New notification process for work with ionising radiation

The new Ionising Radiation Regulations 2017 (IRR17) came into force on 1 January 2018. They replaced the existing IRR99 regulations, due to the implementation of the EU Basic Safety Standards Directive (BSSD).

For those working with ionising radiation, the biggest change relates to how employers submit information to the HSE.

This relates broadly to industry and specifically to those that use X-ray devices, radioactive substances and devices containing such substances, as well as working with radon gas.

Notification

IRR99 required employers to notify the HSE about their work with ionising radiation.

Under IRR17, a three distinct tier system is introduced:

• Notification
• Registration
• Consent (more than one may be required)

If working with ionising radiation, even where the HSE has previously been notified, employers must apply to the HSE between 1 January and 5 February 2018.

Application Process

The HSE will make an online service available whereby employers can apply for notification, registration and consent simultaneously. These will apply to all sites under the employer’s control.

The following fees apply:

• £25 for registration
• £25 for each consent
• £0 for notification

Once the HSE has been notified, registers the notification and has consented, employers will not need to apply again unless the information they provided changes significantly.

The application process follows a ‘graded approach’, whereby the type of application depends on the level of risk of work that is conducted by the employer.

• Notification - lowest risk

- Applies to work with less than 1,000kg of radionuclides or work in a radon atmosphere above the annual average of 300Bq m-3.

• Registration – medium risk

- Applies to radiation generators, 1,000kg or more of radionuclides above the low and medium end of specific concentration levels

• Consent – highest risk

- Only applies to: uranium mining, deliberate use of radioactive materials for specific medical veterinary purposes, deliberate use of radioactive substances in products, operation of an accelerator, industrial irradiation, disposal or long-term storage of radioactive waste, industrial radiography and discharge of significant quantities of radioactive effluent.

Where an application may not be required

An application may not be required where work utilises:

• Radionuclides that are at the very low end of specific concentration levels,
• Sealed, HSE type approved sources,
• Electrical apparatus type approved by the HSE,
• Devices operating at a voltage of 30Kv or lower, like the cathode ray tube, and
• Contaminated material, declared not subject to further control by the appropriate environment agency.

For further information, please see schedule 1 of the draft Approved Code of Practice and guidance as well as the HSE website.