Health and Safety Executive

REGULATION OF INDUSTRIAL RADIOGRAPHY IN UK

David Orr

HM Specialist Inspector of Health and Safety (Radiation)

Health and Safety Executive

Health and Safety Executive

Several regulators involved with site radiography inspection/regulation in UK:

• Office for Nuclear Regulation

• Environment Agency

• Health and Safety Executive

Health and Safety Executive

Office for Nuclear Regulation (ONR)• Regulate work activities on nuclear

licensed sites (including industrial radiography)

• Responsible for regulating transport of radioactive material (nuclear and non-nuclear) by road

Health and Safety Executive

Environment Agency:• Concerned with protection of members of

public and environment• Licence users of radioactive materials via

permitting (but not x-ray sets)• Responsible for source security matters• Carry out regular inspections to check

permit conditions (yearly for high activity sources)

Health and Safety Executive

Health and Safety Executive:

• Regulate users of ionising radiation (non nuclear)

• Ionising Radiations Regulations 1999 – implement majority of BSS in UK legislation

http://www.hse.gov.uk/radiation/index.htm

Health and Safety Executive

Health and Safety Executive Inspectors:

• Need a BSc (Hons) in scientific/engineering subject

• Must have relevant experience (not necessarily RPA)

• Trained in house – combination of formal training courses and on the job training

• Currently 2.6 inspectors for UK !

Health and Safety Executive

AUTHORISATION:• Only for specific practices with x-ray sets,

but includes industrial radiography• Generic authorisations issued – if these can

be met no need to apply to HSEhttp://www.hse.gov.uk/radiation/ionising/

authorisation.htm• If cannot be met need to apply to HSE for

“Prior authorisation” – none to date in UK

Health and Safety Executive

INSPECTION:

• HSE Inspectors carry warrants

• Have 7 day notification system for site radiography work

• Current Ministerial statement currently doesn’t allow for pro-active inspection of industrial radiography

Health and Safety Executive

INSPECTION:

Needs to be “reason” for visit:

• Complaint

• Evidence of poor performance

• Notification made to HSE:

• Overexposure

• Source failing to return to container/x-ray set fails to terminate

Health and Safety Executive

ENFORCEMENT:

• Verbal advice

• Notification of Contravention letter – triggers charging regime

• Improvement Notice

• Prohibition Notice

• Prosecution

Health and Safety Executive

GUIDANCE:• Have guidance for health and safety of inspectors• Guidance for users being withdrawn as part of

“reducing regulatory burdens”EMERGENCY RESPONSE:• Site radiography companies musht have own

“contingency plans” for dealing with reasonably foreseeable radiation accidents

• HSE has no involvement/role in implementation of these plans