WORKING WITH IONISING RADIATION

Transcription

1 NERC HEALTH & SAFETY PROCEDURE NUMBER: 35 WORKING WITH IONISING RADIATION VERSION NUMBER: 1.0 DATE OF ISSUE: 27 July 2009 INTRODUCTION NERC is committed to the provision of a safe working environment for the protection of its employees and visiting workers. This includes work with radioactive materials and that involving sources of ionising radiation. All work utilising radioactive materials (as stand-alone sealed/unsealed sources or incorporated into other devices) and radiation generators (e.g. X-ray equipment), which emit ionising radiation is subject to the requirements of the Ionising Radiation Regulations 1999 (abbreviated as IRR99). IRR99 is mainly concerned with the protection of people from the effects of ionising radiation i.e. the effects of ionising radiation on the health of an individual. IRR99 is enforced principally by the HSE. It is a requirement of IRR99 that the employer appoints an approved competent Radiation Protection Adviser (abbreviated as RPA) to provide them with expert assistance. The use, storage and disposal of radioactive material in the UK is also subject to the Radioactive Substances Act 1993 (abbreviated as RSA93), which is primarily concerned with the environmental consequences of holding/using radioactive sources whether sealed (closed) or unsealed (open) or ionising radiation generated by static or mobile devices. RSA93 focusses on the protection of the environment from the hazards associated with these materials/ processes and is enforced principally by the Environment Agency or its equivalent in the British Isles. RSA93 requires that users of radioactive materials be registered with the enforcing authority and are authorised by that body for their keeping and use, accumulation and disposal of radioactive waste together with maintenance of complete records. There is also a considerable body of other UK and European legislation which may, wholly or in part, apply to other aspects of radioactive materials e.g. transport. A summarised list of relevant current legislation is provided in Appendix I. The purpose of this procedure is to provide advice to NERC staff, associates and visitors whose work involves radioactive materials to help ensure compliance with the requirements of current UK legislation (RSA93 and IRR99). It provides guidance only sites with specialist knowledge should already have detailed Local Rules in place. Further assistance is obtainable from your Radiation Protection Advisor and from the Environment Agency-Radio Active Substances (RAS) Division or equivalent regional authority.

2 Health Protection Agency (HPA) NERC employs the Health Protection Agency (HPA) under contract to act as its Radiation Protection Advisor (RPA) for the majority of its sites and collaborative centres that use either radioactive materials and/or ionising radiation generating equipment. However, there are some sites with NERC employees that employ an independent RPA e.g. Universities. Information and contact details about your RPA must be included in the Local Rules for control of radioactive materials on your site. Users should always consult their RPA for advice in the early planning stage before using radioactive materials or radiation generating equipment of any type and before entering into any collaborative work with other organisations which may involve their use. For more information on the HPA and its services, see < >. Reporting of Accidents, Injuries and Near-Misses All accidents, injuries, and near-misses, related to the use of ionising radiation and radioactive materials must be entered into the local accident reporting system. In certain circumstances (refer to paragraph 22 & 61 Contingency Plans), the HSE and the local administering authority must be informed, these are: England & Wales - The Environment Agency (EA) < > Scotland - The Scottish Environmental Protection Agency (SEPA) < > Northern Ireland Environment & Heritage Service-Industrial Pollution and Radiochemical Inspectorate (IPRI) < >. Please note that where the text of this document refers to the Environment Agency this applies to England and Wales only the alternative regional authorities given above should be substituted for Scotland and Northern Ireland where appropriate. A Glossary of terms and acronyms used in this document is provided in Appendix X.

3 TABLE OF CONTENTS INTRODUCTION Section A: Getting Started: The Legislative Framework, Roles and Responsibilities The Radioactive Substances Act 1993: Legal Requirements for Control of the Use, Storage and Disposal of Radioactive Materials & Sources of Ionising Radiation 1. Summary & Justification 2. Definition of Terms - Radioactive Material & Ionising Radiation 3. Application & Registration to Keep and Use Radioactive Materials, & Amendments to existing Authorisations 4. Certificates & Authorisations to Keep and Use Radioactive Materials & Mobile Radioactive/Ionising Radiation Generating Apparatus. 5. Mobile Apparatus 6. Authorisation to Accumulate and Dispose of Radioactive Waste 7. Documentation and Record Keeping 8. Radiochemical Inspectors - the Environment Agency 9. Radiochemical Inspectors - Enforcement & Prohibition Notices 10. Exemption Orders 11. Cessation of Work The Ionising Radiation Regulations 1999: Legal Requirements for Control of Work with Radioactive Materials & Ionising Radiation 12. Summary 13. Definition of work with ionising radiation practice 14. Authorisation of Specified Practices 15. Notification of Specified work 16. Risk Assessment 17. Restriction of Radiation Exposure - General Controls 18. Dose Constraints - General 19. Dose Constraints - Young Persons and New or Expectant Mothers 20. Dose Constraints - Local Dose Investigation Level 21. Dose Limitation 22. Contingency Plans - Incidents, Accidents & Emergencies 23. The Radiation Protection Supervisor (RPS) 24. The Radiation Protection Advisor (RPA) 25. Training, Information & Competence 26. Co-operation between Employers 27. Local Rules 28. Designated Areas - General 29. Designated Controlled Areas 30. Designated Supervised Areas 31. Contamination Monitoring of Designated Areas 32. Classified Persons - Designation 33. Classified persons Termination of Classified Status 34. Classified Persons - Dose Assessment and Recording 35. Classified Persons - Estimated Doses and Special Entries 36. Radiation Workers - Medical Surveillance

4 37. Radiation Workers - Dose Limitation following an Over-Exposure 38. Radiation Workers - Investigation and Notification of Over-Exposures 39. Radiation Workers - Accident Dosimetry 40. Control of Radioactive Materials - General 41. Control of Radioactive Materials - Leak testing 42. Control of Radioactive Materials Record Keeping 43. Control of Radioactive Materials Keeping and Moving 44. Control of Radioactive Materials Notification of Occurrences 45. Control of Radioactive Materials Misuse or Interference with Sources of Ionising Radiation 46. Transport of Radioactive Materials - General 47. Transport of Radioactive Materials - by Road within the UK 48. Transport of Radioactive Materials - outside the UK 49. Duties of Manufacturers, Suppliers and Installers 50. Duties of Employees Roles & Responsibilities 51. Management Organogram Section B: Working with Ionising Radiation 52. Laboratory Design and Materials 53. Administration and Responsibilities 54. Individual Responsibility 55. Local authority to Use Sources of Ionising Radiation 56. Safe Systems of Work 57. Local Rules 58. How to Handle Radioactive Materials - Good Laboratory Practice & personal Hygiene 59. Ordering and Stock Control of Radioactive Materials 60. Disposal of Radioactive Materials 61. Contingencies 62. Annual Limits of Intake (ALI values) 63. Radioactive Materials & Apparatus at Sea 64. Radioactive Materials & Apparatus in the Field Section C: Management, Auditing & Dealing with Inspections 65. Internal Auditing 66. Reports/Returns to the administering body (EA, SEPA or IPRI) 67. Dealing with External Inspections Section D: Appendices Appendix I: Appendix II: Appendix III: Appendix IV: Appendix V: List of current U.K. legislation & ACoP s (including Exemption Orders) HSE documents & other general guidance Risk assessment Training Mobile containerised radiochemical laboratories at sea

5 Appendix VI: Appendix VII: Appendix VIII: Appendix IX: Appendix X: Appendix XI: Appendix XII: Use of Neutron Probes in NERC Template for production of your Local Rules Transport Consignment Note example Sources of further information Glossary of terms & acronyms The law relating to use and disposal of radioactive materials at sea a) Andrew Wright (HPA, formerly NRPB). Advisory document on Keeping and use of radioactive materials on research vessels and disposal of waste arising from research at sea b) Excerpts from correspondence between PML & MAFF on disposal of carbon-14 and tritium at sea Acknowledgements

6 Section A: Getting Started: The Legislative Framework, Roles and Responsibilities This section aims to inform and provide advice to NERC managers, supervisors, staff and visitors working with ionising radiation and radioactive materials with a view to ensuring regulatory compliance and minimising radiation exposures. The Radioactive Substances Act 1993: Control of the Use, Storage and Disposal of Radioactive Materials & Sources of Ionising Radiation 1. Justification & Summary Before considering the use of ionising radiation in scientific work, it is important that all possible alternative methods have been considered and that the proposed work can be scientifically justified. The use, storage and disposal of radioactive material and sources of ionising radiation are subject to the Radioactive Substances Act The purpose of RSA93 is to manage and control radioactive materials in the environment, particularly with respect to radioactive waste. When planning and carrying out work with radioactive materials and ionising radiation there are 2 guiding principles a) to carry out the work by the Best Practicable Means (BPM) and b) to ensure the quantities of materials used and radiation doses to individuals are kept As Low As Reasonably Practicable (ALARP). 2. Definition of Terms & Permissions - Radioactive Material & Ionising Radiation The Radioactive Substances Act 1993 (RSA93) defines what is meant by the terms radioactive material, radioactive waste and mobile radioactive apparatus (Sections 1-3). RSA93 (Section 6) specifically prohibits the use of any radioactive materials of any description without registration, certification and authorisation under section 10 of the Act unless an exemption order applies. RSA93 (Section 9) specifically prohibits the use of any mobile radioactive apparatus of any description without registration, certification and authorisation under section 10 of the Act unless an exemption order applies. 3. Application & Registration to Keep and Use Radioactive Materials, & Amendments to existing Authorisations (See RSA93 Sections 7 to 12) All organisations with premises where work is to be carried out with sealed or unsealed radioactive material must obtain one or more Certificates of Registration from the Environment Agency prior to commencement of that work.

7 Where this work involves use of apparatus which generates ionising radiation, e.g. X- rays, neutron probes/generators & accelerators, there is also a requirement for prior authorisation. There are some exceptions such as use of electron microscopes and X- rays for routine gauging/detection measurements or examination of post/baggage, for example. See paragraph 14. When applying to the Environment Agency or equivalent regional authority for a new registration or the amendment of an existing registration under the Radioactive Substances Act 1993, you should first consult your RPA to discuss your requirements - if you have appointed one at this stage. Alternatively, contact the Environment Agency- Radioactive Substances Division (EA-RAS) who are generally very helpful in these situations or visit their website at and search under PIR/RSR or RAS. You will need to provide the following information: Information about the premises to which the application relates. The type of work to be undertaken on the premises e.g. research. A description of the radioactive materials/ionising radiation generating equipment to be kept and used and the maximum amounts of those materials which will be present on the premises at any one time. The intended use of the radioactive materials/ionising radiation generating equipment. How you intend to dispose of waste radioactive material after use, if applicable. Application forms are available from the EA either by post or in electronic format for the following types of radioactive material: Open or unsealed sources Closed or sealed sources Mobile closed or sealed sources or mobile apparatus Environmental studies 4. Certificates & Authorisations to Keep and Use Radioactive Materials & Mobile Radioactive/Ionising Radiation Generating Apparatus Following a successful application to keep or use radioactive materials, a registration certificate will be issued. As soon as a certificate of registration and authorisation to use radioactive materials or ionising radiation-generating apparatus is granted, the NERC site Director must appoint in writing a competent Radiation Protection Adviser (RPA) and a suitably qualified local Radiation Protection Supervisor (RPS). See paragraphs 23 & 24. The certificate will include limitations and conditions; typical examples are: Restriction on purposes for which radioactive material/radiation generating equipment is kept and used. Maximum numbers and activities of sources. Supervision of sources/equipment. Identification and marking of sources and containers. Measures to control/manage the sources/equipment e.g. prevent unauthorised access. What to do if a source/equipment is lost, stolen or misused.

8 What to do if a source/equipment is damaged or radioactive material is otherwise lost from a sealed source. Arrangements for record keeping. A single Certificate of Authorisation will be issued for each type of radioactive material that is kept or used at a particular premises e.g. unsealed sources or mobile radioactive apparatus. Issue or amendment of a certificate will normally cancel any previous registration which applied to that type of source on those premises. Certificates are normally site specific i.e. they will cover one site only. Copies of registrations will be sent to any local authority in whose area sources or apparatus will be kept or to which disposals may be made. 5. Mobile Apparatus Mobile apparatus includes equipment which is portable and designed to be used for fieldwork measurements or for releasing radioactive material into the environment or introducing it into organisms. See Appendix VI Use of Neutron and Gamma Probes in NERC. 6. Authorisation to Accumulate and Dispose of Radioactive Waste Radioactive waste is defined as any article or substance which, if were not waste, would be radioactive material, or any substance or article which has become contaminated with radioactive material. Users should note that if radioactive material is kept on a premise for more than 3 months without being used, it will be assumed by the enforcing authority to be radioactive waste unless the keeper/user can prove that this is not the case. A Certificate of Authorisation is required under RSA93 for the accumulation and disposal of all radioactive waste unless: the waste is accumulated on a site licensed under the Nuclear Installations Act 1965; or the waste comprises clocks/watches/instruments (but not waste arising from manufacture or repair involving luminous materials); or an Exemption Order (refer to Appendix I) is available. Supervision by a competent person, normally the Radiation Protection Supervisor (RPS), must be provided to ensure that any waste disposals comply with the conditions of the authorisation. The following information will be required for an authorisation (or an amendment to an existing authorisation) under RSA93 to accumulate/dispose of radioactive waste: details of the premises to which the application relates details of the processes leading to the creation of the waste the type of waste generated, in terms of radiological hazard e.g. low/high level waste, physical state (solid, liquid, gas) how the amounts of waste will be limited in terms of radioactivity and volume the proposed disposal routes radionuclides to be disposed and the maximum quantities to be disposed daily/monthly/yearly

9 how you intend to measure or estimate the quantities to be disposed if your disposal is to be discharged to the environment, e.g. via the sewer, an environmental impact assessment will be required. This will be a worst case scenario ask your RPA for assistance. if your disposal is to a third party, e.g. a specialist waste disposal contractor, details of the arrangements will be required including transport from your premises to those of the contractor. To obtain an authorisation to accumulate or dispose of waste, you should also hold a registration certificate for keeping the radioactive material which will constitute the waste. The EA (or other authorising body) may seek approval from relevant local authorities and water boards before granting an authorisation When an authorisation to accumulate and/or dispose of radioactive waste is granted, it may include limitations and conditions such as: types and quantities of radioactive waste which may be accumulated and/or disposed maximum activity or activity concentration to be disposed in terms of particular isotopes or types of emitter e.g. beta or alpha emitters authorised disposal routes for each type of waste authorised storage arrangements for the accumulated waste awaiting disposal appointment of a competent person to supervise the accumulation and/or disposal of waste this will normally be the local RPS measures to be taken to manage the radioactive waste e.g. prevent loss or unauthorised disposal contingency action if accumulated waste is lost or stolen contingency action if radioactive material is found to be leaking from accumulated waste satisfactory arrangements for record making and keeping, including annual returns of amounts disposed to the EA satisfactory arrangements for the sampling and analysis of the waste. A single Certificate of Authorisation will be issued for the accumulation and/or disposal of waste from a particular premise. Issue or amendment of any certificate will normally cancel any previous authorisation which applied to that premise. 6a. Disposal of redundant smoke detectors and ECD s (electron capture detectors from gas chromatographs) Smoke detectors that utilise a radioactive source can be disposed of under an exemption order provided that the source does not exceed? kbq. If the smoke detector exceeds the limit specified in the exemption order then the disposal route is as for an ECD or other sealed source. Sealed sources not covered by one of the exemption orders (e.g. ECD s) require disposal at the end of their operational life by an authorised contractor. Such disposals may incur considerable costs and these should be considered when purchasing/ acquiring equipment containing these sources. 7. Documentation and Record Keeping RSA93 (Section 20) specifies requirements for suitable and sufficient records relating to his use, keeping and disposal of all radioactive materials and other radioactive apparatus (including mobile apparatus) to be made, kept and retained. Employers may be required

10 to retain these records after they cease to hold authorisations for such activities. It is good practice to retain these records for as long as possible, and to ensure that all records are available for inspection by the enforcing authority at any time. In addition, RSA93 (Section 19) requires that copies of the registration certificates and authorisations be displayed on the premises such that they are accessible to persons who have duties under their conditions and also to any other persons who may be affected by matters set out in them. 8. Radiochemical Inspectors the Environment Agency (RSA93 Sections 4-5, 31-schedule 2). Radiochemical Inspectors employed by the EA or other regional enforcing body have the same statutory rights of entry and inspection under RSA93 as do their equivalents in the HSE and local authorities. These rights cover all premises where radioactive material/ionising radiation generating apparatus is kept or used, including those operating under an authorised exemption. An Inspector may enter your premises at any reasonable time and does not have to give prior notice. In an emergency, defined as any instance where the Inspector has reason to believe that there may be an immediate danger to life or health, he may enter at any time. 9. Radiochemical Inspectors - Enforcement & Prohibition Notices (RSA93 Sections 21-22). Enforcement and prohibition notices may be served by a Radiochemical Inspector in the same way as his equivalent in the HSE/local authority. They may be served should NERC or its employees fail to comply with any limitation or condition described in a registration or authorisation certificate. Enforcement notices will specify the steps which must be taken to remedy the unsatisfactory situation and the time in which that remedy must be completed. Prohibition notices will be served by the EA Inspector if he considers that continuing the activity poses an immediate risk of environmental pollution or harm to human health. Remedial action is specified as for the enforcement notice. If you suspect or believe, as a NERC employee, that contravention of a certificate of registration or authorisation under RSA93 has occurred there must be an immediate investigation. There must also be an investigation following any incident or accident involving radioactive materials or radiation generating apparatus. Examples include: Loss or theft of radioactive materials/apparatus Accidental spills or discharges of radioactive materials. Accidental damage to sources/apparatus or tampering/misuse of equipment which may lead to radiation exposure Unauthorised accumulation of waste Keeping quantities of radioactive materials in excess of authorised limits Waste disposals in excess of authorised limits or in contravention of authorised disposal conditions. 10. Exemption Orders

11 These are statutory instruments made under the Act and specify classes of premises, undertakings or persons and descriptions of radioactive material or radioactive apparatus which do not need to be registered or further authorised. The orders are a mechanism for providing a degree of control, without excessive bureaucracy, over minor uses of radioactive substances where there is a clear benefit from its use, whilst ensuring continued protection of the environment and the public. Currently there are 18 exemption orders (EO s) under the Act and those which apply to NERC are listed in Appendix 1. Exemption Orders may exempt employers from certain requirements of RSA93 e.g. the requirement to register the use of a source, or the requirement for an authorisation to dispose of a source. Materials covered by an EO generally pose a minor radiological hazard which is easily controlled by meeting the requirements of the EO. Advice should be sought from your local RPS and your RPA regarding the applicability and use of EO s in your workplace. 11. Cessation of Work When work using radioactive materials or radiation generating equipment finishes, the RPS for the site should inform the EA or other enforcing authority. The EA will need to be assured that no radioactive material or operable apparatus remains on site and that the site is not contaminated. Once it is satisfied that these conditions have been met, the EA will cancel the certificates of registration and authorisation. The Ionising Radiation Regulations 1999: Control of Work with Radioactive Materials & Ionising Radiation 12. Summary Work practices utilising radioactive materials and radiation-generating apparatus (e.g. X- ray equipment) are subject to the requirements of the Ionising Radiation Regulations These regulations and their associated Approved Code of Practice (ACoP) are health and safety regulations that aim to protect individuals against the harmful effects of radioactive materials and ionising radiation. The regulations include requirements for management of the work, appointment of competent persons, risk assessment, dose limitation, supervision of individual workers, training, designation of areas, radiation exposure & contamination monitoring, provision of local rules and record keeping. 13. Definition of work with ionising radiation practice

12 The IRR99 define a Practice as work involving the production, processing, use, handling, storage, transport or disposal of radioactive substances or the operation of any electrical equipment emitting ionising radiation and containing components operating at a potential difference of more than 5 kv which can increase the exposure of individuals to radiation from an artificial source or from a radioactive substance containing naturally occurring radionuclides which are processed for their radioactive, fissile or fertile properties. The IRR99 apply to any Practice. The IRR99 apply to NERC employees and to any student or visitor who is undergoing instruction or training involving operations which would constitute work with ionising radiation if that individual were an employee. 14. Authorisation of Specified Practices There are certain specified practices that must be authorised by the Health and Safety Executive before commencement. These are - The use of x-ray equipment for: - industrial radiography - processing of products - research - the exposure of persons for medical treatment The use of accelerators except electron microscopes If any of the specified practices are to be undertaken on the registered site, further advice must first be obtained from your Radiation Protection Adviser (RPA). 15. Notification of Specified work In general, work with ionising radiation under a new Certificate of Authorisation must be notified to the HSE at least 28 days prior to commencement of that work. Notification is only required once i.e. additional notifications are not required on each occasion a particular type of work is performed unless this has been specifically required by a notice served by the HSE. Subsequently, any significant changes to the work must also be notified to the HSE if these would change the particulars of the original authorisation. 16. Risk Assessment Before beginning any work involving ionising radiation/radioactive materials, a risk assessment must be undertaken if there is no existing assessment available which is appropriate to the work. Measures to be taken to restrict the exposure of employees and others to ionising radiation will be based on this risk assessment and recorded as a written safe system of work. The content of the risk assessment will include, but not be limited to: - details of the radiation sources to be used - the estimated radiation doses to which individuals may be exposed - the likelihood of contamination spread - levels of surface and airborne contamination

13 - possible accident situations - steps to prevent identified accident situations. The project manager is responsible for ensuring the necessary risk assessments are made with the help of the local RPS and with advice obtained from the appointed external RPA. 17. Restriction of Radiation Exposure - General Controls All exposures to ionising radiation must be kept as low as reasonably practicable (the ALARP philosophy). The hierarchy of control measures which should be used to ensure exposures are restricted in accordance with the ALARP principle is as follows: Design features and engineering controls. These include, but are not limited to: - installed shielding - containment (particularly for unsealed radioactive materials) - ventilation systems - beam collimators - interlocks (door or key) - warning devices. These features and controls should be fail-safe. For example, if a warning device on an X-ray generator fails the exposure will cease. It is important that where a warning device is present at the entrance to an area, all persons with access to the location of the warning device understand its purpose and the action they should take when the warning device is activated. NERC employees are responsible for the maintenance and testing of all design or engineering safety features or warning devices. The frequency of the maintenance and testing will depend on the possible dose implications of failure, the reliability of the control measure and the doses likely to be received by an individual carrying out the maintenance or testing. In general, design and engineering control measured should be maintained in accordance with manufacturer s guidelines and tested at least once per year. Safe Systems of Work (SSoW) These include but are not limited to: - manual warning signs - written instructions - permit to work systems. Safe systems of work (sometimes also referred to as Safe Working Practices or SWP s) are procedural controls and require individuals to comply with them in order to be effective. Systems of work are particularly important where normal design or engineering control measures have been disabled, e.g. during maintenance. Local rules are part of the procedural controls implemented for designated areas (see paragraphs 27 & 28). Personal Protective Equipment (PPE) This includes but is not limited to:

14 - generic protective clothing, e.g. laboratory coats, gloves, overshoes, goggles/ safety-spectacles/full face shield. - specialised protective clothing, e.g. lead aprons, thyroid collars - respiratory protective equipment (RPE), e.g. face masks and respirators. PPE must adequately protect the individual from the hazard presented, and must be suitable in terms of use by the individual and in the work environment. The risk assessment for the work should be used to identify the requirement for and type of PPE. NERC must ensure that any PPE (including RPE) which is provided: - complies with the PPE (EC Directive) Regulations 1992, or for RPE is used in accordance with the requirements of HSG53: the Selection, Use and Maintenance of Respiratory Protective Equipment* - is properly used - has adequate storage facilities - is thoroughly examined at suitable intervals - is properly maintained. *Records of the examination of RPE must be kept for at least two years. 18. Dose Constraints - General Dose constraints should be used at the planning stage for any new work with ionising radiation, or where significant changes to current practices are proposed. The dose constraint represents the upper bound on the individual radiation exposure which is acceptable to enable the new or modified activity to be justified. The value of the dose constraint should be agreed between NERC, as the employer, and the appointed RPA. Dose constraints should be compared with estimated doses for the new or modified activity and advice should be sought from the appointed RPA where the predicted dose exceeds the dose constraint. For exposure of members of the public, NERC use a dose constraint of 0.3mSv for any single activity, as recommended by the Health Protection Agency (HPA). This constraint relates in particular, to any disposals of radioactive material via authorised routes. 19. Dose Constraints - Young Persons and New or Expectant Mothers Young Persons: It is NERC policy that no young person, defined as being under the age of 18 years, is allowed to work with radioactive materials or apparatus emitting ionising radiation. This ruling applies whether the individual is employed by the NERC or is a visitor working temporarily on NERC premises. NERC advises its collaborative centres and similar academic organisations receiving NERC funding to follow this policy. New and Expectant Mothers: Once an employee has notified NERC that she is pregnant, the exposure of that employee must be limited to ensure that the dose to the foetus does not exceed 1mSv during the remainder of the pregnancy. Restricting the effective dose to the employee to

15 2mSv will normally be sufficient; however, where there is a risk from an internal radiation hazard, care must be taken to establish the relationship between maternal and foetal exposure to ensure the dose limit is met. New mothers who are breast feeding must not be subject to working conditions where a significant level of bodily contamination could occur. Where the restrictions indicated above are not consistent with the employee s normal work, the employer is required, in accordance with the Management of Health & Safety at Work Regulations 1999 to: - alter the hours of work of the individual; or - identify and offer her suitable alternative work; or - suspend her from work on full pay. N.B. Whilst there is no legal requirement to notify your employer that you are either pregnant or breastfeeding, it is very important for the health of you and your child that you do so in writing as early as possible. This enables your work to be reviewed and assessed to minimise any hazards from exposure to radiation or radioactive materials. Any such information will be treated as strictly confidential and restricted to those staff concerned with managing your work. 20. Dose Constraints - Local Dose Investigation Level Employers must investigate whenever an employee exceeds an effective dose of 15mSv for the first time in any calendar year. However, employers are encouraged to set lower local dose investigation levels which trigger a review of working conditions whenever recorded doses exceed the level anticipated for the work being undertaken. Different investigation levels may be set for different work areas and must be stated in the local rules for the area. Advice should be sought from the appointed RPA when considering an appropriate value for a local investigation level. 21. Dose Limitation The following dose limits must not be exceeded in any calendar year: Employees of 18 years and over Others (including the public) Effective dose (msv) Equivalent dose (millisieverts, msv) eye lens skin extremity In addition, for women of reproductive capacity, the equivalent dose to the abdomen shall be limited to 13mSv in any consecutive three month period. Where a component of the individual s dose has arisen from an intake of radioactive material, the assessment of that dose should take account of the likely dose accrual over the 50 years following the intake, or where the individual is under 18 years of age until they are 70 years old. The committed effective dose should be recorded in the year the intake occurred. Where doses to members of the public are being assessed, realistic estimates of dose should be made, taking into account the expected exposure pathways and representative members of the group most likely to be exposed.

16 The RPA must be informed as soon as possible if it suspected that any dose limit has been exceeded (see also paragraph 17). 22. Contingency Plans Incidents, Accidents & Emergencies Contingency plans must be formulated for any radiation accident which a risk assessment has shown to be reasonably foreseeable. The purpose of the contingency plan is to restrict the exposure to ionising radiation and secure the health and safety of persons who may be affected by the accident. Planning is required for all reasonably foreseeable accidents, even where the doses which could be received are small, e.g. following a spill in a laboratory. The involvement of radioactive materials in fires is normally reasonably foreseeable. The level of detail required in the plan will depend on the accident scenario. However, plans should normally identify: - who will put the plan into effect - the immediate actions for assessing the seriousness of the accident - the immediate actions required to bring the accident under control - what PPE is required and where it may be found - whether any additional dosimetry is required - what training is required for persons involved in or affected by the accident - who to contact for expert advice, e.g. contact details for the appointed RPA - whether and when to call emergency services - how exposures received by individuals involved in the accident and accident - how the response will be assessed and followed up if necessary Where the contingency plans apply to work within a designated area, a copy or summary of the contingency plans must be contained within the local rules for that area. In most cases contingency plans must be rehearsed. The nature and frequency of the rehearsals will depend on: - the potential severity of the accident - the likely doses that could be received - the complexity of the plan - the number of people involved in the implementation - whether the emergency services are involved Advice should be sought from the appointed RPA regarding the setting up and testing of contingency plans. 23. The Radiation Protection Supervisor (RPS) Each NERC site must appoint one or more local Radiation Protection Supervisors (RPS s). The primary role of the RPS is to ensure, on behalf of the NERC site and its Director, compliance with The Ionising Radiations Regulations 1999 (IRR99) in any area subject to its local rules. The appointment should be made in writing by the site Director and should make clear the scope of the RPS s responsibilities. Individuals chosen to be appointed as an RPS should:

17 - know and understand the requirements of IRR99 and local rules - command sufficient authority from the people doing the work to allow them to supervise the radiation protection aspects of that work - understand the necessary precautions to be taken and the extent to which those precautions restrict exposures - know what to do in an emergency Every NERC site should consult its appointed RPA regarding the selection, training and appointment of RPS s. 24. The Radiation Protection Advisor (RPA) When any NERC site applies for, and is granted, a Certificate of Registration & Authorisation to work with radioactive materials/ionising radiation under RSA93, the site Director must appoint a Radiation Protection Adviser (RPA). The appointment must be made in writing and include the scope of the advice which the RPA is required to give. Each NERC site must ensure that the appointed RPA is suitable, i.e. that they hold a certificate of competence (renewable every 5 years) to act as an RPA and have knowledge and experience relevant to NERC s work with ionising radiation. Each NERC site must consult their appointed RPA on the following matters: - implementation of requirements for designated areas - prior examination of plans for new facilities - acceptance into service of new or modified sources of ionising radiation in relation to any control measures - calibration and routine testing of monitoring equipment - periodic examination and testing of control measures. In addition and in accordance with the ACoP, each NERC site should consult their appointed RPA with regard to the following: - risk assessment - designation of supervised and controlled areas - any investigation into personal exposure, e.g. where an individual has exceeded a dose limit or constraint or where the results of personal dosimetry are either not available or not reliable - any investigation into an unauthorised or accidental release of radioactive material - drawing up contingency plans - dose assessment and dose recording - quality assurance programmes for equipment used in connection with medical exposures, e.g. calibration of radiopharmaceutical dispensers. 25. Training, Information & Competence NERC must ensure that all persons who work with radioactive materials/ionising radiation, and those who may be affected by that work, are given suitable and sufficient information, instruction and training to ensure their health and safety is secured. This must include: - the risks to health from exposure to ionising radiation - the precautions which should or can be taken to reduce those risks - the importance of complying with The Ionising Radiations Regulations 1999.

18 In particular, NERC project managers must ensure that individuals are briefed and understand any written arrangements which apply to the work and that individuals working in adjacent areas understand the meaning of any warning signs or signals and what action they need to take, if any, for their own protection. Additional training may be required for Radiation Protection Supervisors (RPS) to enable them to discharge their responsibilities (see paragraph 23). Training for the site RPS s can usually be arranged by the RPA. NERC must also ensure that females are informed of the importance of notifying their employer of pregnancy or if they are breastfeeding. This ensures the correct action is taken to restrict the exposure of the unborn foetus or nursing child. All female employees shall be given a copy of the HSE guidance for new and expectant mothers INDG334 available from the HSE website ( 26. Co-operation between Employers NERC must co-operate with other employers who work with ionising radiation on their premises and with the employers of individuals who are not NERC employees but who are exposed to ionising radiation as a result of NERC business. In particular NERC must provide details of the dose accrued by individuals to their employer and should consult with that employer with regard to the training and restriction of the exposure of those individuals. 27. Local Rules for the Use of Radioactive Materials & Ionising Radiation Local rules must be prepared for all controlled areas and, where appropriate, supervised areas or other lower level areas (<1mSv/year) whether temporary or permanent. The local rules must be set down in writing and be appropriate to the radiation risk and nature of the operations performed in that area. The local rules should identify the key working instructions required to restrict exposure to ionising radiation in that area and should cover normal operations and the action to take in the event of an accident. As a minimum, local rules should contain: - the identification and description of the area covered; - an appropriate summary of the safe working instructions, including written arrangements to ensure non-classified persons doses are restricted; - identification or summary of any contingency arrangements which relate to the area; - the names and contact details of the Radiation Protection Supervisor(s) and Radiation Protection Adviser; - the local dose investigation level (see paragraph 20 above). Every NERC site must ensure that all persons working in an area where local rules apply have read and understood those local rules and that the instructions contained within them are followed. Further guidance is provided in Appendix VII Template for the Production and Management of your Local Rules. 28. Designated Areas - General

19 Each NERC site should consult its appointed RPA regarding the designation of areas to be used for work with radioactive materials/ionising radiation apparatus. The RPA s advice should also be sought on the monitoring of designated areas and selection, use and calibration of monitoring equipment. Under IRR99, designated areas are divided into controlled areas and supervised areas. Under NERC policy the addition of a designated approved area (temporary or permanent) is recommended which is subject to prior approval by the RPS and covered by Local Rules. 29. Designated Controlled Areas According to IRR99, areas must be designated as controlled wherever: - it is necessary for any person who enters that area to follow special procedures in order to restrict their exposure to ionising radiation; or - it is necessary to follow special procedures to prevent or limit the probability and magnitude of radiation accidents or their consequences; or - any person working in that area is likely to receive an effective dose greater than 6mSv a year, or an equivalent dose greater than three tenths of any relevant dose limit In practice, areas should be designated as controlled whenever: - the external dose rate in the area exceeds 7.5μSv per hour averaged over the working day; or - the hands of an employee can enter an area in dose rate exceeds 75μSv per hour over the working day; or - there is a significant risk of spreading contamination outside the work area; or - it would be necessary to prevent or closely supervise access to the area by persons who are not connected with the work with ionising radiation whilst that work is being carried out. For some work although it is not necessary to designate an area during routine operations, it may be necessary to designate the area during maintenance operations. Controlled areas must be: - physically demarcated or delineated - identified as a controlled area using suitable and sufficient warning signs, indicating the nature of the radiation sources in the area and the risks arising from those sources. Access to controlled areas must be restricted to: - classified persons; or - outside workers, for whom a method of personal dose assessment is available, who have been appropriately trained in local procedures and who has been certified fit for the type of radiation work to be carried out; or - non-classified persons working in accordance with written arrangements to restrict their exposure to a level below three tenths of any relevant dose limit; or - any other person so long as their exposure does not exceed any relevant dose limit.

20 Personal dosimetry should be issued to all individuals working in controlled areas. For outside workers, the results of any dosimetry issued must be entered into the individual s radiation passbook. Results of personal monitoring must be kept for at least fifty years and should be made available, on request, to the individual to which they relate. Where there is a risk of contamination in a controlled area, arrangements must be made to minimise the risk of spreading that contamination. In particular: - suitable and sufficient washing and changing facilities should be provided and these facilities should be properly maintained; - eating, drinking, smoking and any other hand to mouth operations should be prohibited in the area to restrict the possibility of ingestion of any contamination; - a means for monitoring for contamination any person or item leaving the area should be provided. 30. Designated Supervised Areas Areas must be designated as supervised whenever: - it is necessary to keep the conditions in the area under review to determine whether the area should be designated as a controlled area; or - any person entering the area is likely to receive an effective dose greater than 1mSv per year, or an equivalent dose greater than one tenth of any relevant dose limit. In practice it will be appropriate to designate an area as supervised rather than controlled where: - only low activity sealed radioactive sources are used; or - the quantity of unsealed radioactive material being handled is small and the risk of a spill or spread of contamination is low. Supervised areas must be appropriately signed indicating that the area is a supervised area. The signs should be in appropriate positions and should include the nature of the radiation sources in the area and the risks arising from those sources (e.g. radiation and/or contamination sources). 31. Contamination Monitoring of Designated Areas Each NERC site must make arrangements for the monitoring of its designated areas. The level and frequency of the monitoring will depend upon the nature and extent of the radiological risks in the area and should be sufficient to ensure any changes in working conditions or breakdowns in controls are identified. For areas designated on the basis of external exposure to radiation it will be appropriate to measure dose rates. For areas designated on the basis of internal exposure, measurements of air and/or surface contamination levels taking into account the physical and chemical nature of the radioactive material should be made. The main purposes of monitoring are to: - check that areas have been and remain correctly designated

21 - determine radiation and contamination levels so that appropriate control measures for restricting exposure can be identified and implemented - detect breakdowns in controls - confirm conditions are satisfactory to allow work to continue in the area - provide information on which to make estimates of personal exposure to radiation or contamination where personal dosimetry results are not available The monitoring regime should take into consideration: - the nature and quality of the radiation - the physical and chemical state of the radioactive material - where the measurements should be made, e.g. on the benches, floors, walls etc. - how frequently or on what occasions the measurements should be made, e.g. following an incident - what method of monitoring should be used, e.g. direct measurement or sample collection - who should carry out the monitoring and what training they need; - what records should be kept (see below) - the selection of action or investigation levels - when and by whom the monitoring procedures should be reviewed. Monitoring records must be kept for at least two years and should include: - date, time and location of the monitoring; - confirmation that the area designation remains correct or where any investigation levels have been reached or exceeded such that further action is required; - the nature and quantity, as a dose rate or activity, of the radiation present; - whether there was any contamination present, if applicable, and whether it was fixed or loose. Equipment which is used for monitoring must be suitable and sufficient for purpose. It must be properly maintained so that it remains fit for purpose and be adequately tested and examined on a regular basis, normally at least once per year. A Qualified Person must be consulted with regard to the equipment suitability, calibration and testing. Procedures must be established to ensure any equipment which is damaged or which fails a routine test or calibration is removed from service and a replacement issued. Records authorised by the Qualified Person, (such as Test and Calibration Certificates), must be kept for a period of at least two years. 32. Classified Persons - Designation Individuals who are likely to receive an effective dose greater than 6mSv per year, or an equivalent dose greater than three tenths of any relevant dose limit, must be designated as classified persons. The NERC will use the risk assessment for the work with ionising radiation to decide whether or not classification is required. Where an individual is required to be classified, the NERC will ensure that the individual is aged 18 years of over and has been certified as fit by an appointed doctor or employment medical adviser (EMA). Where these two criteria are not satisfied, the individual will not be classified and either the work will be reviewed to enable it to be performed by an unclassified person, or another individual, who has successfully been designated as a classified person, will be selected to carry out the work.