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Regulation of Industrial Radiography in the UK: Insights from HM Specialist Inspector

Learn about the regulatory landscape of industrial radiography in the UK, including the roles of key regulators such as ONR, Environment Agency, and HSE. Discover the authorization process, inspection protocols, enforcement actions, and guidance available for users and inspectors.

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Regulation of Industrial Radiography in the UK: Insights from HM Specialist Inspector

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  1. REGULATION OF INDUSTRIAL RADIOGRAPHY IN UKDavid Orr HM Specialist Inspector of Health and Safety (Radiation)Health and Safety Executive

  2. Several regulators involved with site radiography inspection/regulation in UK: • Office for Nuclear Regulation • Environment Agency • Health and Safety Executive

  3. Office for Nuclear Regulation (ONR) • Regulate work activities on nuclear licensed sites (including industrial radiography) • Responsible for regulating transport of radioactive material (nuclear and non-nuclear) by road

  4. Environment Agency: • Concerned with protection of members of public and environment • Licence users of radioactive materials via permitting (but not x-ray sets) • Responsible for source security matters • Carry out regular inspections to check permit conditions (yearly for high activity sources)

  5. Health and Safety Executive: • Regulate users of ionising radiation (non nuclear) • Ionising Radiations Regulations 1999 – implement majority of BSS in UK legislation http://www.hse.gov.uk/radiation/index.htm

  6. Health and Safety Executive Inspectors: • Need a BSc (Hons) in scientific/engineering subject • Must have relevant experience (not necessarily RPA) • Trained in house – combination of formal training courses and on the job training • Currently 2.6 inspectors for UK !

  7. AUTHORISATION: • Only for specific practices with x-ray sets, but includes industrial radiography • Generic authorisations issued – if these can be met no need to apply to HSE http://www.hse.gov.uk/radiation/ionising/authorisation.htm • If cannot be met need to apply to HSE for “Prior authorisation” – none to date in UK

  8. INSPECTION: • HSE Inspectors carry warrants • Have 7 day notification system for site radiography work • Current Ministerial statement currently doesn’t allow for pro-active inspection of industrial radiography

  9. INSPECTION: Needs to be “reason” for visit: • Complaint • Evidence of poor performance • Notification made to HSE: • Overexposure • Source failing to return to container/x-ray set fails to terminate

  10. ENFORCEMENT: • Verbal advice • Notification of Contravention letter – triggers charging regime • Improvement Notice • Prohibition Notice • Prosecution

  11. GUIDANCE: • Have guidance for health and safety of inspectors • Guidance for users being withdrawn as part of “reducing regulatory burdens” EMERGENCY RESPONSE: • Site radiography companies musht have own “contingency plans” for dealing with reasonably foreseeable radiation accidents • HSE has no involvement/role in implementation of these plans

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