Radiation

The Ionising Radiation Regulations 1999 require employers to:

• undertake a suitable and sufficient risk assessment before starting any new type of work with ionising radiation;

• restrict exposure to ionising radiation, firstly through means such as the use of adequate shielding, safety devices, containment and ventilation, where these are reasonably practicable, then by the provision of systems of work and personal protective equipment;

• maintain and examine engineering controls and personal protective equipment;

• consider the risks to pregnant and breast-feeding employees and alter working conditions where appropriate;

• consult (and appoint) one or more radiation protection advisers;

• designate controlled and supervised areas where necessary;

• implement dose limits; and

• make arrangements for designating certain employees as classified persons, arranging for the assessment and recording of doses they receive, and medical surveillance.

These regulations limit the dose of radiation to the whole body (the effective dose) to which workers aged 18 and over can be exposed to 20 millisieverts (mSv) in a calendar year. However, in special cases, a dose limit of 100mSv in five years may apply, with no more than 50mSv in a single year, subject to strict conditions.

For trainees, the limit is 6mSv in a calendar year, and for any other person, including members of the public, the limit is 1mSv a year.

The HSE has published guidance on planning for emergencies involving radiation releases with the potential to affect the public, which supports the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR). The REPPIR implement the emergency planning aspects of a European directive setting out basic safety standards for the protection of the health of workers and the general public against the dangers from ionising radiation.

The regulations apply to fixed sites, rail transport and the transfer of radioactive substances across public places (other than by standard means of transport).

The Basic Safety Standards (BSS) Directive (2013/59/Euratom), was adopted on the 5 December 2013. The new BSS Directive incorporates the latest recommendations from the International Commission on Radiological Protection (ICRP) published in 2007, and harmonises the EU regime with the Basic Safety Standards of the International Atomic Energy Agency (IAEA). The UK government has to implement the Directive into UK law by the 6 February 2018.

In September 2014, Rolls Royce Marine Power Operations Ltd was fined £200,000 and ordered to pay costs of £176,500 following the loss of a radioactive source at its plant in Derby. The company manufactures components for nuclear submarines and uses radioactive sources (containing Ytterbium -169) in its industrial radiography work to test that welds are perfect. Leicester Crown Court heard that significant failings led to a radioactive source (a capsule the size of a small screw) being lost for approximately five hours at the Sinfin Lane site on 3 March 2011. As a result, a number of workers were exposed to high levels of gamma radiation, in some cases many times in excess of relevant legal dose limits. The incident prompted a joint investigation by the HSE and Environment Agency, who jointly prosecuted the company, after serious concerns were identified. The investigation found the workers’ hand exposure to radiation was considerably in excess of the annual permitted dose of 500 millisieverts. In some cases it was exceeded by up to 32 times the permitted amount.

Electromagnetic fields

Electromagnetic fields (EMFs) are a form of radiation that can affect the central nervous system and the body’s temperature at certain frequencies. EMF exposure can occur in any workplace that uses electrical equipment. There is currently no specific UK legislation on EMFs, so the general duties in the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999 apply. The National Radiological Protection Board (NRPB), now part of the Radiation Protection Division of the Health Protection Agency, has produced guidelines on occupational exposure to EMFs.

New directive on workers’ exposure to electromagnetic fields

A new directive on workers’ exposure to electromagnetic fields was adopted on 29 June 2013 and Member States have until 1 July 2016 to transpose the new provisions.

The new text takes account of the recommendations published by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) in 2009 and 2010. It introduces a system of exposure limit values (ELVs) “on the basis of biophysical and biological considerations, in particular on the basis of scientifically well-established short-term and acute direct effects, i.e. thermal effects and electrical stimulation of tissues.”

It does not address the long-term effects, as it is considered that there is currently not enough scientific evidence. But it does require the Commission to take into account new scientific knowledge in this area.

The Directive also allows for exceptions in medical applications using magnetic resonance imaging (MRI), for some sectors (subject to decision by Member States), but only if the circumstances duly justify exceeding the ELVs, and on a temporary basis.

It will mean that employers must assess the risks of exposure to EMFs and take measures needed to reduce them. If maximum exposure limits are exceeded, they must devise and implement a technical and organisational action plan.

The European Trade Union Confederation (ETUC) criticised the directive at draft stage, saying that it “short-changed” workers and put them at “deadly risk” because it only covered short-term effects of exposure and disregarded the long-term effects.

The European Trade Union Institute (ETUI) recently produced new guidance on preventing exposure to electromagnetic fields (EMFs) which also aims to help workers to understand the new EU Directive on occupational exposure to EMFs. The guide provides an overview of occupational exposure to EMFs according to frequency: static fields, low, intermediate and radio frequencies. It also recommends how a precautionary approach can help to reduce high exposure.

Optical radiation

The Control of Artificial Optical Radiation at Work Regulations 2010 (CAORWR) came into force in April 2010. The CAORWR are intended to implement a European Union (EU) Directive to protect workers from hazardous sources of artificial light, such as UV radiation and powerful lasers. These light sources can damage the eyes and skin if not properly managed. The regulations only cover artificial sources of optical radiation and not natural sources, such as the sun.

Common sources of light in workplaces like office lights, photocopiers and computers are not affected by the regulations. However, they apply to organisations using hazardous light sources as part of their work activities. HSE guidance provides examples of safe light sources as well as sources of light that, if used inappropriately, for example, placed extremely close to the eyes or skin, have the potential to cause harm but which are safe under normal conditions of use. It also sets out examples of hazardous sources of light that present a reasonably “foreseeable” risk of harming the eyes and skin of workers and where control measures are needed, as follows:

• metal working — welding (both arc and oxy-fuel) and plasma cutting;

• pharmaceutical and research — UV fluorescence and sterilisation systems;

• hot industries — furnaces;

• printing — UV curing of inks;

• motor vehicle repairs — UV curing of paints and welding;

• medical and cosmetic treatments — laser surgery, blue light and UV therapies;

• intense pulsed light sources (IPLs);

• industry, research and education, for example, all use of Class 3B and Class 4 lasers, as defined in British Standard BS EN 60825-1: 2007; and

• any Risk Group 3 lamp or lamp system (including LEDs), as defined in British Standard BS EN 62471: 2008, for example search lights, professional projections systems.

It advises that less common hazardous sources are associated with specialist activities, for example, lasers exposed during the manufacture or repair of equipment, which would otherwise not be accessible.

The regulations contain minimum standards for the prevention and early diagnosis of damage to the eyes and skin from optical radiation. They set exposure limit values and require employers to carry out risk assessments. The regulations enact worker rights to information, training, consultation and health checks.

HSE advice is available at: www.hse.gov.uk/radiation/nonionising/employers-aor.pdf

Sunlight

A new study by Imperial College London, commissioned by the Institute of Occupational Safety and Health (IOSH), recently reported that skin cancers caused by sun exposure at work are killing nearly 50 workers every year. The research gives the first full picture of the “skin cancer burden” on those working outdoors in industries including construction, agriculture, leisure and entertainment. It also found that 240 new cases are being registered each year.

A separate study, also commissioned by IOSH, found a lack of awareness of the risks of solar or ultraviolet (UV) radiation in construction — the industry hardest hit by the disease. A University of Nottingham study into work attitudes to sun safety found that two thirds of construction workers outside for an average of nearly seven hours a day thought that they were not at risk or were unsure about the risks. More than half (59%) reported having sunburn, a major contributor to skin cancer, at least once a year. And the research found a “macho culture” in parts of the industry and misconceptions about the risk in the UK climate.

IOSH has called on employers to develop “sun safety strategies” that include regular updates on the ultraviolet (UV) index from weather forecasts, minimising sun exposure in the middle of the day and asking employees to wear long-sleeved, loose-fitting tops and trousers.

The CWU joined forces with Royal Mail and IOSH to launch a new sun safety campaign, Sun Smart, Skin Safe. The focus of the campaign is on raising awareness about the risks from sunlight exposure and harmful UV rays and on the primary defence — covering up. Further information about the campaign is available at: www.cwu.org/news/archive/-no-time-to-lose-to-beat-occupational-cancer.html