Radiation



The Ionising Radiations Regulations 2017 came into force in January 2018, repealing and replacing the Ionising Radiation Regulations 1999 and implementing the requirements of the European Basic Safety Standards Directive (2013/59/Euratom) (BSSD).


The 2017 regulations introduce two main changes:


• the dose limit for exposure to the lens of the eye is reduced from 150mSv to 20mSv in a year. Dose limits are the radiation exposure levels that must not be exceeded and are set out in Schedule 3 of the 2017 regulations. The regulations also allow five-year averaging for the dose limit to the lens of the eye, subject to HSE-specified conditions. 


• depending on the level of risk, employers are required to notify, register or obtain consent from the HSE, even if they have already told the HSE that they work with ionising radiation. There is now a three-tier system of notification, registration and consent, depending on the size and likelihood of exposure. This replaces the previous requirement under the 1999 regulations for notification and prior authorisation.


The HSE summarises these and other changes as follows:


• lowering the dose limit to the lens of the eye;


• flexibility for five-year averaging for dose limit to lens of the eye, subject to conditions specified by HSE;


• changing the radon reference level. The radon reference level under the 1999 regulations was over a 24-hour period, while the BSSD expresses the reference level on an annual basis. The reference level set out in the 1999 regulations is broadly equivalent to the annual average reference level set out in the 2017 regulations;


• introducing a three-tier system of notification, registration and consent that replaces the previous requirement for notification and prior authorisation;


• changing the requirement for notification, which for some radionuclides is at a lower threshold than in the 1999 regulations;


• broadening the scope of the definition of an outside worker to include both classified and non-classified workers;


• introducing new weighting factors for dosimetry;


• changing the dose record retention period from 50 years to not less than 30 years after the last day of work;


• introducing a requirement to put procedures in place to estimate doses to members of the public;


• removing the requirement for a registered medical practitioner to be appointed ‘in writing’;


• introducing a requirement for authorisation of the annual whole-body dose limit in special cases: the HSE or the Office for Nuclear Regulation (ONR) may authorise the application of an effective dose limit of 100 mSv over five years (with no more than 50 mSv in a single year) rather than duty holders only giving prior notification;


• recording and analysis of significant events, ie radiation accidents;


• removing the subsidiary dose limit for the abdomen of a woman of reproductive capacity; and


• removing references to “radiation employers”, a term that has previously caused confusion, and replacing it with employers.


In summary:


Regulations 5, 6 and 7 set out the three-tier system of notification, registration and consent which has replaces the previous requirement for notification and prior authorisation.


The regulations set out the following dose limits (in Schedule 3):


For employees and trainees of 18 years of age or above:


• the limit on the dose of radiation to the whole body (the effective dose) is 20mSv in any calendar year;


• the limit on equivalent dose for the lens of the eye is 20 mSv in a calendar year; or 100 mSv in any period of five consecutive calendar years subject to a maximum equivalent dose of 50 mSv in any single calendar year; 


• the limit on equivalent dose for the skin is 500 mSv in a calendar year as applied to the dose averaged over any area of 1 cm2 regardless of the area exposed; and


• the limit on equivalent dose for the extremities is 500 mSv in a calendar year. 


For trainees under 18 years:


• the limit on effective dose is 6 mSv in any calendar year; 


• the limit on equivalent dose for the lens of the eye is 15 mSv in a calendar year; 


• the limit on equivalent dose for the skin is 150 mSv in a calendar year as applied to the dose averaged over any area of 1 cm2 regardless of the area exposed; and 


• the limit on equivalent dose for the extremities is 150 mSv in a calendar year.


The limit on effective dose for any person other than an employee or trainee referred to above, including any person below the age of 16, is 1 mSv in any calendar year. This does not apply in relation to any person (not being a carer and comforter who may be exposed to ionising radiation resulting from the medical exposure of another person. In these cases, the limit on effective dose is 5 mSv in any period of five consecutive calendar years. The limit on equivalent dose for the lens of the eye is 15 mSv in any calendar year; the limit on equivalent dose for the skin is 50 mSv in any calendar year averaged over any 1 cm2 area regardless of the area exposed; and the limit on equivalent dose for the extremities is 50 mSv in a calendar year.


Key sections of the regulations include the following:


• Regulation 8 requires employers to carry out a suitable and sufficient radiation risk assessment before commencing any new activity with ionising radiation. This was previously known as a prior risk assessment and complements the requirements of Regulation 3 of the Management of Health and Safety at Work Regulations 1999 (see Chapter 3).


• Regulation 9 requires employers to work through a hierarchy of measures to restrict exposure to ionising radiations so far as is reasonably practicable — engineering controls, supporting systems of work and PPE as a last resort. 


• Regulation 10 requires employers to ensure that any PPE provided must be suitable and there are adequate facilities provided for the storage of equipment. 


• Regulation 11 requires employers to maintain engineering controls and PPE and examine and test them at appropriate intervals where appropriate.


• Regulation 12 requires employers to make sure that exposures arising from the work are kept as low as reasonably practicable. Complying with dose limits (see above) is an absolute requirement.


• Regulation 13 sets out requirements in relation to contingency plans (see below).


• Regulation 14 requires employers engaged in work with ionising radiation to consult a suitable Radiation Protection Advisor (RPA) to advise on the regulations. 


• Regulation 15 requires employers to ensure that employees working with ionising radiation are given appropriate training in the field of radiation protection and receive suitable and sufficient information and instruction on the risks to health; the precautions to be taken; and the importance of complying with the medical, technical and administrative requirements of the regulations. They should also give adequate information to other people who are directly concerned with the work with ionising radiation carried on by the employer to ensure their health and safety. 


They should inform female employees working with ionising radiation of the possible risk arising from ionising radiation to the foetus and to a nursing infant and of the importance of informing the employer in writing as soon as possible after becoming aware that they are pregnant or if they intend to breastfeed. 


Regulation 16 deals with work with ionising radiation undertaken by one employer likely to give rise to the exposure to ionising radiation of an employee of another employer. The employers concerned must co-operate, by exchanging information for example, so they all have access to information on the possible exposure of their employees to ionising radiation and can comply with the requirements of the regulations. 


Regulations 17–20 require employers to designate and monitor areas in which employees may receive a significant radiation dose and have written rules in place. They must appoint Radiation Protection Supervisors to ensure compliance with the regulations and local rules.


Regulation 21 requires employers to designate employees who are likely to receive a radiation dose greater than 6 mSv per year or an equivalent dose greater than 15 mSv per year for the lens of the eye or greater than 150 mSv per year for the skin or the extremities as classified persons. They must immediately inform those employees that they have been designated as such. Classified persons must be over 18 years of age and a relevant doctor must have certified in a health record that that employee is fit for the work with ionising radiation which that employee is to carry out.


Regulation 22 requires employers to appoint an approved dosimetry service (ADS) to monitor the radiation dose and to keep the dose records.


Regulation 25 sets out the requirements concerning medical surveillance. 


Regulations 26 and 27 explain what action must be taken in the event of an over-exposure.