Ionising Radiation Policy Statement
SOCOTEC UK is the UK’s leading Environmental Compliance Company offering inspection, testing, investigation and advice to customers through an unrivalled range of technical expertise and accredited services.
Whenever work with ionising radiation is undertaken within SOCOTEC UK, then it shall be with due regard to current legislation and the relevant internal Local Rules and Standard Operating Procedures. No work with Ionising radiation shall be conducted within SOCOTEC UK, without a prior risk assessment being conducted; the relevant Radiation Protection Adviser (RPA) must be consulted.
This policy ensures that all activities involving radioactive / nuclear samples, materials and closed sources are detailed in Standard Operating Procedures / Local Rules or equivalent, which are valid, and have been authorised by a senior manager / Director. Ensure that these Standard Operating Procedures / Local Rules have considered Best Available Techniques to minimise any radiation doses to persons undertaking the activities described within, and would not reasonably be considered as procedures leading to radiation doses at or above the statutory dose limits stipulated in the current Ionising Radiations Regulations (IRRs) and its Approved Code of Practice (ACOP), or exceeding the following Dose Restriction Level:
- A dose equivalent of 20 mSv per annum; and
- An average effective dose equivalent of 15 mSv per annum over any 5 consecutive calendar years
Generally SOCOTEC UK staff will not be exposed to a greater effective dose than the general public, at an average of 1 mSv per year. Principal legislation at this time is:
Ionising Radiations Regulations 2017 (IRR17) - applies to work with ionising radiations including sealed sources, open sources, radioactive materials and X-ray generators. An associated guidance document advises employers on how to comply with Regulations 5,6,7 of IRR 17. These documents include a “graded approach” where regulatory measures are proportionate to the size and likelihood of exposures resulting from work:-
- Regulation 5 – Notification of certain work involving ionising radiation to HSE
- Regulation 6 – Registration of certain work practices involving ionising radiation to HSE
- Regulation 7 – Consent from HSE to perform specific work practices
SOCOTEC UK Ltd, as the employer, has Notified, or applied for Registration and gained consents where applicable, using the HSE online application system.
Environmental Permitting (England and Wales) Regulations 2016 (SI 2016/1154) - applies to the permitted use, registration and safe keeping of radioactive sources. On 1 September 2018, the Environmental Authorisations (Scotland) Regulations 2018 came into force for radioactive substances activities in Scotland. This replaced the Radioactive Substances Act 1993 (RSA93), associated Exemption Order and the High-Activity Sealed Sources and Orphan Sources Regulations 2005.
Environmental Permitting (England and Wales) (Amendment) Regulations 2011 (EPR11) - Contain “exemptions” and guidance if materials are “out of scope” of the regulations, including source storage, use and waste disposal.
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 and Use of Transportable Pressure Equipment Regulations 2009 and (Amendment) Regulations 2011 - These regulations cover the transport of radioactive material on the public highway and are enforced and policed by the Office for Nuclear Regulation (ONR), Police and Driver and Vehicle Standards Agency (DVSA).
The Health and Safety (Amendment) (EU Exit) Regulations 2018 (SI 2018/1370) - Minor changes are made to terminology to reflect that the UK is no longer an EU member state. The changes do not alter the duties in the Regulations. [March 2019]
The above legislation and local rules and procedures contain the fundamental requirements needed to control and restrict the exposure of employees when carrying out work with ionising radiations involving any source and shall be observed by all employees working at the SOCOTEC UK laboratories and also at external customer sites.
Ensure that training is provided to all persons required to follow Standard Operating Procedures / Local Rules for work with radiation and that as far as is reasonably practical, ensure that all persons follow Standard Operating Procedures / Local Rules and the respective training.
Ensure that Safety Monitoring has been arranged for the Sites of SOCOTEC UK as specified in the Environment Agency permit(s) and is operational under the direct management of an appropriately authorised manager with advice from the appropriate RPA. Ensure that these Safety Monitoring arrangements include checks that:-
- The requirements of this instruction are being carried out,
- Local Rules have been established and are being adhered to, where appropriate
To ensure that the above requirements are met, the SOCOTEC UK businesses have in accordance with the Ionising Radiation Regulations 2017, appointed Radiation Protection Advisers (RPA's). The RPA(s) will provide advice and guidance on all matters relating to ionising radiations and will also provide any necessary technical support, such as monitoring, required to fulfill those duties.
In addition, at every SOCOTEC UK location, where work with ionising radiations is carried out, the Manager responsible for that location shall appoint one or more Radiation Protection Supervisor's (RPS's), who have had suitable training and direct knowledge of the day to day work. A senior co-ordinating RPS may also be appointed for a business, particularly where multiple locations are involved.
A Radioactive Waste Advisor has been appointed in order for us to discharge our responsibilities as a producer of Radioactive Waste.
Group Health and Safety issues are dealt with by SOCOTEC UK Health, Safety and Environment Managers.
Identified staff are being monitored.
Chief Executive Officer
SOCOTEC UK Limited