Health and Safety Executive

Health and Safety Executive

Miscellaneous

provisions - HSE

ProposalsRob Wellens

OEWG Meeting 11 November 2014

Topics covered

• Voluntary workers

• Dose and medical record retention period

• Special medical surveillance

• Sealed and unsealed sources

• Radiation weighting factors

• NORM industries

• Data monitoring systems

M1. Voluntary workers

Current requirement

• IRR99 does not specifically address the radiation protection of voluntary workers

BSS requirement

• Article 31 requires that voluntary workers are afforded the same radiation protection as an employee

M1. Voluntary workers (2)

HSE Proposal

• New regs to reflect the BSSD requirement

Preliminary estimated impact

• Already covered under general duties of an employer

• Familiarisation costs

M2. Dose and medical record retention periods

Current requirement

• IRR99 requires that these records are kept for 50 years

BSS requirement

• Articles 43.3 & 48.1 require a retention period of 30 years

M2. Dose and medical record retention periods (2)

HSE Proposal

• Reduce period to 40 years– Consistent with other long latency health

surveillance requires, e.g. Asbestos

Preliminary estimated impact

• £510k per each year for records not being retained

• Reduce risk of any confusion for medical professionals and different requirements for different risks

M3. Special medical surveillance

Current requirement

• IRR99 ACOP and guidance set out special medical surveillance provisions

BSS requirement

• A49.1 – provision for any further action deemed necessary

• A49.2 – SMS if dose limits exceeded

• A49.3 – subsequent exposures agreed with Appointed Doctors

M3. Special medical surveillance (2)

HSE Proposal

• Move relevant ACOP and guidance provisions into Regulation

Preliminary estimated impact

• No great changes to current practice

• Familiarisation costs

M4. Sealed and unsealed sources

Current requirement

• IRR99 sets out requirements for accounting for, recording keeping and misuse or interference of radioactive sources

BSS requirement

• Articles 86 & 87 use specific terms that are not in IRR99 – – “use”– “transport”– “unauthorised use”

M4. Sealed and unsealed sources (2)

HSE Proposal

• New regs to reflect the BSSD requirement

Preliminary estimated impact

• Familiarisation costs

M5. Radiation weighting factors

Current requirement

• IRR99 Appendix I details radiation weighting factors

BSS requirement

• Annex II details slightly different radiation weighting factors, and slightly different supporting text

M5. Radiation weighting factors (2)

HSE Proposal

• New regs to reflect the BSSD requirement

Preliminary estimated impact

• Familiarisation costs for ADSs

M6. NORM industries

Current requirement

• IRR99 ACOP para 11 sets general scope for how NORM industries are covered

BSS requirement

• Annex VI lists specific NORM industries that are covered by the BSSD

M6. NORM industries (2)

HSE Proposal

• New regs to reflect the BSSD requirement

Preliminary estimated impact

• Familiarisation costs

M7. Data monitoring systems

Current requirement

• IRR99 sets out requirements for record keeping

BSS requirement

• Annex X requires that voluntary workers are afforded the same radiation protection as an employee

M7. Data monitoring systems (2)

HSE Proposal

• New regs to reflect the BSSD requirement

Preliminary estimated impact

• Already covered under general duties of an employer

• Familiarisation costs

Questions / Comments?

• To re-emphasise– These are HSE’s preliminary proposals

on how to implement the BSSD

• Do you have any questions / comments on the preliminary proposals