Health and Safety Executive Health and Safety Executive Miscellaneous provisions - HSE Proposals Rob 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