6. • Confirmation that you have drawn up contingency plans for any reasonably foreseeable radiation accident? • Confirmation that you have provided adequate training to those of your employees engaged in work with ionising radiation and those likely to be affected by that work?
7. • Confirmation that you have, where legally required, designated and demarcated controlled and supervised areas? • Confirmation that you have taken steps to measure and/or estimate your employees’ exposure to ionising radiation?
8. • Confirmation that you have, where legally required, drawn up written local rules and appointed radiation protection supervisor(s)? • Confirmation that you have consulted an RPA as to the observance of the IRR 17?
9. HSE Licensing Occupational exposure aspects of: • the deliberate administration of radioactive substances to persons and, in so far as the radiation protection of human beings is concerned, animals for the purpose of medical or veterinary diagnosis, treatment or research • the deliberate addition of radioactive substances in the production or manufacture of consumer products or other products, including medicinal products, and the import of such products • any practice involving a high-activity sealed source;
10. • For consistency HSE will be exercising options available from BSSD to license the following practices – Industrial radiography – Work with particle accelerators – Industrial irradiation.
11. HSE Licensing • • Likely to be digital/electronic with fee • Practices will have to be licensed by Feb 2018 – May be able to apply from Oct 2017 • May not be known as licensing – May be granted ‘permission’ or ‘approval’ to carry out practice? Processes under development – Licence conditions?
12. Indicative Questions • Confirmation that the overall management, planning, organising, controlling and reviewing of this radiation risk have been considered
13. • Confirmation that they have appointed and consulted with a suitable radiation protection adviser (RPA) • Confirmation that those engaged in the practice have received appropriate training in radiological protection
14. • Confirmation that those engaged in the practice have been informed of the radiological risks to their health from the practice and the precautions that should be taken • Confirmation that those engaged in the practice will receive regular updates/refresher training in radiological protection
15. • Confirmation that those employees not engaged in work with ionising radiation but who are likely to be affected by it have received appropriate training in radiological protection.
16. • Confirmation that the design features; engineering controls; and safety features of the facility and the radiation sources are such that exposures to radiation will be as low as reasonably practicable (ALARP) • The maximum anticipated total annual effective dose( in m. Sv) to an employee engaged in the practice
17. The maximum anticipated total annual dose equivalent (in m. Sv) to an employee engaged in the practice for: (i)Lens of the eye (ii)Extremities (iii)Single organ or tissue
18. • The maximum anticipated total annual effective dose (in m. Sv) to an employee not directly engaged in the practice • The maximum anticipated total annual effective dose (in m. Sv) to a member of the public
19. Confirmation that a prior risk assessment has been completed that has identified: (i) ways in which potential exposures or accidental and unintended medical exposures could occur; (ii)the probabilities and magnitude of potential exposures to the extent practicable (iii)the quality and extent of protection and safety provisions, including engineering features, as well as administrative procedures required to all exposures ALARP; (iv)the operational limits and conditions of operation
20. • Confirmation that contingency plans for all reasonably foreseeable radiation accident have been drawn up and that they are rehearsed at suitable intervals • Confirmation that the applicability of REPPIR has been considered
21. • Confirmation that a maintenance, testing, inspection and servicing regime is in place which ensures that the radiation source and the facility continue to meet the design requirements, operational limits and conditions of operation throughout their lifetime • Confirmation that the management of any radioactive waste will ensure that exposures to employees will be ALARP
22. • Confirmation that the management of any disused source or radiation generators will ensure that exposures to employees will be ALARP • Confirmation that where appropriate suitable and sufficient quality assurance regimes are in place
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