On the first of August 2019, the following Health and Safety Legislation in relation to ionising radiation came into force;
- Ionising Radiation (Application) Order 2019
- Ionising Radiation (Basic Safety Standards and Justification of Practices) Regulations 2019
- Ionising Radiation (Medical Exposure) Regulations 2019
What is ionising radiation
Ionising radiations occurs as either electromagnetic rays (such as X-rays and gamma rays) or particles (such as alpha and beta particles). It occurs naturally (eg radon gas) but can also be produced artificially.
The main difference is that ionising radiation carries more energy than non-ionising radiation.
Ionising radiation includes:
- gamma rays
- radiation from radioactive sources and sources of naturally occurring radiation, such as radon gas
Ionising radiation has many uses in industry, such as energy production, manufacturing, medicine and research and produces many benefits to society. However, it is important that the risks of ionising radiation are managed sensibly to protect workers and the public.
Non-ionising radiation includes:
- visible light
- ultra-violet light
- infra-red radiation
- electromagnetic fields
Sources of electromagnetic fields are used extensively in telecommunications and manufacturing with little evidence of related long-term health problems.
Ultra-violet light is part of natural sunlight and also forms part of some man-made light sources. It can cause a number of health problems, including skin cancer.
Further information on ionising and non-ionising radiation can be obtained from the Health Security Agency, formally Public Health England.
How can people be exposed to ionising radiation?
People can be exposed externally to radiation from a radioactive material or a generator such as an X-ray set, or internally by inhaling or ingesting radioactive substances. Wounds that become contaminated by radioactive material can also cause radioactive exposure.
Everyone receives some exposure to natural background radiation and much of the population also has the occasional medical or dental X-ray. The Inspectorate is concerned with the control of exposure to radiation arising from the use of radioactive materials and radiation generators in work activities. This is to ensure that workers and members of the public are not harmed by these activities.
The use of ionising radiation covers the use of radioactive materials and radiation generators in these work activities in:
- manufacturing, food production and waste processing
- oil and gas production
- non-destructive testing
- medical and dental sectors
- education and research establishments (e.g. universities and colleges)
The nuclear industry and transport of radioactive substances is regulated by the Office for Nuclear Regulation. However, employers will also need to notify, register or gain consent from Health and Safety Inspectorate where these requirements apply.
Ionising Radiation (Application) Order 2019
The Ionising Radiation (Application) Order 2019, brings into force the UK’s Ionising Radiation Regulations 2017.
The IRAO19 details only the amendments that have been made to the Ionising Radiation Regulations 2017 in order to apply them to the Isle of Man, however; a copy of the amended regulations (with amendments made) can be found in IRAO19 Annex.
The risk – based approach
As part of the IRAO19, there is a requirement on employers involved in work with ionising radiation (unless exempt from the regulations) to either notify the Department of the practice, register the practice with the Department or get consent from the Department to carry out their practice using ionising radiation.
This is part of a risk-based approach, where notification is the lowest tier of this risk based approach representing the lowest risk activities involving ionising radiation, registration is the intermediate tier and consent is the highest tier, reserved for the higher risk activities involving ionising radiation.
Please read over the following guidance documents before attempting to complete the application form.
Flowchart – Follow this flowchart to assist you in deciding which tier of the risk based approach you need to apply for.
Indicative list of practices – This document provides examples of applications of ionising radiation and the tier of the risk based approach that they fall under.
Once you have read over the guidance documents, please complete the application form to notify, register or gain consent from the Health and Safety Inspectorate.
Non-medical imaging using non-medical equipment
If as part of your work with ionising radiation you use non-medical equipment to carry out non-medical imaging of subjects (e.g. to detect contraband on individuals) you must also submit an application for approval of this sort of practice the Health and Safety at Work Inspectorate
This requirement is detailed in Part 8 of the Ionising Radiation (Basic Safety Standards and Justification of Practices) Regulations 2019.
Type approval of apparatus
For the purposes of Schedule 1 of The Ionising Radiation Regulations 2017 (as applied to the Island by the Ionising Radiation (Application) Order 2019); the Department recognises and accepts the apparatus approved by the UK’s Health and Safety Executive.
The apparatus approved by the UK’s Health and Safety Executive for the purposes outlined in Schedule 1 can be located on the UK's Health and Safety Executive website.
Ionising Radiation (Basic Safety Standards and Justification of Practices) Regulations 2019
The Ionising Radiation (Basic Safety Standards and Justification of Practices) Regulations 2019 lays down basic safety standards for protection against the dangers arising from exposure to ionising radiation and is made up of the following parts;
Part 1 – General Information and Interpretation
Part 2 – Land and Other Exposer Situations
- Reg 4 -Measures to be taken in relation to exposures from land
- Reg 5 – Provision of information concerning public exposures from radioactive contaminated land
- Reg 6 – Measures to be taken in other exposure situations
Part 3 – Building Material
Part 4 – Radon
- Reg 8 – Indoor exposure to radon
- Reg 9 – Requirement to make available to the public information regarding radon
- Reg 10 - Radon action plan
- Reg 11 - New buildings
- Reg 12 - Areas of high radon concentration
Part 5 – Orphan Sources
- Reg 13 – Identification of orphan sources
- Reg 14 – Action to recover orphan sources left behind by past practices
Part 6 – Personal Ornaments and Toys
- Reg 15 – Addition of radioactive substances to personal ornaments or toys
Part 7 – Justification of Practices Involving Ionising Radiation
- Reg 7 – Justification of classes or types of practices
Part 8 – Justification of Practices Involving Non-Medical Imaging Exposure
- Reg 17 – Identification of imaging practices
- Reg 18 – Approval of imaging practices
- Reg 19 Individual justification and regular review
- Reg 20 – Dose constraints
- Reg 21 – Consent
Justification is one of the key principles of radiological protection established by the International Commission on Radiological. The principle of justification is that no practice involving exposures to radiation should be adopted unless it produces sufficient benefit to the exposed individuals or to society to offset the radiation detriment it causes.
Ionising Radiation (Medical Exposure) Regulations 2019
The Ionising Radiation (Medical Exposure) Regulations 2019, address the radiation protection of persons undergoing medical exposures whether as part of their own medical diagnosis or treatment, as part of research, as asymptomatic individuals, as those undergoing non-medical imaging using medical radiological equipment or as carers and comforters of persons undergoing medical exposures.
The Regulations impose duties on employers and those with responsibilities for undertaking activities covered by the legislation, including optimising and justifying medical exposures and administering ionising radiation.
While overall the Regulations broadly reflect existing provisions, they also introduce additional requirements which act to enhance protection for those undergoing medical exposures:
- the Regulations expand requirements for reporting of accidental or unintended exposures to ionising radiation to include doses that are less than intended
- the Regulations formalise the recognition of medical physics experts (MPEs)
the Regulations introduce requirements for licensing of the administration of radioactive substances to persons for diagnosis, treatment or research.