Health and Safety Executive Recent HSE Radiation Team

Health and Safety Executive Recent HSE Radiation Team Health Care Inspections James Taylor PSI (Radiation) HSE Radiation. Team email: james. taylor@hse. gov. uk

NHS Trust Inspections 18/19 • 6 NHS Trust Inspections – Ionising Radiations Regulations 2017 – L 121 ACo. P ‘Work with Radiation’ – Management of Health and Safety at Work Regulations 1999 • 100% material breach rate so all received a Notification of Contravention (No. C) and two Improvement Notices were issued.

General Issue • Management of radiological protection – Inadequate overall management of radiological protection – Insufficient planning, organisation, control, monitoring and review – No central policy regarding the training on radiation protection. – Responsibilities not assigned • No overall control

IRR 17 Common Failings: 1. Risk Assessments • Suitable and sufficient radiation risk assessments not undertaken – Dose investigation levels too high – Level of RPS supervision not specified – Monitoring requirements not properly identified – Radiation accidents not identified • Thus no contingency plans – Risks to ‘non-employees’ not identified

• The requirements for radiation risk assessments are quite clear • • See ACo. P paras 70 -71 Some NHS Trusts not following this guidance

2. Reg 9: Restriction of Exposure. ALARP • Contamination control, access control and monitoring in Nuclear Medicine Dept. – Improvement notice served • Insufficient or inadequate warning devices for brachytherapy – Improvement notice served • Investigation levels exceeded but no investigations carried out

3. Reg 13: Contingency Planning • • Contingency plans not rehearsed • Insufficient number of contingency plans (Not all reasonably foreseeable radiation accidents identified as part of radiation risk assessment) Contingency plans summary or reference not in local rules

4. Reg 15: Information, Instruction and Training • Should be for all employees engaged in work with ionising radiations or likely to be affected by it. – Includes cleaning and ancillary staff! • Refresher training not always performed – Must include clinicians

5. Reg 18: Local Rules and Radiation Protection Supervisors • Local rules too generic – were not key working instructions • Insufficient number of RPSs – If actions of RPSs specified in contingency plans they must be available to carry out those actions • RPSs not given sufficient time to supervise work

6. Reg 20: Monitoring of Designated Areas • Contamination monitoring within and outside nuclear medicine controlled areas not sufficient – Must be sufficient to indicate breakdowns in controls or systems and detect changes in contamination levels

7. Reg 21: Designation of Classified Persons • Basis of classification is likely routine exposures and exposures that could be incurred as a result of a radiation accident – Generally, more NHS persons should be classified due to likely routine exposures and those that could be incurred as a result of an accident • Classification level is not a threshold!

8: Other IRR 17 Issues • Cooperation between employers – External engineers – Agency staff – Students • • Accounting for radioactive materials Personal dosimetry – Section 7 of HSW Act 1974

Registrations and Consents • Compliance with IRR 17 is a condition of registration and consent • Registrations and consents may be revoked if this condition is not met. • Standard IRR 17 No. C text: – You should note that HSE has the power to revoke your consents should you fail to comply with the conditions to which they are subject.