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Appendix A9.6

Radiation protection policy statement

Page contents:

1. Introduction
2. Legislative framework
3. Organisation
4. Local arrangements
5. Training
6. Monitoring of radiation areas
7. Audit and review

1. Introduction

1.1  We always seek to achieve the highest working standards for all work with radioactive substances, and other sources of ionising radiation. This is in order to protect your health and safety, that of other persons, and to minimise impacts on the environment. As a matter of course, all work with radioactive substances, and other sources of ionising radiation, must meet all relevant legislative requirements.

1.2  Measures to ensure this will include:

  • the use of alternative non-radioactive techniques or less hazardous sources wherever reasonably practical, in accordance with the statutory requirements of ALARP (As Low as Reasonably Practicable) and BAT (Best Available Techniques)
  • the provision of suitable facilities and equipment for work with radioactive substances and other sources of ionising radiations
  • the provision of suitable management arrangements for radiation work
  • prior risk assessment and control
  • the provision of sufficient information and instructions to all radiation workers, and others who may be affected by such work.  Such information and instructions will normally be provided in the form of 'Local Rules' and Standard Operating Procedures (SOPs)
  • the provision of sufficient training to all radiation workers, and others who may be affected by such work

1.3 This policy is supplementary to our health and safety policy. Application of it must be consistent with the requirements of both health and safety and environmental protection regulations, to ensure the protection of the health of workers and the general public against dangers arising from ionising radiations, and the protection of the environment.

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2. Legislative framework

2.1 The legislative framework for radiation work and radioactive substances is covered by two principal pieces of legislation:

The Ionising Radiations Regulations 1999 (IRR99) are enforced by the HSE, and require us to keep work-related radiation exposures As Low As Reasonably Practicable (ALARP).

The Radioactive Substances Act 1993 (RSA93) is enforced by the Environment Agency, and covers the acquisition, keeping, use and disposal of radioactive substances. Authorisations granted under the Act require us to apply Best Available Techniques (BAT) to minimise the impacts of our radiation work on the environment. Discharges must not exceed Authorised limits.

The Environmental Permitting (England and Wales) Regulations 2010 (EPR2010) is enforced by the Environment Agency, and creates one regulatory system by streamlining and integrating Waste Management Licensing, Pollution Prevention and Control, Water Discharge Consents, Groundwater Authorisations and Radioactive Substances Regulation Permits into one statutory instrument.

2.2 When these regulations come into force on 6 April 2010, radioactive substances permitting will move from the RSA93 environment to EPR2010 (schedule 23) and all subsequent licensing, regulation and enforcement will be conducted under the new regulations. RSA93 will continue to exist, in support of the existing Radioactive Substances Exemption Orders, until the current EO review is complete and the new exemption arrangements are incorporated into EPR2010 by subsequent amendment regulations. At this point, RSA93 will be revoked in England and Wales.

2.3 Scotland and Northern Ireland will not have EPR2010, so the new arrangements will be implemented via The Radioactive Substances Act 1993 (Amendment) (Scotland/NI) Regulations 2010 and The Radioactive Substances Exemption (Scotland/NI) Order 2010.

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3. Organisation

3.1 Institute Directors

Directors of institutes carrying out work with radioactive substances, or other sources of ionising radiation, must ensure that suitable management arrangements are made and resources and equipment are provided and maintained to cover work with ionising radiations.

These include that:

  • regulatory authorities are given prior notification of radiation work, and registrations and authorisations are obtained, as required by legislation
  • where required by legislation, a suitably competent Radiation Protection Adviser (RPA) is appointed to advise the institute on radiation protection matters in accordance with the regulations.  They will have direct access to the director and senior management.  They must be given sufficient authority, time and resources to fulfil their role effectively
  • a suitably competent Radiation Protection Officer (RPO) is appointed in writing to manage the day-to-day operation of the institute's radiation protection arrangements.  They will have access to senior management and be a member of the Institute Health and Safety Committee or equivalent Committee.  They must be given sufficient authority, time and resources to fulfil their role effectively and will be involved, as appropriate, in Institute safety audits/inspections
  • where required by legislation, suitably competent Radiation Protection Supervisors (RPSs) are appointed to supervise work with ionising radiations.  Appointment criteria must be in accordance with the HSE Information Sheet on RPSs.  They must be given sufficient authority, time and resources to fulfil their role effectively
  • in accordance with conditions of authorisation, a suitably competent qualified expert is appointed to advise the institute on compliance with the limitations and conditions of the statutory authorisations granted to it
  • 'Local rules' and contingency plans, are required by legislation, are implemented and periodically reviewed
  • formal prior risk assessments for all radiation work are prepared and communicated effectively to all relevant persons
  • suitable and sufficient information, instructions and training is provided to radiation workers, and others as appropriate, before radiation work commences
  • appropriate records are made and retained as required by legislation

Such duties may be delegated, but full responsibility for compliance rests with the Institute Director.

3.2 Individuals

You must before commencing radiation work:

  • attend all appropriate training as required
  • ask for more information/instruction/training if you feel that you have not been given sufficient to enable you to work safely, and at minimal risk to yourself or others
  • ensure that you have discussed your proposed radiation work with an appropriate RPS, and have agreed procedures to be followed with them
  • ensure that you have read and understand the 'Local Rules', SOPs, risk assessments and emergency procedures relating to your work
  • advise your line manager as soon as possible of planned pregnancy, pregnancy or breastfeeding, so that appropriate actions can be taken

in performing radiation work:

  • seek to reduce the radiation risks of your work to a minimum, using safe working methods and equipment as instructed and using only the minimum quantities of radioactive substances necessary for successful research.  Alternative, non-radioactive methods should always be considered
  • co-operate with your line manager, RPS, RPO and any other person appointed to advise or monitor safety arrangements for radiation work
  • follow the 'Local Rules', SOPs, other instructions and emergency procedures relating to your work
  • only purchase radioactive substances in accordance with the specific systems and local rules designed for that purpose.  This includes purchasing only enough radioactivity sufficient for immediate needs
  • carry out radiation work only in appropriately designated areas and regularly monitor these areas for contamination
  • maintain clear, legible records as required by 'Local Rules' and SOPs
  • inform the RPO if you intend to work with ionising radiation at another site/organisation allowing good time to enable arrangements on mutual dosimetry to be implemented
  • wear personal radiation dosemeters where required by Local Rules and as instructed
  • inform the RPO and local RPS immediately of the loss or uncontrolled release of any radioactive substances or sources
  • dispose of radioactive wastes only in accordance with 'Local Rules' and SOPs
  • inform the RPO of the termination of work with ionising radiations

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4. Local arrangements

4.1 Each institute which uses radioactive substances, or other sources of ionising radiation, must make suitable arrangements to manage such work. These will include local rules and procedures designed to minimise radiation doses to staff, students, contractors and all other persons. Local rules will be prepared to cover all controlled areas, supervised and other areas associated with the use of ionising radiation carried out in BBSRC. The local rules will include systems of work which must be followed at all times.

4.2 Local rules will be reviewed periodically for each area, and whenever there are significant changes in the nature of the radiation work or management of radiation protection. Management are responsible for ensuring that staff are made aware of any changes in local rules.

4.3 Any incident (accidental or otherwise) involving exposure to staff or the public, or uncontrolled/unauthorised release to the environment, must be brought to the attention of the RPO and the Health and Safety Advisor and local RPS immediately. Contravention of local rules must be reported to the RPO so that they can take appropriate action. Significant infringement of local rules will be a disciplinary offence.

4.4 Each institute will include radiation work and radiation work areas in the scope of internal health and safety audits/inspections. The inspection team will include the RPO, or an RPS appointed by the RPO, as appropriate. All non-conformances will be brought to the attention of the RPO, as well as the appropriate Head of Department.

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5. Training

5.1 Anyone working with ionising radiation at one of our sites will receive prior and on-the-job training appropriate to the work being performed. Training in the correct use of new equipment will also be given to individuals, where appropriate.

5.2 Anyone appointed as an RPS will receive appropriate training prior to being appointed, and as necessary thereafter. They must know and understand the requirements of the regulations and the local rules as they affect the work that they supervise, and have appropriate familiarity with the work which they supervise.

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6. Monitoring of radiation areas

Each site must monitor any controlled, supervised and other areas as appropriate on a regular basis to demonstrate that surface contamination, air contamination and/or dose rates are satisfactory for continuing work with ionising radiation. Equipment for such monitoring (contamination monitors or dose-rate meters) must be provided and maintained. They will be annually tested, calibrated and thoroughly examined. Monitoring and test results will be maintained by each site for at least 2 years. It is good practice to keep the records longer as they can provide good support to exposure risk management.

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7. Audit and review

Institute Radiation Protection Officers will meet annually and review the implementation of our policy. The following indicators will be used to monitor the effectiveness of the policy:

  • Reported radiation incidents
  • Significant non-conformances reported by RPOs
  • RPA inspection visits and audits, including review of personal dosimetry results
  • Reports of inspections by the HSE and EA

The Radiation Protection Officers meeting will report to the Joint Health and Safety Committee, which in turn reports to the Joint Negotiating and Consultative Committee.

Professor Douglas Kell
Mark Fernandes

June 2010 

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Last updated 08/06/10
Amendment 95  June 2010