Health and Safety Executive Health and Safety Executive Radon - BSS Directive - HSE Proposals Rob Wellens OEWG Meeting 11 November 2014
Topics covered There are four areas of proposed change: –Separate dose recording –Introduction of a “time integrated radon exposure value” –Annual average, not a 24 hr measurement –When to notify HSE
RN1. Time integrated radon exposure value (TIREV) What is TIREV? BSSD introduces the concept of TIREV for workplaces above 300Bq m -3 Equivalent of 6mSv effective dose An easy calculation for dutyholders to see whether their measurement equates to 6mSv Not envisaged as a regulatory requirement –An aid for dutyholders
RN1. Time integrated radon exposure value (TIREV) (2) Current requirement None BSS requirement Article 35.2 allows for the use of a TIREV
RN1. Time integrated radon exposure value (TIREV) (3) HSE Proposal To introduce a TIREV Preliminary estimated impact Familiarisation costs
RN2. Separate Dose Recording Current requirement IRR99 requires an individual dose record, but does not require that radon doses be recorded separately on that dose record. BSS requirement Article 43.4 requires an individual dose record records occupational radon doses separately
RN2. Separate Dose Recording (2) HSE Proposal To require separate dose recording Preliminary estimated impact Any ADS approved to record radon doses would need to be able to demonstrate how the radon doses are recorded separately HSE is looking to work with these ADSs to establish the costs involved
RN3. Annual Average Current requirement IRR99 sets a level of 400Bq m -3 in a 24 hour period BSS requirement Article 54.1 sets a level of 300Bq m -3 as an annual average
RN3. Annual Average (2) HSE Proposal To use an annual average HSE estimates that IRR99 level equates to ~270Bq m -3 annual average Radon is a chronic exposure issue, so annual average makes more sense
RN3. Annual Average (3) Preliminary estimated impact Easier to understand and use A very small number of dutyholders may come out of scope Some familiarisation costs
RN4. Notification Current requirement IRR99 requires HSE to be notified if levels above 400Bq m -3 in a 24 hour period are measured BSS requirement Article 54.3 requires notification if dutyholders cannot remediate below an annual average of 300Bq m -3
RN4. Notification (2) HSE Proposal To require notification after remediation To make radon risk assessment and measurement requirements explicit
RN4. Notification (3) Preliminary estimated impact Smaller number of notifications to HSE Greater clarity for dutyholders regarding regulatory requirements Neutral effect on measurement and remediation, as this has always been required Some familiarisation costs
Questions / Comments? To re-emphasise –These are HSE’s preliminary proposals on how to implement the BSSD (radon requirements) Do you have any questions / comments on the preliminary proposals
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