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REGULATION OF INDUSTRIAL RADIOGRAPHY IN UK David Orr HM Specialist Inspector of Health and Safety (Radiation) Health and Safety Executive. Several regulators involved with site radiography inspection/regulation in UK: Office for Nuclear Regulation Environment Agency
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REGULATION OF INDUSTRIAL RADIOGRAPHY IN UKDavid Orr HM Specialist Inspector of Health and Safety (Radiation)Health and Safety Executive
Several regulators involved with site radiography inspection/regulation in UK: • Office for Nuclear Regulation • Environment Agency • 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
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: • 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 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 !
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 HSE http://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
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
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
ENFORCEMENT: • Verbal advice • Notification of Contravention letter – triggers charging regime • Improvement Notice • Prohibition Notice • Prosecution
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