1. First FRCR Examination in Clinical Radiology Statutory Requirements and Non-Statutory Recommendations Ionising Radiations Regulations John Saunderson Radiation Protection Adviser
17/04/2017

2. Relevant Radiation Legislation
Ionising Radiations Regulations 1999
staff, public, equipment (IRR99)
Ionising Radiation (Medical Exposure) Regs 2000
patients, research subjects (IRMER)
Environmental Permitting Regulations 2010
keeping & disposing of radioactive materials (EPR2010)
The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009
Medicines (Administration of Radioactive Substances) Regulations 1978
nuclear medicine, brachytherapy (ARSAC)
17/04/2017

3. Guidance Approved Code of Practice (ACOP) Guidance Notes DoT guidance
odd HSE guidance
etc.
IPEM, NRPB, RCR, BIR, etc. stuff.
17/04/2017

4. Ionising Radiations Regulations 1999
Responsibility for radiation safety
Local rules and procedures
Role of radiation protection adviser and radiation protection supervisor
Classified workers
Restriction of exposure (through design, systems of work and ppe)
Dose limits
Equipment used for medical exposures
Notification of incidents
Dose constraints for comforters and carers
Routine inspection and testing of equipment
Notification of incidents .
17/04/2017

5. Responsibility for radiation safety
Radiation employer - i.e. an NHS Trust, private dentist, etc.
Authorised practices
Notification to HSE
Prior risk assessments
Employee must
not knowingly expose himself greater than necessary
use personal protective equipment provided
report equipment defects
look after PPE
(extra duties for classified persons)
17/04/2017

6. Local rules and procedures
Controlled areas
Supervised areas
Local Rules.
17/04/2017

7. Controlled area
any area where it is necessary to follow special procedures to restrict significant exposure, or
any area where > 6 mSv/y, or 3/10th dose limit is likely
also ACOP says if
> 7.5 uSv/h averaged over 8 h working day
> 75 uSv/h to hands averaged over 8 h working day
contamination risk
need to keep non-radiation workers out
or > 7.5 uSv/h averaged over 1 minute and
site radiography, or

8. Controlled area
any area where it is necessary to follow special procedures to restrict significant exposure, or
any area where > 6 mSv/y, or 3/10th dose limit is likely
also ACOP says if
> 7.5 uSv/h averaged over 8 h working day
> 75 uSv/h to hands averaged over 8 h working day
contamination risk
need to keep non-radiation workers out
or > 7.5 uSv/h averaged over 1 minute and
site radiography, or
employees untrained in radiation protection enter area (unless radioactivity is dispersed inside a person).

9. Supervised area
any area where it is necessary to keep conditions under review, or
any area where > 1 mSv in a year, or 1/10th dose limit is likely.
17/04/2017

10. Local Rules How to work safely in that area Must contain
Dose investigation levels
contingencies for foreseeable accidents
RPS (radiation protection supervisor) name
describe area covered
work instructions for unclassified workers.
17/04/2017

11. Local Rules Could also contain management and supervision of work
testing and maintenance of safety features
radiation and contamination monitoring
testing of monitors
personal dosimetry
arrangements for pregnant and breast feeding staff
risk assessments
programme to review ALARA
RPA contact.
17/04/2017

12. Local Rules
Usually get new employees to read Local Rules and sign to say they have understood them.
17/04/2017

13. Role of radiation protection adviser and radiation protection supervisor
17/04/2017

14. Radiation Protection Adviser R.P.A.
Must have qualification approved by HSE (e.g. RPA certificate)
Must be appointed in writing
Must be consulted on
controlled and supervised areas.
prior examination of plans
regular calibration of dose monitoring equipment
periodic testing of safety features and warning devices
risk assessment of new radiation work.
incidents where more then 6 mSv has been received.
critical examination of safety features of new radiation equipment.

15. R.P.A. need not be appointed if only
Very, small amounts of radioactive material (below specified levels)
Very low dose (< 10 cm) x-ray units of a design approved by HSE
VDUs with < 10 cm
< 30 kV and < 10 cm.
17/04/2017

16. Radiation Protection Supervisor R.P.S.
Must be appointed “for the purpose of securing compliance with these Regulations” in controlled or supervised areas
Name must be in Local Rules
It is recommended that
know & understand regs. and local rules
command sufficient authority
understand necessary precautions
know what to do in an emergency.
17/04/2017

17. Here on 4th Nov 2014

18. Classified workers
Anyone who may exceed 6 mSv effective dose per year, or 3/10th of a dose limit (e.g. 150 mSv hand dose, or 45 mSv lens dose)
Must be informed (!)
Must be 18 or over
Must be certified fit to work with radiation by a suitable doctor
Dose monitored and recorded for 50 years with an HSE Approved Dosimetry Service - results to HSE
Radiation passbook for “outside workers”
Adequate (at least yearly) medical surveillance - record for 50 y.
17/04/2017

19. Restriction of exposure (through design, systems of work and ppe)
Restrict exposure
. By engineering
. By systems of work
. By personal protective equipment
Controlled areas - demarcate and sign
Non-classified workers can only enter under written system of work
Must demonstrate by personal dose monitoring or other means that doses are restricted

20. Dose Limits Schedule 4 Part 1
17/04/2017

21. Employees  18 Trainee < 18 20 mSv/y effective dose
150 mSv/y equivalent dose to lens of eye
500 mSv/y equivalent dose over 1 cm2 skin
500 mSv/y equivalent dose to hands, forearms, feet and ankles
Trainee < 18
6 mSv/y effective dose
50 mSv/y lens of eye
150 mSv/y over 1 cm2 skin
150 mSv/y hands, forearms, feet and ankles .
17/04/2017

22. Abdomen of women of reproductive capacity at work
13 mSv / 3 months equivalent dose
Not employee or trainee, or a “comforter or carer” or undergoing a medical exposure
1 mSv effective dose, unless dose the result of a medical exposure of another, then 5 mSv / 5 y
15 mSv/y lens of eye
50 mSv/y over 1 cm2 skin
50 mSv/y hands, forearms, feet and ankles .
17/04/2017

23. Reg. 11(2)
(2) Where an employer is able to demonstrate in respect of any employee that the dose limit specified in paragraph 1 of Part I of Schedule 4 is impracticable having regard to the nature of the work undertaken by that employee, the employer may in respect of that employee apply the dose limits set out in paragraphs 9 to 11 of that Schedule and in such case the provisions of Part II of the Schedule shall have effect.
17/04/2017

24. Part II Dose Limits Employees  18 Not allowed for Trainees < 18
100 mSv / 5y and 50 mSv/y effective dose
150 mSv/y equivalent dose to lens of eye
500 mSv/y equivalent dose over 1 cm2 skin
500 mSv/y equivalent dose to hands, forearms, feet and ankles
Not allowed for Trainees < 18
Abdomen of women of reproductive capacity at work
13 mSv / 3 months equivalent dose .
17/04/2017

25. To use Part II must . . . Consult RPA inform employee ADS in writing
give 28 days notice to HSE
if > 20 mSv given in a year
undertake investigation
notify HSE
Review every 5 years.
17/04/2017

26. Dose Limits
Note, not like a speed limit. Doses must be as low as is reasonably practicable (ALARP)
Dose constraints used in design
e.g. 0.3 mSv for members of public,
5 mSv for comforters and carers (1mSv if pregnant)
Foetus limit: 1 mSv from notification of pregnancy by employee
Need formal investigation levels for staff
Do not apply to medical exposures.
17/04/2017

27. For HEY Trust the DIL’s are
17/04/2017

28. 17/04/2017 Hull & East Yorkshire Hospitals’ dose investigation levels
Radiation Protection Adviser
17/04/2017

29. HSE Nov. 01
“There has been a number of reported cases where employees have failed to take good care of their dosemeters. Many of these cases involve employees in the Health Services, some of whom have been senior clinicians.
“Non-Classified employees who have been provided with a dosemeter by their employer to ensure compliance with reg 18(2)(b)(ii) of the IRR99 have a duty to look after that dosemeter and return it for processing as required. Provided the employer has informed the employees of that duty and is exercising the appropriate level of supervision, employees who persistently fail to wear, look after or return their dosemeters promptly are liable to enforcement action by inspectors up to and including prosecution under Section 7 of the HSW Act Employers may find statement of this fact useful when dealing with 'errant' staff.”
17/04/2017

30. Equipment used for medical exposures
Design, construct, install, maintain to keep doses ALARP
Display indication of dose (e.g. DAP meter, mAs meter, etc.)
Equipment quality assurance programme
IPEM91
Must test before first clinical use
Must test at appropriate intervals
Must test after major maintenance.
17/04/2017

31. Routine inspection and testing of equipment
Follow IPEM 91
Test, e.g kV accuracy
Expertise, e.g. A = radiographer, B = medical physics
Frequency, e.g. annual for B general
Remedial level, e.g. +/- 10% for kV
Suspension level, e.g. +/- 20% for kV
17/04/2017

32. Notification of incidents
Must report to HSE where dose to patient is “much greater than intended” due to equipment fault.

33. Patient Doses Much Greater Than Intended [HSE PM77 (3rd)]
x 20 - extremities, skull, chest, dentition, shoulder, chest, elbow, knee and nuclear medicine where intend <=0.5mSv
x 1.5 – Interventional radiology, use of contrast, CT, nuclear medicine where intend >5mSv
x10 – other imaging.
17/04/2017

34. Patient Doses Much Greater Than Intended [HSE PM77 (3rd)]
x 1.1 – whole course of radiotherapy
x 1.2 – single fraction of radiotherapy, or unsealed radionuclide therapy.
17/04/2017

35. Incidents
Any untoward occurrence which may result in excess radiation to staff or patients must be referred to the Radiation Protection Supervisor and the Radiation Protection Adviser, who will estimate the dose and liase with management, HSE, DoH, HCC, EA, etc. as appropriate
Suspect equipment must be withdrawn from service and labelled according.
17/04/2017

36. Investigation establishing what happened identifying the failure
deciding on remedial action to minimise the chance of a similar failure
estimating the doses involved
decide whether patient informed (usually yes).
17/04/2017

37. Comforters and Carers
"individuals who (other than as part of their profession) knowingly and willingly incur an exposure to ionising radiation in the support or comfort of another person who is undergoing, or has undergone a medical exposure"
Dose constraint required.
17/04/2017

38. Comforters and Carers e.g. parent holding a child being X-rayed
not a nurse, care assistant, etc.
if < 1 mSv public dose limit, not “C&C”
5 mSv dose constraint
if pregnant 1 mSv dose constraint
must be aware of the risk.
"individuals who (other than as part of their profession) knowingly and willingly incur an exposure to ionising radiation in the support or comfort of another person who is undergoing, or has undergone a medical exposure”
c.f. doses to patients in red book
Highly unlikely for a single exposure.
17/04/2017

39. 17/04/2017

40. Reference Book List
Advice on Exposure to Ionising Radiation during Pregnancy
Guidance Notes
IPEM 91
17/04/2017

41. Here on 6th Nov 2014??
17/04/2017