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Ministry of Defence

JSP 392 Radiation Safety Handbook


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PRELIMINARY PAGES Contents Para 1 2 4 4 5 6 Authority Maintenance Record of Changes Channels for Comment File Reference Disclaimer Forward Glossary Volume 1 Chapter Contents Volume 2 Leaflet Contents Comments Form Page

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AUTHORITY 1 JSP 392 is sponsored by the Director of Safety and Claims as Chairman of the Occupational Health and Safety Board (OHSB) and produced and maintained by the Directorate of Safety and Claims (DS&C). It is issued under the authority of the Chairman OHSB. MAINTENANCE 2 This Joint Service Publication (JSP) will be maintained on the Defence Intranet and Internet, and will be revised on an annual basis. Where amendment is necessary, these amendments will be announced by DCI GEN and any changes or additions also published on the Defence Intranet and Internet. All paper copies of JSP 392 material are uncontrolled. 3 Amendments will be developed on behalf of the Directorate of Safety and Claims (DS&C) and staffed through the JSP 392 Review Committee and Functional Safety Boards (FSBs). Major amendments and new inclusions will be submitted for endorsement at the appropriate level. These will be announced by Defence Instructions and Notices under Channel 7 Safety, Health, Environment and Fire. RECORD OF CHANGES

Amendment No 1

Amendment Record DS&C

Affected Pages See table below

Date January 2008

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Amendment No 1

Date Jan 2008

Text Affected Glossary Chapter 1 (paragraph 3) Chapter 2 (3) Chapter 3 (18) Chapter 4 (11, 26) Chapter 5 (3.2,15) Chapter 7 (1) Chapter 8 (8) Chapter 9 (5, 6) Chapter 11 (Annex A) Leaflet 3 (paragraph 14, 40, 43, 46) Leaflet 4 (14-15, 49, Annex B, Annex C) Leaflet 6 (Annex A (24, 40.12)) Leaflet 9 (36, 37, Annex C) Leaflet 10 (14.4) Leaflet 11 (34) Leaflet 13 (2, 3, 5, 6, 22) Leaflet 14 (26, Annex A, Annex B) Leaflet 17 (9) Leaflet 21 (Table 2, Annex B) Leaflet 25 (Annex A (12)) Leaflet 28 (Table 3) Leaflet 30 (All) Leaflet 31 (17) Leaflet 32 (3, 9, 10, 11, 20) Leaflet 39 (13, Annex E) Leaflet 40 (Annex B, Annex C)

NOTE: Minor changes such as typographical errors are not listed. CHANNELS FOR COMMENT 4 Enquiries or proposed changes should be addressed to DS&C at the address below using the comments form or, if considered appropriate, through the Deputy Chief Environment and Safety Officer (Ministry of Defence). dsc-ohs5@mod.uk DSC-OHS5 Directorate of Safety and Claims Occupational Health & Safety and Radiation Protection Team Floor 6, Zone D MOD Main Building Whitehall London, SW1A 2HB FILE REFERENCE 5 File reference DSC-06-10-01 relates to this JSP.

DISCLAIMER 6 Nothing contained within this JSP removes the responsibility of any duty holder to comply with the law and MOD requirements.

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FOREWORD

The purpose of this publication is to enable Ministry of Defence (MOD) units (including Defence Agencies) to comply with legislation relating to radiation protection including environmental protection associated with sources of ionising and non-ionising radiation and the Secretary of States Policy Statement on Safety, Health and Environmental Protection. In overseas commands this publication applies to all personnel, service and civilian. This JSP is divided into two major parts comprising: Volume 1, Radiation Policy, contains both ionising and non-ionising radiation and radioactive substances policy that applies across the MOD. Volume 2, Radiation Instructions and Advice, provides instructions and advice on individual aspects of radiation protection for specific uses. Issues associated with the interpretation or application of the policy in Volume 1 should be brought to the attention of the Directorate of Safety and Claims (DS&C). The contact details are: DSC-OHS5 Directorate of Safety and Claims Occupational Health & Safety and Radiation Protection Team Floor 6, Zone D MOD Main Building Whitehall London, SW1A 2HB email: dsc-ohs5@mod.uk Tel: +44 (0)20 7218 3720 or Military 9621 83720 Requests for advice on the interpretation of the information contained within Volume 2 of this handbook or amendments to Volume 2 of this publication should be addressed to: Head of Dstl Environmental Sciences Department c/o Institute of Naval Medicine Crescent Road Alverstoke Gosport Hants PO12 2DL Tel: +44 (0)2392 768130 or Military 9380 68130

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GLOSSARY Acceptance Test An examination of newly installed medical and dental X-ray equipment to check the specifications and fitness of the equipment for the optimisation of radiation doses to patients. Tuition leading to competence in radiation protection and appropriate instruction, including practical experience, in diagnostic or therapeutic techniques involving ionising radiation as specified in Schedule 2 of the Ionising Radiation (Medical Exposure) Regulations (IRMER) 2000. The largest value of annual intake of a radionuclide by a specific route into the body that will not exceed the annual dose limits either to the whole body or individual organs as given in Schedule 4 of IRR99 for a classified person. A registered medical practitioner who is appointed by the Health and Safety Executive (HSE) under Ionising Radiations Regulations 1999 (IRR99) to carry out the duties described in IRR99. Document issued by the appropriate Regulatory Authority authorising an establishment to accumulate, discharge or dispose of quantities of radioactive material as specified in the approval document. A dosimetry service approved, by certificate in writing, by the HSE

Adequate training (Medical and Dental)

Annual limit of intake (ALI)

Appointed Doctor

Approval Document

Approved Dosimetry Service (ADS) Approved Dosimetry Record Keeping System (ADRKS) Becquerel (Bq) Calendar quarter

The system used by an Approved Dosimetry Service (ADS) for maintaining dosimetry records. The unit of activity, defined as one disintegration per second. Any consecutive 3-month period commencing 1 January, 1 April, 1 July, 1 October. A 12-month period commencing 1 January. Any person or organization undertaking the conveyance of radioactive materials by any means of transport. Chemical, biological, radiological and nuclear. This is a Centralised Index system containing details of dose information for each classified person and identifying them to their Approved Dosimetry Laboratory. It is operated by the Health Protection Agency (HPA) for the HSE. A person designated in accordance with Regulation 20 of IRR99 or in the case of an outside worker employed by an undertaking in Northern Ireland of in another member state, a person who has been designated as a Category A exposed person within the meaning of article 21 of the European Council Directive 96/29/Euratom.

Calendar year Carrier

CBRN Central Index of Dose Information (CIDI)

Classified person

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Closed source

Comforter and carer

A radioactive source from which the dispersal of the radioactive material is minimised by sealing, bonding or other means. This term includes bonded sources, homogeneous sources, laminated sources and sealed sources. An individual who, other than as part of their occupation, knowingly and willingly incurs an exposure to ionising radiation resulting from the support and comfort of another person who is undergoing a medical exposure from an internal or external source. The most senior officer of a ship, unit or establishment. Commanding Officer includes the Commandant, Officer Commanding, Captain, Master, Director, Head of Establishment and Medical Officer-in-Charge. The effective or equivalent dose that will be accrued by the body or a tissue over a 50-year period following the intake of radioactive material. The recipient of transported radioactive material. Any person who sends radioactive materials in any form from a ship, unit or establishment. A document certifying that the contents of a consignment of radioactive materials are properly described by name, are properly packaged, marked and labelled and are in a proper condition for transport according to the applicable transport regulations. The unintended presence of radioactive material on surfaces, areas, personnel (including any surface of the body or clothing) or objects or in gases or liquids. A plan designed to protect persons who may be affected by ionising radiation arising from any foreseeable accident or incident to which the plan relates. An area designated in accordance with Regulation 16 of the IRR99, or in the case of Northern Ireland or in another member state an area subject to special rules for the purposes of protection against ionising radiation and to which access is controlled. An examination of new or structurally modified medical X-ray rooms and dental surgeries to ensure that the installation and any associated safety features and warning devices satisfy the original design criteria and statutory requirements relevant to the restriction of exposure. This is the non-SI unit of activity. One Curie is equal to 3.7 x 1010 becquerels (Bq). This term is officially obsolete, but may still be used in older publications or on some equipment. For any radionuclide, the DAC is that concentration in air which if breathed by a person (reference man) for a working year of 2000 hours (40 hours per week for 50 weeks per year) would result in the person receiving the Annual Limit of Intake by inhalation.

Commanding Officer

Committed dose

Consignee Consignor

Consignor's Certificate

Contamination

Contingency plan

Controlled area

Critical examination

Curie

Derived air concentration (DAC)

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Derived limit

A limit derived from a dose limit or a secondary limit that is intended to prevent the dose limit being exceeded. Such limits include doserates in a work place, airborne contamination limits and surface contamination limits. Defence Nuclear Safety Regulator. A restriction on the prospective dose to individuals, which may result from a defined radiation source. Dose constraints are to be used in the planning stage of radiation protection. Limits of radiation dose to the whole body or individual tissues or organs or extremities of the body in a specified period. These limits are given Schedule 4 of IRR99. The rate at which a person or part of a person would receive a given dose of ionising radiation. A device used for measuring absorbed radiation doses. The measurement of radiation doses. It applies to both the devices used and to the technique. Defence Science and Technology Laboratorys Environmental Sciences Department. An exposure of an employee engaged in an activity associated with the response to a radiation emergency, or potential radiation emergency in order to bring help to endangered persons, prevent exposure of a large number of persons or save a valuable installation of goods, whereby one of the dose limits for a classified person could be exceeded. An employer is whoever employs an employee In the IRMER 2000, an employer is any natural or legal person who has the legal responsibility for a given installation, usually the Chief Executive of the National Health Service (NHS) Trust governing a Ministry of Defence Hospital Unit (MDHU) or single-Service Medical Director General (MDG) for other medical establishments. Includes all Naval, Army, Air Force, and MOD civilian (including Defence Agency) establishments and attachments. An order exempting radioactive substances from all or part of the Radioactive Substances Act. The Order may specify other requirements for those radioactive substances. Ionising radiation originating from outside the body of the person. The appropriate single-Service authority responsible for the oversight of advice and dissemination of radiation protection information. The focal point authority is to be notified of any new sources of ionising and non-ionising radiation. A check carried out using a radioactive source to demonstrate the consistency of response of an instrument before and/or during use.

DNSR Dose constraint

Dose limits

Dose rate

Dosemeter Dosimetry

Dstl ESD

Emergency Exposure

Employer Employer (For Medical/Dental Purposes.) (See Radiation Employer)

Establishments

Exemption Order

External radiation Focal point authority

Functional check

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Gaseous tritium light device (GTLD) Gaseous tritium light source (GTLS) Gray (Gy)

An instrument, piece of equipment, article or sub-assembly containing one or more GTLSs. A sealed glass container filled with gaseous tritium and coated internally with a phosphor. The SI unit of absorbed dose; defined as an energy deposition of 1 J.kg-1 of irradiated material. The senior officer at an establishment. The record of medical surveillance of a classified person kept by the ship or establishment maintained by the employer in accordance with regulation 24(3) of the IRR99 A sealed source (as defined by Directive 96/29/Euratom) containing a radionuclide whose activity at the time of manufacture is equal to or exceeds the activity levels specified in Annex I of EC Directive 2003/122/Euratom i.e. that the activity equals or exceeds 0.01 of the corresponding A1 value given in the IAEA Regulations for the safe transport of radioactive material. The following types of source/radioactive material do not fall within the scope of HASS: a) Any component of a nuclear weapon; b) Any nuclear fuel element; c) Any radioactive substance inside a nuclear reactor; and d) Containers of radioactive material where the radioactive material would not constitute a sealed source in the absence of the container, and the container is for the purpose of storage or transport rather than to ensure the integrity of the source as in ISO 2919:1999. e) Radioactive waste, f) GTLSs and GTLDs A record of radiation protection instrument maintenance, repair and calibration. Ionising radiation coming from inside the body of a person. This is the transfer of energy in the form of particles or electromagnetic waves of the wavelength of 100 nanometres or less or a frequency of 3 x 1015 hertz or more capable or producing ions directly or indirectly. This includes Gamma () rays, X-rays (either from radionuclides, X-ray equipment or produced as a by-product of some other apparatus), alpha () particles, beta () particles and neutrons. The lead equivalent of a shielding material is the thickness of lead affording that same protection as the material in question under the same conditions of irradiation. Ionising radiation that has passed through the protective housing of an X-ray tube, but not through the radiation aperture. Orders adequate to enable the work with ionising radiations at a particular ship, unit or establishment or to be carried out in accordance with statutory and MOD requirements. Rules made in accordance with regulation 17 of IRR99

Head of establishment Health record

High Activity Sealed Source (HASS)

Instrument log

Internal radiation Ionising radiation

Lead equivalent

Leakage radiation

Local orders

Local rules

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Low Specific Activity (LSA)

Low Specific Activity material is defined as radioactive material, which by its nature has a limited specific activity, or a radioactive material for which limits of estimated average specific activity apply. Advice may be sought from the RPA. The exposure of a person to ionising radiation for the purpose of a medical or dental examination or clinical research under the direction of a suitably qualified person. The transfer of radioactive materials within a ship, unit or establishment. This is any electromagnetic radiation that is not ionising radiation. This includes laser radiation, electromagnetic fields and ultra-violet radiation. Values given in Schedule 8 of the IRR99. A notification issued by the appropriate Regulatory Authority specifying the maximum holdings of radioactive material that may be used or stored at an establishment. Nuclear programmes are those to deliver and support the nuclear weapons and nuclear propulsion programmes The radiation exposure received as a result of work undertaken with ionising radiations. Any person who carries out any practical aspect associated with the procedure of a medical or dental exposure including those to whom practical aspects have been delegated, medical physics experts and, except where they do so under the supervision of a person who is adequately trained, persons participating in practical aspects as part of practical training (IRMER 2000) i.e. usually a radiographer or a medical physicist, but may be a medical or dental officer or other adequately trained medical or dental assistant or nurse. In the use of ionising radiation associated with veterinary examinations it is the person controlling the veterinary examination. Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) 2001, defines an operator as the person in control of the operation of premises.

Medical exposure

Movement

Non-ionising radiation

Notifiable quantities Notification (EA)

Nuclear programmes

Occupational Exposure

Operator

Outside worker

A classified person who carries out services in the controlled area of any employer, other than the controlled area of his own employer. The exposure of any person to ionising radiations to an extent that a dose limit is exceeded. An overpack is an enclosure, such as a bag or box, used by a single consignor to consolidate into one unit a consignment of two or more packages for the convenience of handling stowage and carriage. A document giving formal approval for and stating conditions under which persons specified in the document may work in a controlled area. An Individuals record of their exposure.

Overexposure

Overpack

Permit-to-work

Personal dose records

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Personal dosimetry number (PD)

A unique identifying number allocated by the Dstl Environmental Sciences Department (Dstl ESD) Approved Dosimetry Record Keeping Service to each person entered on the Approved Dosimetry Record Keeping System (ADRKS). The term that includes both protective clothing and breathing apparatus. A registered medical or dental practitioner, or other health professional who is entitled to take responsibility for an individual medical exposure (IRMER 2000) i.e. usually a radiologist, but may be the senior medical or dental officer. Before the commencement of a new activity involving work with ionising radiation a suitable and sufficient assessment of the risk to the employee or other person should be made. This assessment should identify the measures required to restrict the exposure of the employee or other person. Where the risk exists from a reasonably foreseeable accident, the employer, should prevent, or with the use of a contingency plan, limit the consequences of such an accident, and provide employees with appropriate information, instruction and training to restrict any exposure. Clothing provided to prevent the contamination of the person or the person's clothing or the lead rubber apparel worn when required during X-ray diagnostic procedures. A location not controlled by the employer (Commanding Offier) i.e. on the outside of the site boundary, or on a public right of way through the site. A person appointed by the employer having the necessary expertise, training and experience in instrumentation theory and practice to undertake or to supervise the examination and testing of radiation monitoring instruments to meet the requirements of the IRR99. An accident where immediate action is required to prevent or reduce the exposure to ionising radiation of employees or any other persons and includes a radiation emergency. A card issued to persons working away from their parent establishment containing relevant personal details and a summary of their radiation dose. Any event which is likely to result in any member of the public being exposed to ionising radiation arising from that event in excess of 5mSv effective dose in the one year period immediately following the radiation emergency. Any dose averted by any health protection measure taken during the 24 hours immediately following the event shall be disregarded. An employer who in the course of a trade, business or other undertaking carries out work with ionising radiation. Any apparatus that accelerates charged particles using a potential greater than 5 kV. Cathode-ray tubes and visual display units that do not produce a dose-rate of more than 5 Sv h-1 at a distance of more than 50 mm from any accessible surface are excluded.

Personal protective equipment

Practitioner

Prior risk assessment

Protective clothing

Public places

Qualified person

Radiation accident

Radiation dose summary card

Radiation emergency

Radiation employer

Radiation generator

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Radiation passbook

Radiation Protection Adviser (RPA)

Document issued by an ADS to record the estimated dose information for an outside worker working in a controlled area of another employer. A person or corporate body appointed by the employer to advise him on the observance of the IRR99 and on other health and safety matters in connection with ionising radiations. The individual or body must meet such criteria of competence as may from time to time be specified in writing by the HSE. A person appointed in writing by the Commanding Officer in respect of a particular process or processes to ensure that work is carried out in compliance with IRR99. An assessment prior to the introduction of new equipment, Installations or working practices, to identify the nature and magnitude of the radiation hazard likely to arise during normal operating conditions and in the event of any foreseeable accident or incident. An officer appointed by the Commanding Officer for the purpose of administering his responsibilities under these instructions. Orders produced by the ship, unit or establishment containing the information for the management of radiological protection. A measure of the risk of late effects, principally cancer, caused by the type of radiation under consideration relative to X or gamma irradiation of a specified energy. Includes closed sources, articles containing radioactive substances, unsealed radioactive substances and non-radioactive articles contaminated with radioactive substances.

Radiation Protection Supervisor (RPS)

Radiation Safety Assessment

Radiation Safety Officer (RSO)

Radiation Safety Standing Orders (RSSOs) Radiation weighting factor

Radioactive material

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Radioactive Substance

There are three definitions for a substance that must be regarded as Radioactive for the purposes of radiation protection, dependent upon which regulations are applicable: a. IRR99: Any substance which contains one or more radionuclides whose activity cannot be disregarded for the purposes of radiation protection. b. The Radioactive Substances Act 1993 (RSA93): i) a beta and/or gamma emitting solid radioactive material, whose activity exceeds 0.4 Bq g-1. ii) a substance that has become radioactive through bombardment by neutrons or ionising radiations. For other materials seek the advice of the Radiation Protection Adviser. c. The Transport Regulations. Radioactive material shall mean any radioactive material containing radionuclides where both the activity concentration and the total activity in the consignment exceed the values in columns 4 and 5 of Table 1 of the IAEA Safety Standards Regulations for the Safe Transport of Radioactive Material, 1996 Edition, Revised. (TS-R-1) (Units and establishments should seek advice from their Radiation Protection Adviser or their Dangerous Goods Safety Adviser.)

Radioactive waste

This is defined in RSA93 as waste which consists wholly or partly of: a. a substance or article which, if it were not waste would be radioactive material, or b. a substance or article which has been contaminated in the course of the production, keeping or use of radioactive material, or by contact with or proximity to other waste falling within paragraph a. Radioactive material will be considered to be waste when designated by a ship, unit or establishment

Radionuclide

A radioactive species of atom characterised by its mass number, atomic number and nuclear energy state. A registered dental or medical practitioner, or other health professional who is entitled to refer individuals for medical exposure to a practitioner (Ionising Radiation (Medical Exposure) Regulations 2000) i.e. usually a General Practitioner (GP) or General Dental Practioner (GDP), hospital doctor or dental surgeon or nurse practitioner.

Referrer

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Regulatory Authority

Authority responsible for the issue of Notifications for keeping and using radioactive materials and the issue of Approval documents for disposal of radioactive material. The Regulatory Authorities are as follows: a. Environment Agency (EA) in England and Wales. b. Scottish Environmental Protection Agency (SEPA) in Scotland. c. Environment and Heritage Service (EHS) in Northern Ireland.

Respiratory Protective Equipment (RPE) Risk Assessment

Equipment designed for protection of the individual against the hazards of airborne contamination. Carried out to identify risks to health and safety to any person arising out of, or in connection with, work or the conduct of their undertaking. It should identify how the risks arise and how they impact those affected. This information is then used to aid decisions on how to manage those risks. A source containing any radioactive substance whose structure is such to prevent, under normal conditions of use, any dispersion of radioactive substances into the environment. Note. For the purposes of IRR 99 only, this definition is qualified to specifically exclude any radioactive substance inside a nuclear reactor or any nuclear fuel element. The SI unit of equivalent dose; defined as the product of the absorbed dose (in Gy) and the radiation weighting factor. It provides an indication of risk to health, principally of cancer, in humans. Any industrial radiography undertaken outside an enclosure. Radioactive material that is in the form of an indispersible solid or in a sealed capsule so constructed that it can only be opened by destroying the capsule. An area designated by the employer in accordance with regulation 16 of IRR99. Procedures designed to restrict the radiation dose to workers and other persons to as low as reasonably practicable. A record of the personal radiation dose of a previously classified person which is produced by the ADS when they cease to work for the Ministry of Defence or its Agencies. A device containing thermoluminescent material used to measure dose from ionising radiations. Persons aged 16 years and over (including students) who are undergoing training or instruction which involves operations which would, in the case of an employee, be work with ionising radiation. The transfer of radioactive materials from a ship, unit or establishment

Sealed source

Sievert (Sv)

Site radiography Special form

Supervised area

Systems of work Termination record

Thermoluminescent dosemeter (TLD) Trainees

Transport

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TREMCARD

Transport Emergency Card (TREMCARD) containing instructions for drivers carrying radioactive material abroad between European countries, the instructions for drivers are required in the language of the driver of the vehicle and the languages of the countries of transit and destination. Transport Emergency Cards (TREMCARD) detailing the required instructions are available in different languages. TREMCARDS can also be used for movements within the UK. A package that is permitted to contain up to the relevant A1 or A2 activity limit for any given isotope. Type A packages are designed to prevent the loss or dispersal of the radioactive package contents and prevent any increase in the maximum radiation level recorded at the external surface of the package during normal conditions of transport. A radiation worker who is unlikely to exceed three-tenths of the annual dose limits for classified persons Any radioactive substance that is not a closed source. It includes non-radioactive objects contaminated with radioactive substances. Depleted uranium: Uranium containing less than 0.72% U-235 by weight. Natural uranium: Uranium containing the naturally occurring distribution of uranium isotopes (approximately 99.28% uranium-238 and 0.72% uranium-235 by weight). The X-rays that come from the target and emerge through the aperture of an X-ray tube. Persons who enter radiation areas other than for purposes of undertaking work. Units used to indicate the level of exposure to radon daughters in air. One working level (1WL) = 2.08 x 10-5 J m-3. An exposure of one working level month (WLM) would be received by working in a radon daughter concentration of one working level for 170 hours (i.e. a typical working month). Any task entailing the production, processing, handling, use, holding, storage, moving, transport or disposal of any radioactive substance, or entailing the operation or use of any radiation emitting machine or apparatus, including instruction or training in which a person is engaged in as a trainee. This also includes work carried out in an atmosphere containing radon 222 gas at a concentration in air, averaged over any 24 hour period, exceeding 400 Bqm-3 , except where the concentration of short-lived daughter products does not exceed 6.24 x 10-7 Jm-3. A measure of the amount of use of X-ray equipment in a specific period, expressed in units of milli-amp minutes (mA min).

Type A package

Unclassified radiation worker

Unsealed radioactive substance Uranium

Useful beam

Visitors

Working Level (WL)

Working Level Month (WLM)

Work with ionising radiations

Workload

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Workplace Supervisor (WPS)

Workplace supervisors are appointed where it is unnecessary to appoint an RPS, to undertake duties to ensure that work with sources of ionising radiation is carried out in accordance with legislation, the requirements of this publication and local orders for radiation safety. WPSs may be appointed to supervise radioactive materials, X-ray equipments or radon that do not require the setting up of designated areas, or a combination of these activities.

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VOLUME 1 CHAPTER CONTENTS

Chapter 1 Chapter 2 Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11

Scope, application and availability Radiological protection and MOD policy Ionising radiation protection policy Radioactive substances control policy Radioactive waste Non-ionising radiation protection policy Radiation protection committees Radiation protection appointments Training and qualifications in radiological protection Radiation dose control Record keeping

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VOLUME 2 LEAFLET CONTENTS

Leaflet 1 Leaflet 2 Leaflet 3

Acquisition of sources of ionising radiation by IPTs Risk assessments Notification, approval and assessment of the introduction and use of sources of ionising radiation including radioactive substances Restriction of exposure to radiation Written arrangements for unclassified persons entering controlled areas Dosimetry and personal dose records including medical surveillance of classified persons Radiation protection adviser consultation and advisory visits Radiation detection and monitoring equipment Storage, accounting and leak testing of radioactive material Movement and transport of radioactive materials Requirements for the transfer (including the return to stores) sale, loan and gifting of radioactive materials and radioactively contaminated items Accumulation and disposal of radioactive waste Assessment and management of radioactively contaminated land Investigation, notification and reporting of unusual radiation events Training requirements and courses Local orders for radiation safety Radioactive electronic valves Smoke detectors containing Americium 241 Gaseous tritium light sources (GTLSs) and gaseous tritium light devices (GTLDs) Instruments containing Ni-63 Instrument check sources Luminised equipment High voltage electrical equipment Postal and baggage fluoroscopes Dental x-ray machines Medical diagnostic X-ray machines

Leaflet 4 Leaflet 5 Leaflet 6 Leaflet 7 Leaflet 8 Leaflet 9 Leaflet 10 Leaflet 11

Leaflet 12 Leaflet 13 Leaflet 14 Leaflet 15 Leaflet 16 Leaflet 17 Leaflet 18 Leaflet 19 Leaflet 20 Leaflet 21 Leaflet 22 Leaflet 23 Leaflet 24 Leaflet 25 Leaflet 26

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Leaflet 27 Leaflet 28 Leaflet 29 Leaflet 30 Leaflet 31 Leaflet 32 Leaflet 33 Leaflet 34 Leaflet 35 Leaflet 36 Leaflet 37 Leaflet 38 Leaflet 39 Leaflet 40

Veterinary diagnostic X-ray machines Industrial radiography including enclosures, site and underwater radiography Items and components containing thorium Depleted uranium Museums Protection against radon Exposure to cosmic radiation Laser safety Radiofrequency radiations Microwave ovens Ultraviolet radiation Classified persons and outside workers Radiation safety duties of MOD employees Contingency plans

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COMMENTS FORM DSC-OHS5 Directorate of Safety and Claims Occupational Health & Safety and Radiation Protection Team Floor 6, Zone D MOD Main Building MOD Main Building Whitehall London SW1A 2HB Email: DSC-OHS5@mod.uk File: D/DSC-06-10-01 Senders Reference: To: From:

UIN:

Date:

Chapter/Annex

Page/Paragraph:

Comment:

Name: email Address: Signed:

Telephone No. Rank/Grade: Date:

Thank you for commenting on JSP 392

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CHAPTER 1 SCOPE, APPLICATION AND AVAILABILITY Contents Para 1 4 9 Scope Structure and Application Availability

SCOPE 1 This publication sets down the policy, instructions and guidance for peacetime ionising and nonionising radiation protection. It applies to MOD ships, units and establishments both in the United Kingdom and overseas. In times of war other standards may apply. In situations other than peace or war i.e. transitions between the two, the provisions in this publication should be applied as far as is reasonable practicable, or as defined in operational guidance. 2 Regulation of the Naval Nuclear Propulsion Programme is described in JSP 518 and the regulation of the Nuclear Weapons Programme is described in JSP 538. Similarly the policy for nuclear accident response is laid down in JSP 471, MOD Nuclear Accident Response. JSP 392 is called up by these publications. 3 The Transport of Dangerous Goods by Road, Rail and Sea including radioactive materials (Class 7) is contained in JSP 800 part 4b and Dangerous Air Cargo Regulations are contained in JSP 800 Part 4a. STRUCTURE AND APPLICATION 4 The policy, instruction and guidance for radiation protection are part of MODs arrangements for the management of health, safety, and environment matters. The overarching health and safety document is JSP 815 Defence Environment and Safety Management. 5 JSP 375, the Ministry of Defence Health and Safety Handbook provides instruction and guidance on health and safety matters. JSP 418 The MOD Sustainable Development and Environment Manual sets out MOD policy and provides some practical guidance on the protection of the environment in the Ministry of Defence. JSP 392 complements these publications. 6 JSP 392 is divided into two distinct volumes. Volume 1 contains radiation protection policy, which is applicable throughout the MOD and to its agencies. Reference is made in this volume to the Ionising Radiations Regulations 1999 (IRR99) which is available on the World Wide Web at http://www.opsi.gov.uk/si/si1999/19993232.htm and the Approved Code of Practice (ACOP) which may need to be purchased, See http://www.hse.gov.uk/radiation/ 7 Volume 2 of the publication contains instructions and guidance for units (including ships) and establishments throughout the MOD. This is directed at employers, Radiation Safety Officers (RSO), Radiation Protection Supervisors (RPS) and users of radioactive material. This volume of the publication has been written primarily for the small user. 8 This JSP in its entirety should not be referenced in contracts documents. However, specific requirements in this document may be detailed in a contract specification. Commercial Officers should discuss with the subject matter expert in the appropriate TLB the information that they intend to include.

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AVAILABILITY 9 This JSP must be made readily accessible to line managers, radiation protection appointees and employees who wish to see it. 10 The document is available on the Defence Intranet and World Wide Web.

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CHAPTER 2 RADIOLOGICAL PROTECTION AND MOD POLICY Contents Para 1 3 5 Introduction MOD Policy Roles and Responsibilities

INTRODUCTION 1 Radiological protection is a broad term that is generally taken to encompass the protection of man and the environment from the effects of both ionising and non-ionising radiation. Those effects may arise from work activity, natural sources, redundant material, waste or legacy material. 2 In radiological protection, a distinct division can be made between radiological protection for ionising and non-ionising radiations. The two main aspects of radiological protection are health and safety matters and environmental protection; they are interrelated and both are relevant to nuclear safety. MOD POLICY 3 Both the health and safety and the environmental protection, including assurance, aspects of radiological protection must be considered and managed within the overall framework of MODs policy for those areas. This is set out in detail (together with guidance material) in: JSP 815 the Defence Environment and Safety Management, where you can find: 4 The Policy Statement by the Secretary of State for Defence. Descriptions of MODs Boards etc dealing with environment, safety and health. Interface arrangements between MOD and other organisations. Information on the high-level structures for safety, health, environment and fire matters with Service and defence organisations.

JSP 375 the MOD Health and Safety Handbook. JSP 418 the MOD Sustainable Development and Environment Manual. Briefly, it is the policy of the Secretary of State for Defence that: Within the United Kingdom, MOD will comply with all relevant applicable legislation (including legislation giving effect to the UK's international obligations). Overseas, MOD will apply UK standards where reasonably practicable, and in addition comply with relevant host nations' standards. Where MOD has been granted specific exemptions, disapplications or derogations from legislation, international treaties or protocols, we will introduce standards and management arrangements that are, so far as reasonably practicable, at least as good as those required by legislation.

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The Secretary of State for Defence will invoke the powers to disapply legislation only on the grounds of national security and only when such action is essential to maintain operational capability. Where there is no relevant legislation, internal standards MOD will aim to optimise the balance between risks and benefits.

ROLES AND RESPONSIBILITIES 5 The Secretary of State for Defence has overall responsibility for all safety and environmental matters within MOD. In the policy statement the Secretary of State delegates the task of discharging the Secretary of States personal responsibilities through the line management chain to the heads of management areas at all levels, down to Heads of Establishments, Directors and Commanding Officers. Line managers at lower levels will also have duties under legislation, as will individuals (see JSP 375 and JSP 418 for the full explanations). 6 It is therefore often the case that Heads of Establishments, Directors and Commanding Officers discharge the duties of the employer under the Health and Safety at Work Act 1974 or other similar roles. However, their ability to do so must necessarily be influenced by the resources allocated to them by those higher in the chain of delegation and their options may be limited by the instructions or policy of higher management.

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CHAPTER 3 IONISING RADIATION PROTECTION POLICY Contents Para 1 2 10 11 12 13 14 16 17 18 Principles of Radiological Protection Legislation Nuclear Safety Compensation Scheme for Radiation Linked Diseases Radiation Worker Counselling Dosimetry Radiation Dose Information Radiation Monitoring Equipment Radon Monitoring Radiation Warning Label

PRINCIPLES OF RADIOLOGICAL PROTECTION 1 For ionising radiation, the main principles of radiation protection are formulated by the International Commission on Radiation Protection (ICRP) who publish recommendations. ICRP also produce a great deal of practical information. Other aspects of radiation protection derive from other bodies, e.g. the International Atomic Energy Agency (IAEA) and environmental forums. Governmental bodies etc may act upon the ICRPs recommendations, IAEA Conventions etc to produce legislation and other means of implementing a regime of radiological protection. Where appropriate, this could form the basis of MOD policy, e.g. in the absence of applicable legislation. LEGISLATION 2 The main UK statutes and subordinate legislation of interest to MOD in radiological protection for ionising radiation are: Health and Safety at Work Act 1974 Ionising Radiations Regulations 1999 Radiation (Emergency Preparedness and Public Information) Regulations 2001 Ionising Radiations (Medical Exposures) Regulations 2000 Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007

Radioactive Substances Act 1993 (RSA93) Exemption Orders

European Communities Act 1972 High Activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 that amend RSA93 Justification of Practices Involving Ionising Radiation Regulations 2004

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3 Equivalent legislation may exist for the Devolved Administrations and UK overseas territories and dependencies. 4 The legislation varies in its application to MOD and defence activities and there are many other regulations etc on radiological protection. 5 Legislation is supported by a variety of publications, from statutory guidance and Approved Codes of Practice through Government, non departmental public bodies and agency advisory material to material from industry groups, e.g. Good practice guidance for the management of contaminated land on nuclear and defence sites, published by Safegrounds (an industry group), and Clearance and Exemption Principles, Processes and Practices for Use by the Nuclear Industry. 6 Given MODs peculiar position under legislation as opposed to operators in the civil sector it should be borne in mind that it is S of Ss policy to comply with legislation or to introduce standards and management arrangements that are, so far as reasonably practicable, at least as good. 7 The Health and Safety at Work Act 1974 and its subordinate legislation generally applies to MOD.

8 The Radioactive Substances Act 1993 (RSA93) contains a disapplication in respect of certain defence sites. However, it is MODs policy for the enforcing agencies to be provided with information as if the law applied and for them to issue approvals similar to those in the civil sector and to levy the same charges. MOD has negotiated MoUs with the agencies that enforce RSA93 that define how those agencies will fulfil their national responsibility to oversee the safe keeping and disposal of radioactive material in the MOD. 9 The Justification of Practices Involving Ionising Radiation Regulations 2004 do not apply to defence activities. If they did, they would have little impact until an entirely new practice was conceived. At present, most of MODs practices appear in the list of existing practices that was issued at the same time as the regulations and is updated as new civil practices are authorised. There are some practices that are particular to MOD, such as the nuclear weapon and propulsion programmes. NUCLEAR SAFETY 10 Nuclear safety is closely related to radiological protection and the latter can have a major impact. The Nuclear Installations Act 1965 (NIA65) does not bind the Crown (other than a single provision on damage and liability) and so the Secretary of State for Defence has appointed an internal regulator (DNSR, the Defence Nuclear Safety Regulator) in this area. DNSR sponsors JSP 518 Regulation of the Naval Nuclear Propulsion Programme and JSP 538 Regulation of the Nuclear Weapon Programme. However, the major defence nuclear contractors are covered by NIA65 which is enforced by the Nuclear Installations Inspectorate (NII) of the Health and Safety Executive (HSE). COMPENSATION SCHEME FOR RADIATION LINKED DISEASES 11 MOD is a member of the Compensation Scheme for Radiation Linked Diseases (the Scheme). Using the Scheme, it is less arduous for the claimant, than going to law, to determine whether compensation should be paid in relation to MOD radiation workers (or their surviving dependants) who develop certain types of cancer or cataracts (which may be linked with exposure to ionising radiation at work). However, an application to the Scheme, whether or not a payment is made, does not prevent those persons seeking redress in law. Detailed information about the Compensation Scheme is in Volume 2. RADIATION WORKER COUNSELLING 12 In response to a recommendation of the House of Commons Defence Committee (HCDC 12th report Radiological Protection of Service and Civilian Personnel), MOD offers counselling to radiation workers, former radiation workers and their families. The counselling provides an opportunity to discuss concerns with someone medically qualified to give advice. It does not involve any medical examination, or any form of medical surveillance or screening. Detailed information about the counselling scheme is in Volume 2.

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DOSIMETRY 13 There are statutory requirements for employees to be subject to radiation dose monitoring (dosimetry). A service for this is generally available from Approved Dosimetry Service (ADS) run by Dstl EDS at Alverstoke. Should any user wish to cease using the Dstl ADS then this must be agreed by the appropriate TLB and the Chief Environment and Safety Officer (MOD). Some sites may already be using their own or other dosimetry services. RADIATION DOSE INFORMATION 14 MOD contributes anonomised radiation worker radiation dose statistics to the Health Protection Agencys for their periodic review of the ionising radiation exposure of the UK population. 15 The National Registry of Radiation Workers (NRRW) is a database containing data on radiation workers and their associated radiation exposure. Its purpose is to allow rates of cancer and other causes of death of radiation workers to be compared with those within the UK for each disease and tested against the level of radiation exposure to see if any relationship exists. The Ministry of Defence has been a major contributor since 1980. RADIATION MONITORING EQUIPMENT 16 The Marine Environment, Survivability & Habitability IPT (MESH IPT) in DE&S has a MOD-wide responsibility for chemical, biological, radiological and nuclear equipment (particularly monitoring equipment). They sponsor JSP 425 Examination and Testing of Ionising Radiation Monitoring (Including Protection) Instruments that gives the MOD policy for the calibration of MOD radiation monitoring (including protection) instruments. RADON MONITORING 17 Top Level Budget holders (TLBs), in conjunction with the RPA, are periodically to review the need for radon monitoring at sites and married quarters within their area of responsibility. National surveys have identified Radon Affected Areas (RAAs) where naturally occurring radon concentrations are highest. So far, RAAs are in Cornwall, Devon, Derbyshire, Northamptonshire, Somerset, parts of Grampian and the Highlands of Scotland, together with the southern parts of County Armagh and County Down in Northern Ireland, but the identification process continues. RADIATION WARNING LABEL 18 Within MOD there are a small number of radioactive sources, which if removed from their shielded containers, have the potential, from a short exposure, to cause serious injury, or even death. Such sources are those used in industrial radiography, radiation hardening examinations and in high exposure radiation instrument testing. The International Atomic Energy Agency has developed a universal radiation warning symbol with the message of "Danger-Stay Away" that anyone anywhere will understand. This is shown in Leaflet 4 Annex B. The new radiation warning symbol will supplement, not replace, the existing trefoil symbol. 19 In MOD establishments using such radioactive sources the warning symbol is to be placed on the device housing the source, as a warning not to dismantle the device or to get any closer. Where practical, it should be placed under the device cover such that it is not visible under normal use but would be visible if anyone attempts to disassemble the device. The symbol is not intended for doors, walls or shipping containers. 20 For new equipments the label should be included as part of the purchasing process. At establishments holding these sources the radiation warning symbol should be added during the maintenance period. Such small radiation warning labels would need to procured from a supplier of signs or manufactured by units in their local workshops.

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CHAPTER 4 RADIOACTIVE SUBSTANCES CONTROL POLICY Contents Para 1 7 8 9 11 14 15 16 17 18 19 23 25 27 28 29 30 31 34 General Parallel Arrangements in MOD RSA93 Parallel Arrangements in England and Wales Keeping and Use of Radioactive Substances EA Inspections MOD Database of Radioactive Materials Audits and RPA Advisory Visits MOD Safety and Environment Boards, Committees and Working Group Structure RSA93 Parallel Arrangements in Scotland RSA93 Parallel Arrangements in Northern Ireland Application of RSA93 to Contractors and Museums HASSR 2005 Parallel Arrangements Procurement and Use of Radioactive Materials Use of Radioactive Material Consultation with an RPA Prior to the Introduction of New Equipment Disposal of Redundant or Surplus Radioactive Materials Accounting and Transfer of Radioactive Material Records and Accountancy Transfer of Radioactive Articles Disposal of Radioactive Items by Sale or Donation Disposal of Ships

GENERAL 1 The Radioactive Substances Act 1993 (RSA93) is the main legislation covering the control of radioactive substances in the United Kingdom. The Act does not apply to premises occupied on behalf of the Crown for Naval, Military or Air Force purposes. However, MOD policy is to implement parallel arrangements to those required by the Act. 2 Practices involving certain high level sealed radioactive sources are subject to additional control measures under the High Activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASSR 05). MOD policy is to implement parallel arrangements, as these Regulations do not apply to MOD premises. 3 Certain aspects of the control of radioactive substances on nuclear licensed sites are regulated under the Nuclear Installations Act 1965 (NIA 65). Licensing under this Act is not applicable to the Crown and, on MOD nuclear sites, parallel standards are applied through authorisation conditions by the Defence Nuclear Safety Regulator (DNSR) internal nuclear regulators as described in JSP 518. 4 NIA 65, RSA 93 and HASSR 05, as appropriate, are applied at MOD contractor operated sites such as the nuclear licensed site at Devonport. 5 A number of arrangements for the control and accounting for radioactive substances, articles and equipment are embodied in the Ionising Radiation Regulations 1999 (IRR99) which are made under the Health and Safety at Work Act 1974 (HASAWA 74) and apply directly to the MOD in Great Britain. Application of the HSWA and its regulation by the HSE is described in JSP 375. In Northern Ireland, the applicable legislation is the Ionising Radiations Regulations (Northern Ireland) 2000.

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6 As stated in JSP 375, standards adopted in overseas Commands should, as far as is reasonably practicable, be no less stringent than those applying in the United Kingdom, subject to the discretion of local commanders and taking cognisance of local statutory requirements. PARALLEL ARRANGEMENTS IN MOD 7 The policy on the application of parallel arrangements under RSA93 and HASS 05 with respect to radioactive substance control is described below. The parallel arrangements apply across MOD with the exception of MODs nuclear authorised sites where the control of non-mobile radioactive substances is regulated by DNSR. Detailed instructions on the arrangements are contained in Volume 2. RSA93 Parallel Arrangements in England and Wales 8 A Memorandum of Understanding between MOD and the EA formalises an agreement whereby the EA carry out a number of quasi regulatory functions which together with additional measures within MOD are intended to satisfy the Secretary of States requirement that standards are, as far as is reasonably practicable, at least as good as those required by legislation. The main features administered by the EA are summarised below: Keeping and Use of Radioactive Substances 9 To parallel the registration requirements of Sections 7 and 10 of RSA93, EA issues a Certificate of Notification to MOD users, which is equivalent to the Certificate of Registration required by civil users. 10 The Certificate of Notification carries terms and conditions for that certificate. The standard terms and conditions for MOD sites have been agreed centrally and compliance is a MOD mandatory requirement. EA Inspections 11 EA are authorised by MOD to carry out inspections of premises where radioactive materials are held. These inspections will be carried out by arrangement with CO/HE. EA will bring to the attention of CO/HEs any areas of non-compliance. The CO/HE should inform DS&C of the outcome of any EA inspection. 12 Inspections carried out by EA do not include any remit to review MODs security arrangements.

13 A number of measures carried out and administered internally within the MOD are necessary to complete the parallel arrangements to satisfy SoS policy. They are: MOD Database of Radioactive Materials 14 A database of MOD radioactive materials is maintained to support the notification process.

Audits and RPA Advisory Visits 15 Audits are carried out at every level in MOD. Appropriate audits at each level are to include the control of radioactive substances. Dstl carry out RPA advisory visits across the MOD other than nuclear weapons and nuclear propulsion programmes areas. The advice provided is extended to include advice on RSA93 matters. Generic findings of the RPA are forwarded to the policy branch of MOD for scrutiny and development of policy where appropriate. MOD Safety and Environment Boards, Committees and Working Group Structure 16 Compliance with the parallel arrangements laid down in JSP 392 is monitored through the Defence Environment and Safety Board structure.

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RSA93 Parallel Arrangements in Scotland 17 [A Memorandum of Understanding between MOD and the SEPA yet to be agreed summary here as for EA depending on any differences.] RSA93 Parallel Arrangements in Northern Ireland 18 [Summary as above when MOU in place.]

Application of RSA93 to Contractors and Museums 19 Where contractors and museums operate on premises within MOD managed sites, disapplication of RSA93 is appropriate provided that: 19.1 The premises are occupied on behalf of the Crown for MOD purposes and

19.2 MOD arrangements for equivalent/parallel standards and management arrangements are applied through contractual or written agreements 20 Disapplication of RSA93 should be considered on a case by case basis and involve, as a minimum, consultation with the RPA and the external environmental regulator. Reference should also be made to the relevant Memorandum of Understanding with the external environment agency. 21 In cases where there is doubt as to whether the conditions of Para 12 are met, DS&C should also be consulted. Where contractor or museum premises are not on an MOD managed site, then, the case for disapplication is to include a detailed statement as to how the conditions of Para 12 are to be met. 22 General guidance on the management of contractors is contained in JSP 375 Volume 2.

HASSR 2005 Parallel Arrangements 23 For non-nuclear MOD sites, arrangements for Notification of the Environment Agencies described under RSA93 above have been extended to encompass the additional requirements for HASS. The main features which extend or differ from the RSA93 parallel arrangements are: 23.1 An application for a HASS Notification is to be made by the prospective holder direct to the relevant environment agency. The practice, which utilises the HASS, may not commence until the Certificate of Notification has been received from the relevant environment agency. 23.2 Arrangements for the physical security of HASS are, so far as reasonably practicable, to parallel those operative on civil sites. Advice on physical security should be sought through the Principal Security Adviser of the TLB concerned. 24 The regime for the control of HASS held by MOD nuclear authorisees mirrors that appertaining to civil nuclear licensees and is administered by the DNSR. This regime does not extend to mobile HASS held by authorisees, where the standard parallel arrangements for HASS apply. PROCUREMENT AND USE OF RADIOACTIVE MATERIALS Use of Radioactive Material 25 Radioactive material is not to be used in MOD equipment where use of alternative materials is reasonably practicable and consistent with meeting operational requirements. Under no circumstances is Radium 226 to be used for luminous items.

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26 Where the use of radioactive material is essential, the prior risk assessment carried out in accordance with IRR 99 is to address the use of possible alternative radionuclides. This is to enable the selection of radionuclide(s) which carry the lowest reasonably practicable overall risk, consistent with meeting operational requirements. The cost and manner of disposal of radioactive materials used will also need to be considered by IPTLs at an early stage of the assessment. Consultation with an RPA prior to the introduction of new equipment 27 In projects for which they have responsibility, the DLO/DPA Integrated Project Team Leader (IPTL) must include in contracts a requirement to consult with an RPA prior to the introduction of any new radioactive material or equipment capable of producing ionising radiation. Disposal of Redundant or Surplus Radioactive Materials 28 Accumulation of surplus or redundant radioactive material is to be avoided. It should normally be disposed of within 3 months, usually via the stores system. Where items cannot be returned through the stores system, the RPA is to be consulted for advice. ACCOUNTING AND TRANSFER OF RADIOACTIVE MATERIAL Records and Accountancy 29 All radioactive materials including those exempt from the need for a Notification are to be recorded and accounted for. Transfer of Radioactive Articles 30 When radioactive articles are transferred / consigned from one site to another, a full audit trail of the supply and receipt is to be maintained. The consignor must ensure that the consignee has the appropriate regulatory permits (e.g. Notification, Registration, etc) in place before commencing the transfer. Disposal of Radioactive Items by Sale or Donation 31 The disposal of radioactive items by sale or donation does not constitute disposal as radioactive waste and therefore does not require regulatory approval. However, the relevant environment agency conditions prohibiting the sale or supply of materials, unless it is suitably marked and/or described, are to be met. Furthermore, with the exception of exempt articles, no radioactive items are to be disposed of by sale or donation unless it is first ascertained that the proposed recipient has appropriate registration under RSA93. Proof that this was carried out should be retained for audit. 32 Sales of radioactive articles to overseas customers may be subject to special rules or conditions. In all such cases, advice is to be sought from the appropriate RPA before sale arrangements commence. 33 No items containing radium-226 are to be offered for sale to or donated to the general public.

Disposal of Ships 34 It is MOD policy that all major platforms, including ships and aircraft are monitored for radioactive items prior to disposal.

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CHAPTER 5 RADIOACTIVE WASTE Contents Para 1 5 6 7 10 12 Introduction UK Radioactive Waste Inventory Radioactive Waste Ownership Radioactive Substances Act 1993 and Defence Related Activities Discharges to the Environment UK Strategy for Radioactive Discharges

INTRODUCTION 1 The MOD is committed to complying, with legislation and so far as is reasonably practicable, with national policies relating to the management of radioactive waste and decommissioning. Details of national policy on the management of radioactive waste can be found on the DEFRA website: http://www.defra.gov.uk/environment/radioactivity/index.htm 2 MOD in managing radioactive waste is committed to delivering the commitments in the Secretary of States Policy Statement on Safety Health and Environmental Protection. In particular radioactive waste management practices must be framed in the context of the MODs policies and management arrangements on sustainable development and the environment. These are detailed in JSP 418 Sustainable Development and Environment Manual available on the Defence Intranet and on the World Wide Web. 3 As a general policy, managers and waste owners must: 3.1 Ensure through the use of best practical means1, that due consideration is given to not creating waste; or where this is not reasonably practical, minimising the generation of radioactive waste at every stage of any activity involving radioactive materials; 3.2 Carefully consider decay storage, recycling and/or reuse of materials2 and incineration as an alternative to declaring them as waste;

The BPM principle has most recently been defined by a statement of the UK Government and the devolved administrations' policy on the decommissioning of nuclear facilities http://www.scotland.gov.uk/Publications/2004/09/19915/42728 Essentially, it requires operators to take all reasonably practicable measures in the design and operational management of their facilities to minimise discharges and disposals of radioactive waste, so as to achieve a high standard of protection for the public and the environment. BPM is applied to such aspects as minimising waste creation, abating discharges and monitoring plant, discharges and the environment. It takes account of such factors as the availability and cost of relevant measures, operator safety and the benefits of reduced discharges and disposals. If the operator is using BPM, radiation risks to the public and the environment will be as low as reasonably achievable (ALARA).
2

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3.3 Ensure through the use of best practical means, that risks and doses to people now and in the future are kept as low as reasonably practical; 3.4 Ensure through the use of best practical means, that harm to the environment now and in the future so far as is practical is minimised; 3.5 Ensure from the conceptual stage, that for all activities involving radioactive substances, the method of eventual disposal has been considered and resources provided, this includes where required, the provision of decommissioning plans; 3.6 Establish performance indicators to demonstrate the extent to which these policy requirements are being achieved; and 3.7 Conform, where reasonably practicable, to the Environment Agencies risk screening and appraisal methodologies. 4 At the direction of the Sustainable Development and Environment Board, DS&C may carry out top level audits to determine compliance with these policy requirements and where necessary, functional audits of specific areas and activities. UK RADIOACTIVE WASTE INVENTORY 5 Waste owners are required to provide timely and accurate information about the radioactive waste they hold and projected future radioactive waste arisings to the organisation contracted by DEFRA/NIREX to produce the UK Radioactive Waste Inventory. DGSM (NW-SI2) coordinates the collation of this information across MOD and ensures that the required information is provided in the required form and by the due date. RADIOACTIVE WASTE OWNERSHIP 6 Because the Secretary of State (S of S) is accountable for and responsible for the safe management of defence related radioactive wastes it is generally MOD policy to retain title of defence related radioactive waste. Advice should be sought from DS&C where the transfer of title of radioactive waste to another party is being considered, in order that advice on the legal implications can be sought (Euratom, IAEA treaty obligations etc). RADIOACTIVE SUBSTANCES ACT 1993 AND DEFENCE RELATED ACTIVITIES 7 The Radioactive Substances Act 1993 is disapplied by virtue of subsection 2 of section 42 of the Radioactive Substances Act 1993 in respect of premises occupied on behalf of the Crown for Royal Naval, Military or Royal Air Force purposes Advice on the interpretation of the extent of this disapplication in a particular circumstance should be sought, in the first instance, from the Radiation Protection Advisor. Where they are unable to resolve the issue, DS&C should be consulted. 8 To fulfil the requirements of S of Ss policy, MOD has established formal arrangements (including a Radioactive Substances and Nuclear Annex on RSA93 matters to the MOD/EA MOU) with the environmental regulators that describe the arrangements to establish a degree of control equivalent to that in the civil sector. These Annexes can be found at [to be inserted]. 9 Unless items can be disposed of under local regulations overseas with agreement of the countries relevant bodies radioactive waste is to be returned to the UK and disposed of in accordance with UK legislation and the agreement of the UK regulators. DISCHARGES TO THE ENVIRONMENT 10 Waste owners and managers are to ensure the proactive publication of information about discharges to the environment of radioactive substances as required by the Environmental Information Regulations.

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11 It is MOD policy to provide information about radioactive discharges to the environment for inclusion in the Environment Agencys National Pollution Inventory; DGSM provides data to the Environment Agency. DS&C currently coordinates the inclusion of data for inclusion in the Radioactivity in Food and the Environment Reports (RIFE Reports) produced by the Food Standards Agency. These reports can be found at http://www.food.gov.uk/science/surveillance/radiosurv/ UK STRATEGY FOR RADIOACTIVE DISCHARGES 12 The MOD is bound by the national commitments in the UK Strategy for Radioactive Discharges 2001-2020, which sets out how the UK will implement the OSPAR radioactive discharge strategy. http://www.defra.gov.uk/environment/radioactivity/government/discharges/pdf/rad_dischargestrat1.pdf is the website address for this document. 13 The strategy requires: 13.1 progressive and substantial reduction of radioactive discharges and discharge limits, to achieve the strategy targets for each; 13.2 progressive reduction of human exposure to ionising radiation arising from radioactive discharges, as a consequence of reductions in discharges, such that a representative member of a critical group of the general public will be exposed to an estimated mean dose of no more than 0.02 millisieverts (mSv) a year from liquid radioactive discharges to the marine environment made from 2020 onwards; 13.3 progressive reduction of concentrations of radionuclides in the marine environment resulting from radioactive discharges, such that by 2020 they add close to zero to historic levels. (The terms "close to zero" and "historic levels" are not defined in the OSPAR Strategy and the OSPAR Commission is continuing to work on establishing agreed definitions). 14 This strategy recognises that, within the policy of progressive reduction, some flexibility will need to be maintained to safeguard other key Government objectives including the operational capabilities of the armed forces. 15 The Defence sector targets in the national strategy are: 15.1 By 2020, tritium discharges from the defence sector are expected to be reduced from 0.7 TBq to 0.4 TBq a year; and 15.2 year. 16 Other beta/gamma discharges are expected to be reduced from 0.005 to 0.003 TBq a

DS&C is the focal point for the collation of data for submission to DEFRA for the national strategy.

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CHAPTER 6 NON-IONISING RADIATION PROTECTION POLICY Contents Para 1 3 4 7 Table 1 Introduction Principles of Radiological Protection Legislation MOD Policy Page Nomenclature for Non-ionising Radiation........................................................................................3

INTRODUCTION 1 Non-ionising (NIR) radiation covers a range of the electromagnetic spectrum from the ultraviolet through visible light and radiofrequencies to static fields. The common designations for the division of non-ionising radiation into named regions are shown in Table 1. 2 This chapter is not intended to be applied to the exposure of patients undergoing exposure to NIR for therapeutic or diagnostic reasons. PRINCIPLES OF RADIOLOGICAL PROTECTION 3 There have been formal guidelines for the protection of personnel from non-ionising radiation for decades (certainly 1960 for radio frequencies and 1965 for lasers). The International Radiation Protection Association (IRPA), the international body representing radiation protection professionals world-wide, has chartered the International Commission on Non Ionizing Radiation Protection (ICNIRP) as an independent Commission for the purpose of advancing Non Ionizing Radiation Protection for the benefit of people and the environment and in particular to provide guidance and recommendations on protection from NIR exposure. There are also numerous professional and national bodies that make recommendation, give guidance or may legislate. Examples of these are the American Conference of Governmental Hygienists (USA), the Institute of Electrical and Electronics Engineers (USA), the Health Protection Agency (UK), IEC/CENELEC/BSI (international/Europe/UK lasers). LEGISLATION 4 There is no UK legislation specific to non-ionising radiation protection. Therefore, the following legislation is most relevant: the Health and Safety at Work etc Act 1974; the Management of Health and Safety at Work Regulations 1999 and the Health and Safety (Safety Signs and Signals) Regulations 1996. 5 The agencies enforcing UK legislation refer to the advice given to government by the Radiation Protection Division of the Health Protection Agency (formerly the National Radiological Protection Board). That advice is to conform to the ICNIRP guidelines.

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6 The European Union has adopted Directive (2004/40/EC) 29 April 2004 on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) that lays down the basis for controlling occupational exposure. This will be transposed into UK legislation, no later than 24 May 2008. It uses a scheme of basic restrictions and reference levels drawn from the ICNIRP guidelines. There also exists Council Recommendation (1999/519/EC) of 12 July 1999 on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz). Being a Recommendation, it is not binding on EU Member States, hence the lack of UK legislation, but the UK has moved towards its implementation. MOD POLICY 7 The Secretary of States Policy is discussed under ionising radiation protection policy and exactly the same principles apply to non-ionising radiation protection. 8 It is MOD policy that exposure of personnel to EMF will conform to the guidance from the Health Protection Agency's Radiological Protection Division, wherever reasonably practicable. Such exposure should, in addition, be kept to as low a level as is reasonably practicable. There is more information in Leaflet 22 of JSP 375 the MOD Health & Safety Handbook for electromagnetic fields and waves (0 Hz to 300 GHz) and JSP 390 Military Laser Safety.

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Table 1 Nomenclature for Non-ionising Radiation EM Spectrum Designations Static fields 0 Hz > 0 Hz Sub ELF 30 Hz ELF 300 Hz VF 3 kHz VLF 30 kHz LF 300 kHz MF 3 MHz HF 30 MHz VHF 300 MHz UHF 3 GHz SHF 30 GHz EHF 300 GHz or 1 mm IRC 3 m IRB 14 m IRA 760 nm Visible 400 nm UVA 315 nm UVB 280 nm UVC 100 nm continuation of ultraviolet 10 nm X & rays < 10 nm

Non-ionising

Infrared

Microwaves Electromagnetic

Radiofrequency (RF)

Ionising

X & rays

Ultraviolet

optical radiations

Vis

electromagnetic fields

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CHAPTER 7 RADIATION PROTECTION COMMITTEES Contents Para 1 2 4 Introduction Radiation Protection Policy Development Committee and the Radioactive Waste Working Group Radiation Protection Instrumentation Committee

INTRODUCTION 1 The roles and responsibilities for the overall management health safety and environment are described in JSP 815 Defence Environment and Safety Management. Broadly, there is a separation between functional safety boards that deal with policy, MOD parallel arrangements where legislation does not apply to MOD and assurance issues, and management boards and appointees that implement and assure compliance with legislation, MOD and local policy in health safety and environment. RADIATION PROTECTION POLICY DEVELOPMENT COMMITTEE AND THE RADIOACTIVE WASTE WORKING GROUP 2 The Defence Environment and Safety Board, Occupational Health and Safety Board (OHSB), Sustainable Development and Environment Board (SDEB) and Defence Nuclear Environment and Safety Board all have a functional interest in radiological protection. Their individual roles and interrelationships are described in JSP 815. 3 The Radiation Protection Policy Development Committee (RPPDC) reports to the OHSB and the Radioactive Waste Working Group (RWWG) to the RPPDC. The terms of reference (TORs) of both these Committees are contained in JSP 375. These committees may set up working groups as they deem necessary to develop policy on specific topics. RADIATION PROTECTION INSTRUMENTATION COMMITTEE 4 The Radiation Protection Instrumentation Committee (RPIC) reports to the RPPDC. Its TORs are given in JSP 425.

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CHAPTER 8 RADIATION PROTECTION APPOINTMENTS Contents Para 1 2 Aim Introduction Appointments by the Commanding Officer / Head Of Establishment Statutory Appointments Appointed Doctor Radiation Protection Adviser Radiation Protection Supervisor Dosimetry and Dosimetry Record Keeping Services MOD Appointments Radiation Safety Officer Workplace Supervisor Qualified Person Employees

3 4 5 6 7 8 9 11 AIM

1 This chapter outlines the duties and the responsibilities for radiological protection of personnel within establishments and units. INTRODUCTION 2 The Policy Statement on safety health and environmental protection in the Ministry of Defence by the Secretary of State for Defence devolves duties through the line management chain, such that the Commanding Officer/Head of Establishment is a duty holder for environmental and health and safety matters, including radiation protection (see JSP 815 Chapter 3 paragraph 28 etc). CO/HE is required to make a statement detailing their organisation and arrangements in these areas, the appointments detailed below will be part of this. APPOINTMENTS BY THE COMMANDING OFFICER / HEAD OF ESTABLISHMENT Statutory Appointments Appointed Doctor 3 In general, where classified persons are employed, the Commanding Officer/Head of Establishment is to ensure that a registered medical practitioner is available to carry out the duties of the Appointed Doctor (AD) under the Ionising Radiations Regulations 1999 (IRR99) The role of the AD and his appointment are described in Leaflet 6. Radiation Protection Adviser 4 A Radiation Protection Adviser (RPA) will advise the Commanding Officer/Head of Establishment on compliance with national legislation and MOD standards etc. The Commanding Officer/Head of Establishment has a duty to consult the Radiation Protection Adviser on matters which are set out in schedule 5 of IRR99. Sites working within MODs nuclear weapons and nuclear propulsion programmes will have appointed local RPAs. Otherwise, TLBs will have made arrangements for RPA advice to be available. The RPA for most units and establishment outside the nuclear programmes is Dstl Environmental Sciences Department.

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Radiation Protection Supervisor 5 Radiation Protection Supervisors (RPS) are to be appointed by the employer to enable work with ionising radiation to be carried out in accordance with legislation. Appointments are to be made in writing. Dosimetry and Dosimetry Record Keeping Services 6 Where IRR99 requires it, a HSE Approved Dosimetry Service must be used to undertake dose assessments using suitable monitors. It is a requirement of IRR99 that the records of such assessments are kept by a HSE Approved Dosimetry Record Keeping Service (ADRKS). Generally, arrangements for this will be made through the TLB. MOD Appointments Radiation Safety Officer 7 The role of the Radiation Safety Officer (RSO) is analogous to that of the Safety Adviser described in JSP 375. Depending upon workload, competence etc one or more individuals may be appointed to these roles. Appointments are to be made in writing. Workplace Supervisor 8 Workplace Supervisor (WPSs) are appointed where it is unnecessary to appoint an RPS, to undertake duties to ensure that work with sources of ionising radiation is carried out in accordance with legislation, the requirements of this publication and local orders for radiation safety. WPSs may be appointed to supervise radioactive materials, X-ray equipments or radon that does not require the setting up of designated areas or a combination of these activities. Appointments are to be made in writing. Qualified Person 9 The employer of an establishment which has its own ionising radiation protection instrument test house, is to appoint in writing one or more qualified persons to carry out or to supervise the testing of ionising radiation protection instruments in accordance with JSP 425 and IRR99. Qualified persons appointees are to receive the qualification and training specified in JSP 425. 10 Persons appointed to carry out or supervise the examination and testing of radiation detection and monitoring equipment are to, as a minimum, complete the training specified in JSP 425. Job specific training requirements are to be specified in local orders. EMPLOYEES 11 Employees also have the duties with regard to radiation protection described in regulation 24 of IRR99 and paragraph 560 of the ACOP.

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CHAPTER 9 TRAINING AND QUALIFICATIONS IN RADIATION PROTECTION Contents Para 1 3 5 6 Introduction Provision of Suitable Training Training and Qualifications for Specific Radiation Protection Posts and Appointments Training Records

INTRODUCTION 1 The Management of Health and Safety at Work Regulations 1999 (MHSWR 99) requires every employer to ensure that their employees are provided with adequate health and safety training on being first recruited and on being exposed to new risks this training is to be repeated periodically where appropriate. The Ionising Radiations Regulations 1999 (IRR 99) require employers to ensure that employees engaged in work with ionising radiation are given appropriate training in the field of radiation protection. 2 The particular, appointments specified by IRR 99 are the Radiation Protection Adviser (RPA), Radiation Protection Supervisor (RPS) and Appointed Doctor. The requirement for these appointments and other radiation protection appointments required within MOD are detailed in Chapter 8, which also identifies the duties of Commanding Officers and Heads of Establishment to make sufficient appointments and to ensure that appointees and other personnel are adequately supervised and have been given information, instruction and training in the tasks they are to undertake. PROVISION OF SUITABLE TRAINING 3 Commanding Officers and Heads of Establishment are to ensure that the training requirements, including refresher training, for all radiation protection appointments and employees engaged in work with ionising radiation are specified in local orders. It is also to be ensured that visitors who are provided access to ionising radiations are given suitable information, instruction and training. 4 The training specifications may draw directly from the requirements of this publication, from guidance issued by the regulators and from the advice of a suitable RPA. Training may often include generic training courses delivered by an MOD or external provider but it should also include elements specific to the task or job to be carried out and to the hazards and risks concerned. TRAINING AND QUALIFICATIONS FOR SPECIFIC RADIATION PROTECTION POSTS AND APPOINTMENTS 5 Training and qualifications for specific posts and appointments is detailed in Volume 2, leaflet 15.

TRAINING RECORDS 6 A record is to be kept of the training undertaken for two years following termination of the appointment.

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CHAPTER 10 RADIATION DOSE CONTROL Contents Para 1 3 5 Introduction Formal Investigation Level Non-human Species

INTRODUCTION 1 This chapter describes the MOD policy that is additional to the requirements of legislation. Detailed requirements can be found in Volume 2 of this publication. 2 Radiation doses are controlled by two regimes, overall management control and physical arrangements. Any practice involving exposure to ionising radiation must be planned and risk assessed. An element of this will be to ensure that doses are kept as low as reasonably practicable (ALARP). This will make it apparent whether or not the provisions of IRR99 relating to the designation of areas, classification of workers etc need to be applied. Out of this process, management should be able to establish targets that will assist them in assessing their success in achieving high standards of radiological protection including keeping exposures ALARP. An example of this is the dose constraint, which is set at a level consistent with the successful operation of the practice but lower than statutory limits and reporting points. FORMAL INVESTIGATION LEVEL 3 A formal investigation level is to be prescribed by Commanding Officers for occupationally exposed workers. This investigation level is set at a maximum of 6 mSv effective dose in any calendar year, although local circumstances will often justify the setting of a lower level. The RPA must be consulted as to the setting of an appropriate investigation level. 4 Where the effective dose to any MOD employee exceeds the investigation level, a locally conducted investigation is to be carried out by the Commanding Officer to determine whether all steps are being taken to keep radiation exposure ALARP. Detailed instructions are contained in Volume 2 Leaflet 14. The RPA must be consulted as to the conduct of this investigation. NON-HUMAN SPECIES 5 MOD follows the recommendations of the International Commission on Radiological Protection (ICRP) who believes that the standards of environmental control needed to protect man to the degree currently thought desirable will ensure that other species are not put at risk. Occasionally, individual members of non-human species might be harmed, but not to the extent of endangering whole species or creating imbalance between species. However, the ICRP are revisiting this position and are developing criteria for reference animals and plants. MOD will follow developments, both internationally and nationally, and will keep this policy under review.

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CHAPTER 11 RECORD KEEPING Contents Para 1 2 4 7 8 11 Annex A Records of Interest Primary and Secondary (Supporting) Records Introduction Dosimetry Records Record Retention MOD Agencies Closure of Sites Privatised Companies

INTRODUCTION 1 The keeping of many radiation records is a statutory requirement and within legislation the timescales for which records have to be kept are also specified. MOD policy on record keeping is to keep records for the statutory period unless otherwise specified in this chapter. For ships, units and establishments which are not part of the nuclear programmes further detail is given in Volume 2 of this JSP. Other guidance is contained in JSP 375 and in statements issued by DG Info. DOSIMETRY RECORDS 2 There is a statutory requirement for radiation dose records to be kept in accordance with the Ionising Radiations Regulations 1999, REPPIR and Ionising Radiations Regulations (Medical) 2000, their associated Codes of Practice and Guidance Notes. Periods of record retention and those who are to keep the records, for example an HSE Approved Dosimetry Record Keeping Service (ADRKS), are often specified in the regulations. There may also be additional timescales contained within authorisation conditions for MODs nuclear facilities. However, the statutory requirement for retaining records is mostly directed at ensuring that current arrangements are in place for radiation protection. This policy specifically covers historical records. 3 Radiation dose records for Unclassified Radiation Workers are to be kept by the ADRKS or the employer where they are held locally indefinitely so that they are available in the event of a compensation claim or a request for radiation worker counselling. RECORD RETENTION 4 MOD policy is that all MOD units, including Dstl and other MOD Agencies are to retain, both for service and civilian personnel, all primary records (see Annex to this chapter) except those records held on their behalf by the Approved Dosimetry Service (ADS). Issue lists and laboratory certificates are to be kept for the period specified by the ADS.

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5 Similarly, all MOD units, including Dstl and other MOD Agencies are to retain the supporting documents (see Annex to this chapter) for the statutory laid down periods. At the end of these periods these organisations will undertake an assessment of the relevance of retaining these documents for supporting or refuting future claims. The Radiation Protection Adviser (RPA) and ADS should be consulted where doubt exists as to the future relevancy of retained documents, equally the originating author or its successor organisation should be consulted regarding the relevance of retaining associated historic documents. It is expected that in most circumstances the decision will be to retain the documents. In such circumstances such documents are to be archived following standard MOD procedures. Where on the basis of a risk assessment a decision is taken to destroy such records, the Commanding Officer or Head of Establishment, may be held accountable for this action in the event of a claim arising against MOD for work undertaken in his business area for which records no longer exist. 6 Leaflet 39, Annex E provides retention times for current records.

MOD AGENCIES 7 MOD Agencies, including Dstl, will hold both primary and supporting historic documents (see Annex to this chapter) for their predecessor organisations. These documents become the responsibility of these Agencies. Agencies may arrange by mutual agreement and the transfer of financial provision to other MOD business areas for these areas to take over their responsibilities. This will be achieved by written agreement. CLOSURE OF SITES 8 The following information must be made available, if not previously made available, to Defence Estates at handover of a site following closure. The Commanding Officer or Head of Establishment is responsible for ensuring that the following documents are provided as appropriate. 8.1 8.2 8.3 Radioactive Substances Clearance Certificates relating to the site. Reports pertinent to the storage of radioactive sources on site. Radiological survey reports, internal and external to buildings.

8.4 Reports pertinent to historical radiological contamination remediations, internal and external to buildings, and the final destination of any remediated radioactive material be it on, or off site. 8.5 Reports relating to on-site disposal of radiological sources including landfilling and burning grounds. 9 For sites that are to close and whose function is not to be transferred to another MOD organisation or Agency they are to forward their records, having removed any records that are already held by the ADRKS (usually Dstl Environmental Sciences Department (Dstl ESD) Approved Dosimetry Service) to the MOD archive, as is the case with other preserved establishment documents. Dstl ESD and the Directorate of Safety and Claims (DS&C) are to be informed when this occurs and they are to be supplied with the references provided by the archives so documents can be withdrawn from the archives at a future date should they be required. It is recognised that this may lead to delays in responding to Compensation Scheme claims. The amount of delay will correspond to the time taken to withdraw the historic records from archives. 10 Where Dstl ESD considers it appropriate for the records to be entered electronically on the Dosimetry Index and Database (DOSIND) they will notify DS&C. DS&C will continue to populate the DOSIND database with the limited funds it has at its disposal. Priority will be given to documents from those organisations from whom most claims have been made under the Compensation Scheme.

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PRIVATISED COMPANIES 11 Privatised companies and Government owned contractor operated sites e.g. the Royal Dockyards and AWE Aldermaston, often hold on their sites individuals historic radiation dose records, other associated documents relating to their work, administrative arrangements and other records prior to vesting day. Such companies are under contract to provide services to MOD business areas. These business areas, or their successors where they cease to exist, are the organisations responsible for the companies maintenance of such records, usually through the contract, and for their financial provision. Such companies may arrange by mutual agreement and the transfer of financial provision for other MOD business areas to take over such responsibility.

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CHAPTER 11 ANNEX A RECORDS OF INTEREST PRIMARY AND SECONDARY (SUPPORTING) RECORDS

PRIMARY RECORDS 1 Records of interest can be conveniently divided into primary records and supporting records. Primary records are those that will be required to support claims brought under the Compensation Scheme for Radiation Linked Diseases, war pensions, personnel radiation protection litigation and radiation worker counselling. The list below includes such records. The list is not exhaustive. Individual personal radiation dose records for classified and non-classified workers generated by an Approved Dosimetry Service (ADS) and maintained by them. 1.1 Records of personal dose generated from locally issued dosimetry. 1.2 Dose information for individuals working under a written system of work, or equivalent, based upon workplace dose rates (e.g. radiation surveys of controlled and supervised areas) and length of exposure. 1.3 Whole body monitoring results not entered into the ADRKS record. 1.4 Accident and incident investigation reports made for the purposes of Regulations 28 and 29 of the Ionising Radiations Regulations 1985 and the regulations listed in paragraph 2 below. 1.5 Accident and incident investigation reports not covered by (1.4) above which occur in a controlled or supervised areas. 1.6 Summaries produced in support of the Compensation Scheme, war pensions or radiation worker counselling. 1.7 Radon assessments in radon affected areas that may be used to estimate the radiation exposure of members of the MOD workforce. 1.8 Health registers. SECONDARY (SUPPORTING) RECORDS 2 Supporting documents are those which may be needed for claims brought against MOD through the courts by workers and former works claiming ill health which they attribute to their occupational exposure to ionising radiation. The list below includes the following records which is not exhaustive: 2.1 Site and process risk assessments, their reviews and updates or amendments. 2.2 Local rules and/or local orders. 2.3 Records of controlled and supervised areas. 2.4 Radiation and contamination monitoring surveys in such areas. 2.5 Safe operating procedures, permits to work and systems of work (and equivalent). 2.6 Maintenance and examination and testing records including ventilation, respiratory and other personal protective equipment. 2.7 Environmental monitoring records.

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LEAFLET 1 ACQUISITION OF SOURCES OF IONISING RADIATION BY IPTs CONTENTS Para

1 2 3 5 6 12 13 Table 1 Annex A

Scope Introduction Statutory requirements and parallel arrangements Duties Acquisition Records Related leaflets Page Related leaflets................................................................................................................................3

Summary of regulatory and MOD requirements

SCOPE 1 This leaflet covers the acquisition of sources of ionising radiation by Integrated Project Teams (IPTs). The acquisition of sources of ionising radiation for organisations other than IPTs is covered in Leaflet 3. INTRODUCTION 2 The following information describes the statutory requirements and reflects the MOD policy for the acquisition of radioactive materials and other sources of ionising radiation, and the procedures to ensure compliance. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Justification of Practices Involving Ionising Radiation Regulations 2004 (parallel arrangements). Ionising Radiations Regulations 1999 (IRR 99) (apply directly). Radioactive Substances Act 1993 (RSA 93) and associated Exemption Orders (parallel arrangements). High-activity Sealed Radioactive Sources (HASS) and Orphan Sources Regulations 2005 (parallel arrangements). Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) 2001 (apply directly).

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4 The requirements for notification, approval and assessment to meet MOD policy and the above regulations are included in this Leaflet. Advice is to be sought at the earliest opportunity from the appointed Radiation Protection Advisor (RPA) on the scope of application of any particular legislation. DUTIES 5 IPT Leader (IPTL). The general legal duties of suppliers, manufacturers and others will apply to IPTs supplying equipment (including replacement parts) to the armed forces (JSP 375, volume 1, Chapter 7). This specifically includes the duty to identify radioactive materials contained in equipments or emissions of ionising radiation For sources of ionising radiation, the IPTL must ensure that the equipment is designed and constructed to restrict exposure so far as is reasonably practicable to employees and the public from the source of ionising radiation. This will include undertaking a critical examination to ensure that safety features operate correctly, there is sufficient protection from exposure to ionising radiation and that the end user is provided with adequate information about the proper use, testing and maintenance of the equipment. The IPTL is responsible for ensuring that clear and unambiguous information is passed along the whole supply chain from the design, manufacture and supply to the use or installation. 6 The majority of DE&S projects follow the Concept, Assessment, Demonstration, Manufacture, InService and Disposal (CADMID) lifecycle model. The MODs Acquisition Safety and Environmental Management System (ASEMS) is applicable to this model and includes two core safety manuals for IPTs. These manuals are the Project Orientated Safety Management System (POSMS) and the Project Orientated Environmental Management System (POEMS). These assist IPTs in complying with regulatory and policy requirements. Note: POEMS and POSMS do not apply to nuclear based technologies , for example, the naval nuclear propulsion programme. 7 There is a statutory requirement for the IPTL to consult a (RPA) which must be undertaken at the earliest opportunity when a source of ionising radiation is being considered in the Concept stage of the project. The RPA must be consulted on: The prior examination of plans for new installations. Acceptance into service of new or modified sources of ionising radiation. Engineering controls. Design features. Safety features and warning devices to restrict exposure to ionising radiation.

8 The RPA must also be consulted with regard to the nature and extent of the critical examination for equipment containing radioactive substances or equipment generating X-rays. In addition the RPA must be consulted with regard to the results or findings of the critical examination. 9 Early RPA consultation is required in relation to the above requirements but also to determine whether the radiation hazard can be avoided altogether. If there is an operational advantage in using a source of ionising radiation then the RPA will form part of the team of IPT safety experts advising on the IPT Safety Case Report at each stage of the CADMID cycle. 10 Details of the source of ionising radiation must be included in the hazard log together with details of the other hazardous materials present. Similarly, an assessment of the radiation risks must be included in the IPT Safety Case Report which is produced at each stage of the CADMID cycle. The radioactive source must be identified on JSP 515: Hazardous Stores Information System (HSIS) and a summary of the radiation risks identified in the safety case must be provided to the user. This information is normally provided in the relevant equipment manuals.

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11 Before any source of ionising radiation is introduced, permanently or temporarily, (including for trials) into the unit or establishment, a number of requirements for prior notification or approval may be required and must be considered by the IPT, these requirements are included at Annex A. Before a HASS source is acquired the IPTL must demonstrate that there are safe management arrangements for the source at the end of its useful service working life including a requirement that suitable financial provisions have been made for disposal. A list of the key statutory and MOD mandatory requirements are summarised at Annex A. RECORDS 12 Any records generated shall be retained in accordance with MOD Record Retention Policy.

RELATED LEAFLETS 13 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 2 3 Risk assessments Notification, approval and assessment of the introduction and use of sources of ionising radiation including radioactive substances Radiation protection adviser consultation and advisory visits Sale of radioactive and contaminated goods Accumulation and disposal of radioactive waste MOD Health and Safety Handbook Leaflet Title

7 11 12 JSP 375 V 1, Ch 7 JSP 515

Hazardous stores information system

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LEAFLET 1 ANNEX A SUMMARY OF REGULATORY AND MOD REQUIREMENTS

Requirement

Regulation/Policy (IRR99) Reg 13 (1). POEMS and POSMS see para 7. JSP375 POEMS & POSMS JSP 392 Justification of Practices Involving Ionising Radiations Regulations 2004. JSP 392 Volume 1. IRR 99 Reg 5. IRR 99 Reg 6. IRR 99 Reg 7. Management of Health and Safety at Work Regulations 1999. (RSA 93). JSP 392 Volume 1.

Comment The RPA is the subject matter expert for radiation protection advice. See par 5-11 of this leaflet

Related leaflet 7

RPA consultation Identification of radioactive materials and emissions of radiation Notification and approval for introduction or modification Justification of practice Authorisation of specific practices Notification to HSE for specified work

3 Not applicable to defence activities. MOD operates parallel arrangements. HSE authorisation required. HSE notification. Radiation risk assessment must be undertaken before the source is acquired. The risk assessment will identify other IRR 99 requirements. MOD exempt but applies parallel arrangements with EA/SEPA. MOD exempt but applies parallel arrangements with relevant environment agency. If MOD sells or transfers equipment then it takes on role of a supplier and must ensure that equipment complies with legislation. MOD exempt but applies parallel arrangements. Threshold activity level triggers HASS requirements. Threshold activity level triggers REPPIR requirement. Other requirements detailed in Leaflet 3.

3 3

Prior risk assessment

Notifications to keep or use radioactive material

Authorisation for disposal of radioactive waste.

RSA 93. JSP 392 Volume 1.

11 & 12

Notification, control and transfer of high activity sealed sources Hazard assessment and risk evaluation report and report of assessment.

High Activity Sealed Radioactive Sources and Orphan Source Regulations 2005 (HASS). JSP 392 Volume 1. Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) 2001.

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LEAFLET 2 RISK ASSESSMENTS CONTENTS Para

1 2 3 3 4 5 7 8 9 11 17 19 21 22 23 Table 1 Annex A

Scope Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Risk assessment Prior Risk Assessment (PRA) Actions arising from a prior risk assessment Contingency plans Review of risk assessments including prior risk assessments Records Related leaflets Page Related leaflets................................................................................................................................4

Contents of prior risk assessments

SCOPE 1 A suitable and sufficient risk assessment is required for equipment generating ionising radiation or containing radioactive material. This leaflet details what is required in such a risk assessment and the requirements for a prior risk assessment for a new activity involving work with ionising radiation. The matters to be addressed in a risk assessment are also detailed. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR 99) (apply directly).

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DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure all sections have appropriate risk assessments for all work with ionising radiation. The RSO may be required to liaise with the RPS, the IPT, the RPA and others in obtaining a suitable and sufficient risk assessment. The RSO is to ensure that any radiation risk assessments have been brought to the attention of those persons that may be affected by their contents. Radiation Protection Supervisor (RPS) 5 An RPS must be appointed where it is necessary to designate a controlled or supervised area. Where an RPS is appointed, their duties are to include obtaining from the appropriate IPT, or prepare in conjunction with the RSO and RPA, risk assessments for work involving ionising radiation and ensure those risk assessments and contingency plans provided are sufficient for work in their area or section. 6 If a new work activity with ionising radiation is planned a suitable and sufficient prior risk assessment is to be requested as early as possible from those initiating the work. Workplace Supervisor (WPS) 7 In units where it is unnecessary to appoint an RPS, a WPS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety (see Leaflet 16). In addition to those duties, a WPS may be required to assist in the preparation of risk assessments and contingency plans. Employees 8 It is the responsibility of employees to ensure that they are familiar with the content of all risk assessments and contingency plans. RISK ASSESSMENT 9 The general requirement to have a risk assessment as required by MHSWR 99 is dealt with in Leaflet 39 of JSP 375. Where work involves ionising radiation there is a requirement to ensure that the risk assessment considers radiological as well as non-radiological hazards and is suitable and sufficient. In general, a risk assessment is to: 9.1 9.2 9.3 9.4 10 Identify the hazards and how they arise. Investigate how the hazards arise and impact those affected. Explain how the risks are managed, and Undergo a review at least annually or when there are material changes.

Summary risk assessments for some equipment are included in the annexes of the relevant leaflet.

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PRIOR RISK ASSESMENT (PRA) 11 The requirement for a prior risk assessment compliments the related requirement for risk assessment as described above. IRR 99 requires that a new work activity involving work with ionising radiation or radioactive material must not begin until a prior risk assessment has been completed. The main purpose of the prior risk assessment is for the CO to identify the measures needed to restrict the exposure of employees and other persons. Both routine exposure and hazards with the potential to cause a radiation accident must be considered and evaluated. 12 Radiation risk is also to be considered at the requirements definition stage of the procurement cycle for equipment containing radioactive material or emitting ionising radiation, and is to be addressed through service to disposal. All aspects of maintenance and operation (including military service) are to be taken into account. 13 Those managing the procurement process for the equipment containing radioactive material or emitting ionising radiation are, in consultation with the appropriate RPA, to assess the risks and recommend solutions to reduce the risks in order to reduce exposure to radiation to as low as reasonably practicable (see Leaflet 1). 14 The content and considerations for a prior risk assessment are specific to ionising radiation and are detailed in Annex A. 15 The prior risk assessment must be suitable and sufficient for the work activity, so for many activities for which the hazard may be limited, the prior risk assessment need not be complex. The RPA is to be consulted for assistance in the preparation of meeting the requirements of Annex A. 16 A prior risk assessment will satisfy the requirements of a risk assessment detailed in Leaflet 39 of JSP 375 as far as protection from ionising radiation is concerned. However, the radiation protection aspects of the work activity are not to be considered in isolation from other health and safety consideration as one may impact on the other. ACTIONS ARISING FROM A PRIOR RISK ASSESSMENT 17 Units and establishments are to introduce safety measures to eliminate or minimise the risk, as identified in the risk assessment, and provide information, instruction and formal training as appropriate to reduce radiation exposure. 18 Units and establishments are also to identify processes in which, as a consequence of an accident or incident; 18.1 any person may receive a radiation overexposure as a result of a single exposure (see Leaflets 6 and 14), or 18.2 a new controlled area (see Leaflet 4) would be required to restrict access to high dose rate or contaminated areas. CONTINGENCY PLANS 19 Where the risk assessment identifies that a risk exists from an identifiable radiation accident, the CO must take all reasonably practicable steps to prevent any such accident and to limit the consequences of any such accident which does occur. The CO must also provide employees with the information, instruction, training and equipment necessary to restrict their exposure to radiation from accidents. 20 When a prior risk assessment identifies that a radiation accident is reasonably foreseeable, having regard to the steps taken to prevent and limit the consequences, contingency plans are to be produced by the unit or establishment. The RPA is to be consulted on the compilation of the contingency plan. Leaflet 40 gives further details on contingency plans.

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REVIEW OF RISK ASSESSMENTS INCLUDING PRIOR RISK ASSESSMENTS 21 Risk assessments shall be reviewed by a unit or establishment at least annually, however more frequent review may be necessary as determined by taking into account the nature of the work, degree of risk and the extent of any likely changes in the work activity. Additionally, the risk assessment is to be reviewed where: 21.1 There is reason to suspect that the assessment is no longer valid (e.g. due to equipment or process modifications). 21.2 RECORDS 22 Risk assessments should be live documents held locally and must be made available to ensure sufficient distribution to individuals involved in the work to which it refers and to auditors and regulators when required. If a new assessment is required, the old risk assessment is to be retained for a minimum period of 2 years from the date of the new assessment (see Volume 1, Chapter 11). RELATED LEAFLETS 23 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related leaflets Leaflet Number 1 4 6 14 16 40 Leaflet Title There has been a change in the work to which the assessment relates.

Procurement of sources of ionising radiation Restriction of exposure to radiation Dosimetry Investigation, notification and reporting of unusual radiation events Local orders for radiation safety Contingency plans

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LEAFLET 2 ANNEX A CONTENTS OF PRIOR RISK ASSESSMENTS

A prior risk assessment is to consider and contain: 1.1 A detailed description of the work to be undertaken and the intended use of the equipment or process under normal operating conditions, including any planned systems of work. 1.2 The reasons for using particular sources of ionising radiation. (This is not needed if the work involves radioactive material arising from the nuclear propulsion or nuclear weapons programmes, or the management of radioactive waste). 1.3 A description of the radionuclides involved in the process, their form (sealed sources or unsealed radioactive substances) and an estimate of the maximum activities involved. Accumulation of radon in the working environment is to be included. 1.4 A description of any equipment which emits radiation.

1.5 Plans of installations and diagram(s) of the equipment or process, including engineering control measures and design features already in place or planned. 1.6 Description of any controlled and supervised areas

1.7 Estimate of the radiation dose rates and the maximum individual and collective radiation doses likely to be received in normal operation. 1.8 Assessment of the likelihood of contamination arising and being spread and estimates of levels of airborne and surface contamination likely to be encountered. 1.9 The results of any previous personal dosimetry or area monitoring relevant to the proposed work. 1.10 Advice from the manufacturer or supplier of the equipment about its safe use and maintenance. 1.11 1.12 Engineering control measures and design features already in place or planned. Any planned systems of work.

1.13 The effectiveness and suitability of personal protective equipment (PPE) that is to be provided 1.14 The extent of unrestricted access to working areas where dose rates or contamination levels are likely to be significant. 1.15 Details of any possible accident scenarios, their likelihood and potential severity.

1.16 The consequences or possible failures of control mechanisms such as interlocks, ventilation systems, warning devices or systems of work 1.17 Steps to prevent identified accident situations or limit their consequences.

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The prior risk assessment should enable the following to be determined: 2.1 What action is needed to ensure that the radiation exposure of all persons is kept as low as reasonably practicable (see also Leaflet 4). 2.2 What steps are necessary to achieve the control of exposure by the use of engineering controls, design features, safety devices and warning devices and by the development of systems of work. 2.3 Appropriateness and type of personal protective equipment (see also Leaflet 4) 2.4 Whether appropriate to establish any dose constraints for planning or design purposes (see Leaflet 4) 2.5 The need to alter the working conditions of any female employee who declares she is pregnant or breastfeeding (see Leaflet 4) 2.6 An appropriate investigation level to check that exposures are being restricted as far as reasonably practicable (see Leaflet 4). 2.7 Maintenance and testing schedules for control measures 2.8 Necessary contingency plans 2.9 The training needs of classified and unclassified employees 2.10 The need to designate areas as controlled or supervised (see Leaflet 4)

2.11 Actions needed to ensure restriction of access and other measures in controlled and supervised areas 2.12 The need to designate certain employees as classified persons

2.13 The content of suitable programmes of dose assessment for those who must enter controlled areas (see Leaflet 6) 2.14 2.15 The responsibility of managers for ensuring compliance with regulations An appropriate programme of monitoring or auditing of the requirements of the regulations.

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LEAFLET 3 NOTIFICATION, APPROVAL AND ASSESSMENT OF THE INTRODUCTION AND USE OF SOURCES OF IONISING RADIATION INCLUDING RADIOACTIVE SUBSTANCES CONTENTS Para 1 2 4 6 7 8 9 10 11 16 19 23 30 38 39 40 42 43 46 49 54 59 60 Table 1 Annex A B C D E F G H I J Prior authorisation for the use of electrical equipment intended to produce X-rays Prior authorisation for the use of accelerators (other than electron microscopes Particulars to be provided to the HSE in a notification under IRR99 Regulation 6.2 Exemption from notification to HSE Form for HSE notification of work with ionising radiation Quantities of radioactive substances requiring hazard identification and risk evaluation Particulars to be included in a REPPIR HIRE assessment report Prior information to be supplied and made publicly available Exemption from notification under the Radioactive Substances Act 1993 Control of High Activity Sealed Sources (HASS) Scope Introduction Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Route for notification and approval for introduction or modification Actions required under specific legislation Justification of Practices Involving Ionising Radiation Regulations 2004 (JPIIRR) Ionising Radiations Regulations 1999 (IRR99) Authorisation of specified practices (Regulation 5). Notification to HSE of specified work (Regulation 6) Radioactive Substances Act 1993 (RSA93) Provision of notifications and approvals to EA, SEPA and EHSNI Public disclosure of information Pollution inventory reporting Inspections by the environmental regulatory authorities Ships and overseas establishments Breaches of arrangement to hold/dispose of radioactive substances High Activity Sealed Sources Regulations 2005 (HASS) Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) Reporting of hazard assessment & risk evaluation documents to HSE Medicines (Administration of Radioactive Substances) Regulations 1978 as amended (1995) Records Related Leaflets Page Related Leaflets.............................................................................................................................11

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SCOPE 1 This leaflet covers the notification, approval and assessment of the introduction and use of sources of ionising radiation including radioactive substances. The following information describes the legal and MOD requirements for the introduction and use of such items, materials and sources of radiation, and the procedure to ensure that these requirements are met. The requirement to notify regulatory bodies (Health and Safety Executive (HSE), Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI)) or MOD authorities of the occurrence of radiation incidents, accidents, and over exposures is addressed in Leaflet 14. INTRODUCTION 2 Before any source of ionising radiation is introduced, permanently or temporarily, (including for trials) into the unit or establishment, a number of requirements for prior notification or approval must be met. 3 The RPA must be consulted at the earliest opportunity to advise on regulatory issues associated with the introduction into service of a new source, or modifications to an existing source, of ionising radiation. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 4 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Justification of Practices Involving Ionising Radiation Regulations 2004 (parallel arrangements). Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) and associated Exemption Orders (parallel arrangements). High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASS2005) (parallel arrangements). Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR2001) (apply directly). Medicines (Administration of Radioactive Substances) Regulations 1978 as amended (1995) (apply directly).

5 The requirements for notification, approval and assessment to meet MOD policy and these regulations are set out in the following paragraphs. Advice is to be sought from the appointed RPA on the scope of application of any particular legislation. DUTIES Commanding Officer (CO) and Head of Establishment 6 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO).

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Radiation Safety Officer (RSO) 7 If appointed and where authority has been delegated, the Radiation Safety Officer (RSO) will normally discharge the duties of the Commanding Officer with respect to notification and approvals. This will include the actions outlined below under specific legislation. Radiation Protection Supervisor (RPS) 8 A Radiation Protection Supervisor must be appointed where it is necessary to designate areas as controlled or supervised (see Leaflet 4). Where an RPS is so appointed they are to ensure that the work is carried out in accordance with local orders for radiation safety (see Leaflet 16) which addresses the requirements of this leaflet. Workplace Supervisor (WPS) 9 In units where it is unnecessary to appoint an RPS, a WPS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety. In addition to those duties, a WPS may be required to assist in the preparation of the submissions required by this leaflet. Employees 10 It is the responsibility of all employees to ensure that changes to holdings of or work with radioactive material or radiation generators are notified to the RPS or other appropriate person and that all relevant local instructions are complied with. ROUTE FOR NOTIFICATION AND APPROVAL FOR INTRODUCTION OR MODIFICATION 11 The requirements of the procurement process to be followed for equipment incorporating sources of ionising radiation are set out in Leaflet 1, particularly with reference to Projects where DE&S Integrated project team leaders (IPTL) have responsibility. 12 Units, establishments and sponsors of new equipment are to direct their requests for approval to introduce or modify equipment through the TLB Safety Authority (e.g. CESO for the TLB), ensuring that potential issues for radiation safety are raised are copied to the RPA. The notification is to include the following information: 12.1 12.2 12.3 12.4 Name and address of the establishment. Brief description of the proposed introduction or modification. Proposed date of introduction. Prior risk assessment (see Leaflet 2).

13 For installations e.g. radiography facilities, approvals may be conditional upon confirmatory radiation measurements being taken as part of the commissioning or acceptance procedure. 14 Any request for approval is to be made at an early stage (before any procurement action commences) and is to include a suitable and sufficient prior risk assessment, where required (see Leaflet 2). Where the proposal concerns the design of new equipment the responsibility lies with the MOD design authority to seek approval for the introduction through TLB Safety Authority, ensuring that radiation safety is addressed, before the detailed design is undertaken. 15 Sponsors of new equipments or components (whether to be introduced permanently or on trial), or individuals making changes to existing apparatus that could have a radiation health and safety implication, are also to inform, and seek approval through relevant channels. This is to be undertaken at an early stage (before any firm commitments are entered into) and is to either include a new prior risk assessment, or an updated version of a previously written prior risk assessment (see Leaflet 2).

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ACTIONS REQUIRED UNDER SPECIFIC LEGISLATION Justification of Practices Involving Ionising Radiation Regulations 2004 (JPIIRR) 16 Whilst these regulations do not apply directly to defence activities, it is recognised that justification is the first principle of radiological protection, as recommended by the International Commission on Radiological Protection (ICRP). In accordance with the Secretary of States Policy Statement, the MOD will develop arrangements that are, so far as reasonably practicable, at least as good as those required by these regulations. 17 The Department for Environment, Food and Rural Affairs (DEFRA) has published on their web-site (www.defra.gov.uk) a list of existing practices that pre-date the requirement of the regulations. Most of the non-nuclear activities carried on by MOD will come under one or other of these existing practices. Practice has a very wide, generic, meaning and does not relate to any particular site or location. It will therefore be unusual for there to be a new type or class of practice. 18 Any unit or organisation intending to introduce a new type or class of practice within the meaning of the regulations is to notify the Occupational Health and Safety and Radiation Protection team at DS&C (OHS and RP), Postal Point 6-D, MOD Main Building, Whitehall, LONDON, SW1A 2HB of details of the activity in good time before its proposed introduction date. Additionally, DS&C (OHS and RP) is to be notified if new and important evidence about an existing practices efficacy or consequences is acquired. Ionising Radiations Regulations 1999 (IRR99) Authorisation of specified practices (Regulation 5) 19 A prior authorisation granted by the Health and Safety Executive in writing must be obtained by each unit or establishment carrying out the following types of work, for the first time: 19.1 The use of X-ray generators for 19.1.1 Industrial radiography; 19.1.2 The processing of products; 19.1.3 Research; 19.1.4 The exposure of persons for medical treatment; 19.2 The use of an accelerator, except electron microscopes.

20 The HSE has issued generic prior authorisations, including those for use with X-ray machines (Annex A) and accelerators (Annex B). They contain conditions to be met by the above categories of work. If a unit or establishment can fulfil all of the criteria contained in the appropriate generic prior authorisation and a copy of it is held by the unit or establishment no further action is required. Further equipment specific guidance is located in the appropriate Leaflets. Such documents are to be made available to HSE inspectors and RPAs during their visits. Units and establishments will be expected to demonstrate compliance with the criteria they contain. X-ray machines which are used for security purposes do not require prior authorisation. 21 Units and establishments who undertake the above work but who are unable to meet the generic authorisation criteria are to apply for an individual authorisation from the HSE before undertaking any practice listed in paragraph 19. Advice on the need for such a prior authorisation and the procedure for seeking it is to be sought from the RPA. Copies of the application and correspondence received from the HSE are to be copied to the RPA. For units and establishments overseas, applications are to be made through normal channels, seeking advice from the RPA on appropriate standards (ie those of the host nation or UK) to be met as appropriate.

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22 Material changes in circumstances or to working practices related to the authorisation are to be notified to the HSE. Advice on whether changes should be notified to the HSE is to be sought from the RPA. Notification to HSE of specified work (Regulation 6) 23 Units and establishments within Great Britain are to notify the HSE of all work involving ionising radiations. For establishments in Northern Ireland the Health & Safety Executive Northern Ireland is to be notified of all work involving ionising radiations. This will normally include work with: radioactive sources and other radioactive substances (including radioactive valves and equipment with radioactively luminous components), x-ray sets, accelerators and other radiation generators (including equipment where ionising radiation is produced incidental to their intended use). Such notifications are to be submitted to the HSE with at least twenty-eight days notice prior to commencing the work for the first time or such shorter time as the HSE may agree. In the particular case of work in radon atmospheres or with naturally occurring radionuclides, notification is to be made as soon as possible after the work has commenced. The procedure for notification is given at Annex C. The form contained in Annex E is to be used for this purpose. 24 Issues of security arising from the provision of information to the HSE are to be raised through normal staff channels. For units and establishments with more than one employer, the local officer in overall control of the MOD site shall carry out the notification to HSE for the MOD work at that site or establishment. Overseas establishments are to notify the relevant competent authority where appropriate. Advice is to be sought from the RPA as necessary. 25 There are some exemptions from the requirement to notify the HSE of work with ionising radiations. The types of practices that are exempt from notification are listed in Annex D. Categories of equipment that are of a type approved by the HSE are exempt from the notification requirements, for example many smoke detectors in common use are covered. Further advice on the need to supply notification is to be obtained from the normal staff channels, or with their agreement, from the RPA. 26 In addition to submitting the notification to the HSE local office a copy of the notification is to be sent to: 26.1 26.2 The TLB Safety Authority (e.g. CESO for the TLB); The RPA; and

26.3 Dstl Environmental Sciences Department (ESD) at the Institute of Naval Medicine, Alverstoke, GOSPORT, Hants PO12 2DL. 27 A further notification will be required immediately following any material change to the particulars notified to the HSE. Again the information is to be copied to the authorities in the paragraph above. 28 Similarly, HSE are to be notified when work with ionising radiation ceases on site.

29 Details of the local HSE office are to be obtained in the first instance from the unit or establishment Health and Safety Officer. Radioactive Substances Act 1993 (RSA93) Provision of Notifications and Approvals to EA, SEPA and EHSNI 30 The Radioactive Substances Act 1993 does not apply to premises occupied on behalf of the Crown for defence purposes. However, MOD has a policy to implement parallel arrangements to those required by the Act. Dstl ESD is tasked to provide advice to Commanding Officers and Heads of Establishments on how they comply with such arrangements.

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31 To enable MOD to apply parallel arrangements to those set out under RSA93, Dstl ESD maintains a database of radioactive material holdings for all units and establishments. In order to ensure that this database is accurately maintained, units and establishments are to comply with the following procedure: 31.1 In January of each year Dstl ESD will send out a Holdings Return to all units and establishments that will detail any radioactive material previously notified to Dstl ESD. 31.2 The Commanding Officer or Head of Establishment is responsible for ensuring that the information on the Holdings Return is updated, complete and accurate. The Holdings Return (including a nil return) is to be returned to Dstl ESD Alverstoke by 31 March of each year. The presence of nuclear weapons must not be declared on the Annual Holdings Return. 31.3 Chief Environment and Safety Officers or equivalents are to remind their units, by 1 February each year, of the requirement to complete the return by 31 March. 31.4 On receipt of the Holdings Return, Dstl ESD Alverstoke will check the data, verify any changes with the unit or establishment and update the database. 31.5 Commencing in April of each year, the data will be reviewed by Dstl ESD against extant Exemption Orders made under RSA 93 (see Annex I). An assessment will be made on whether a new notification, or a change in notification status, is to be made to the appropriate Regulatory Authority for the unit or establishment and is thus liable for an annual subsistence charge. 31.6 Dstl ESD will review source holdings to determine if any high activity sealed sources are held by the unit or establishment as these will become subject to special requirements which the RPA will advise upon. However, the responsibility for application for HASS notification and all other sources at that site will reside with the very small number of individual units concerned. 31.7 Dstl ESD will submit the updated information and the appropriate fee direct to the appropriate Regulatory Authority on behalf of the Commanding Officer or Head of Establishment. Dstl ESD will act as agent and will ensure that any correspondence is copied to the unit or establishment. 32 In addition to the above, within one month of introduction of new types of radioactive materials, a unit or establishment is to submit a revised list of radioactive holdings to Dstl ESD, as detailed in paragraph 31. 33 As a result of notification with the appropriate environment agency, each unit or establishment is issued with a Notification detailing the authorised holdings of radioactive materials. Dstl ESD forwards a copy of this Notification to the Radiation Safety Officer for retention and display at the unit or establishment. Standard conditions are set out at the beginning of all Notifications and must be complied with. It is advised that units liaise closely with their RPA with regards to compliance. 34 Revised Notifications are issued to units and establishments when amendments to authorised holdings are required and are not usually re-issued on an annual basis. 35 Notifications and Approvals are issued in the name of the Ministry of Defence. However if there is a change in the unit holding the radioactive articles at the site, the new unit is to notify Dstl ESD and the units RPA of the change of name forthwith. Both the unit leaving and arriving at the site must muster their radioactive holdings and produce a written record, which they are to retain for a minimum period of 2 years from the date of the last entry, see Leaflet 9. 36 Radioactive materials held at units and establishments in accordance with an exemption order are exempt from the requirements for a Notification, see Annex I. They are not exempt from the other requirements of the RSA93, particularly those relating to record keeping. Such exemptions do not affect the unit or establishments requirement to notify HSE (or HSE NI) under IRR99. All radioactive materials, including those exempt from the need for a Notification, are to be recorded and accounted for in accordance with Leaflet 9.

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37 In the United Kingdom Dstl ESD Alverstoke will act as central focal point for payment in support of Notifications and Approvals direct to the appropriate regulatory authority on behalf of Commanding Officers, Chief Executives, Heads of Establishment and Directors. Public disclosure of information 38 The regulatory authorities (EA, SEPA, and EHSNI) place applications for Notifications for Open sources (but not sealed sources) and Approvals on the public record unless specific instructions to the contrary are given. Dstl ESD is to be advised of any reasons for withholding information from the public record as soon as possible. In the absence of any information to the contrary Dstl ESD will allow the Notifications for Open sources and Approvals to be placed on the public record. A statement to this effect will be sent to all units and establishments with the Holdings Return in January of each year. The regulatory authorities do not place information relating to Notifications for Closed or Mobile sources on the public register. Pollution inventory reporting 39 The Environment Agency has expanded the scope of the Pollution Inventory for England and Wales to include radioactive waste. All holders of an Approval for the accumulation and disposal of radioactive waste are to complete and return the Pollution Inventory reporting form on an annual basis. Forms will be supplied directly by the Environment Agency. Copies of the returns are to be retained as they will be required from time to time for incorporation into MOD statistics on radioactive waste disposal. Inspections by the environmental regulatory authorities 40 The environmental regulatory authorities are authorised to inspect those units and establishments with Notifications. Commanding Officers or Heads of Establishments will be provided with at least 48 hours notice of an inspection. The visiting inspectors are to be given the fullest co-operation at all times. The Commanding Officer or Head of Establishment is normally to inform appropriate TLB Safety Authority (e.g. the CESO) and the RPA prior to such visits taking place. The CO/HE should inform DS&C (OHS and RP) and their CESO of the outcome of any EA inspection. 41 Inspectors are not normally authorised to have access to classified information and must not be afforded such access unless they are known to have the appropriate security clearance. Inspectors must not, under any circumstances, be made aware of the presence of nuclear weapons or their components during a site inspection. In cases of doubt the regulatory authority shall be denied access and guidance sought, in the first instance, from DS&C (OHS and RP). Ships and overseas establishments 42 Notifications and Approval documents are not required for radioactive material held by HM Ships (other than shore establishments) or overseas Service units and establishments. However, in order to ensure that a complete database of radioactive material is maintained at Dstl ESD, action is to be taken in accordance with paragraphs 31.1 to 31.7. Breaches of arrangement to hold/dispose of radioactive substances 43 Units or establishments that, as a result of an inspection by environmental regulatory authorities, are informed that radioactive substances are being held in excess of quantities described in their Notification, or that radioactive substances have not been disposed of in accordance with their Approval, are to report such incidents through the accident and incident reporting systems within TLBs business processes. Further information and points of contact can be found at http://defenceintranet.diiweb.r.mil.uk/DefenceIntranet/PeopleServices/HealthWellBeingAndSickness/Rep ortingWorkRelatedAccidents/ For those not having access to the intranet they should contact the Chief Environment and Safety Officer within their TLB.

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44 Any MOD unit transferred to the private sector thus becoming a commercial company is no longer exempt from the requirements of the Radioactive Substances Act 1993 and will need to formally register, with the environmental regulatory authorities, its premises in respect of keeping and use of radioactive material and the accumulation and disposal of radioactive waste. Prior to transfer of assets the unit is to notify Dstl ESD of the transfer of radioactive material and waste. The unit is to produce a muster record and preserve it for the period stated above unless an alternative period is specified in the registration document. 45 Disposal of radioactive material is addressed in Leaflets 11 and 12.

High Activity Sealed Radioactive Sources and Orphan Source Regulations 2005 (HASS) 46 High activity sealed sources (see Annex J) became subject to special authorisation, control and transfer procedures from 31 December 2005 for new sources and from 31 December 2007 for those which were first marketed in 2005 or earlier. In addition to the MOD accounting arrangements set out in Leaflet 9, high activity sealed sources are to be accounted for on a HASS Record Form. The form is to be obtained from the relevant environment agency, and once completed, should be forwarded to Dstl ESD as well as the agency. HASS are to be identified separately on the Annual Holdings Return as advised by Dstl ESD. RPA advice must be sought before acquiring a high activity sealed source. 47 Other than for MODs nuclear authorised sites arrangements for notification of the environment agencies described under RSA93 above have been extended to encompass the additional requirements for HASS. The main features which extend or differ from the RSA93 parallel arrangements are: 47.1 An application for a HASS Notification is to be made by the prospective holder direct to the relevant environment agency. The application must include the documentary evidence required by the relevant environment agency. The practice or task for which the HASS will be used shall not commence until the Notification has been certified by the relevant environment agency. 47.2 The certificate of notification, when received, will be accompanied by a set of terms and conditions including the requirement to forward certain records to the relevant agency. Compliance with these terms and conditions is mandatory under the parallel arrangements. 47.3 Arrangements for the physical security of HASS are, so far as reasonably practicable, to parallel those in place on civil sites. Advice on physical security is to be sought from MOD CTSAs through the Principal Security Adviser of the TLB concerned. 47.4 For existing HASS (i.e. those placed on the market before 31 December 2005), transitional arrangements applied until 31 December 2007. 48 Arrangements for the control of HASS held by MOD nuclear authorisees mirror those applicable to civil nuclear licensees. The arrangements are administered by the Defence Nuclear Safety Regulator (DNSR). These arrangements do not extend to mobile HASS held by authorisees or to HASS held beyond the nuclear authorised site boundary in these cases, the normal parallel arrangements pertaining to non-nuclear sites apply. Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) Reporting of Hazard Assessment and Risk Evaluation Documents to HSE 49 The Commanding Officer of any establishment on whose premises quantities of radioactive materials in excess of the values contained in Annex F, or carrier transporting radioactive substances in excess of the quantities given in Annex F, is to make or ensure that a Hazard Identification and Risk Evaluation (HIRE) assessment has been made and a report produced. This will normally be made in collaboration with the RPA and will affect very few units and establishments. The assessment is to demonstrate that all hazards arising from the work with the potential to cause a radiation accident have been identified and the nature and the magnitude of risks to employees and other persons arising from those hazards have been evaluated. Where the assessment shows that a radiation risk to employees or others exists from an identifiable radiation accident, the operator or carrier is to take all reasonably

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practicable steps to prevent such an accident and to limit the consequences of any such accident that could occur. 50 Reports of a HIRE are to be sent direct to HSE but guidance and direction can be obtained by contacting the RPA. The information required by REPPIR is given in Annex G. A copy of the final report is to be provided to DS&C (OHS and RP), except in the cases for HIRE assessments made for the Naval Nuclear Propulsion Programme where the Defence Nuclear Safety Regulator (DNSR) is to be provided with the final report and a further copy sent to DS&C (OHS and RP). For new operators a HIRE assessment report is to be forwarded to the HSE at least 12 months before commencement of work and for transport operations the carrier is to send the report to HSE at least 28 days before commencement of the activity. The requirement for a HIRE assessment does not apply to foreign nuclear powered warships due the exemption issued by the Secretary of State. There is no requirement under the current regulations, for HIRE assessment reports to be submitted to Government Departments in Gibraltar. 51 HIRE assessments are to be reviewed where there is a material change in the work with ionising radiations and within 3 years of the date of the last assessment. This will either be a further assessment or where there are no changes to the last assessment the Commanding Officer, or the carrier, shall sign a declaration to that effect. A report of the assessment or declaration is to be made to the HSE within 28 days of the assessment or declaration being made. 52 Other actions may be required arising from the requirements of REPPIR. They include, making the HIRE report publicly available, the preparation of an operators emergency plan, use of emergency exposures, supply of sufficient information to local authorities to enable them to develop an offsite plan, the testing of exercising of plans at regular intervals and provision of prior information for members of the public that may receive a whole body dose of 5 mSv in a year following the radiation emergency (see Annex H). Units and establishments within the NNPP and NW programmes are developing their own arrangements. Advice on REPPIR issues for these units and establishments is to be sought from the authority given in paragraph 48 and DS&C AD NAR. All other establishments and units, to whom REPPIR is applicable, must seek advice from their RPA. 53 The overall arrangements for the provision of information to the HSE are given in the General Agreement between MOD and HSE (see JSP 375). Where applicable, a copy of the REPPIR HIRE assessment and the operators emergency plan is to be sent to the HSE. Where there are issues of industrial, commercial or personal confidentiality, public security or national defence or other concerns, the unit or establishment is to discuss the matter with DS&C who will consult with the relevant MOD authorities. In most circumstances special arrangements to enable appropriate HSE inspectors to examine classified information can be made. Medicines (Administration of Radioactive Substances) Regulations 1978 as amended (1995) 54 This section applies only if it is intended to administer radioactive substances to persons for research purposes. 55 Only doctors and dentists who have a valid certificate issued by the Administration of Radioactive Substances Advisory Committee (ARSAC) shall administer radioactive substances to patients for research or to other persons such as volunteers for research projects. The necessary application forms, together with the subject Notes of Guidance can be obtained from: ARSAC Support Unit Health Protection Agency Centre for Radiation, Chemical and Environmental Hazards Radiation Protection Division Chilton Didcot Oxon 0X11 0RQ Tel: 01235 832421/834925 Fax: 01235 834925

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56 The relevant legislation is contained in the Medicines (Administration of Radioactive Substances) Regulations 1978 amended by the Medicines (Administration of Radioactive Substances) (Amendment) Regulations 1995. 57 All applications and subsequent certifications are to be notified to Dstl ESD Alverstoke through the appropriate Agency or single-Service Medical Directorate. 58 In addition to specific ARSAC certification requirements, any proposal for radioactive substances to be administered to volunteers for research purposes, or any other irradiation of patients or other persons for research, requires appropriate Agency or single-Service medical and ethical clearance. This clearance must be sought from: DMETA and DDA: The Surgeon General, who will co-opt, or direct the formation of, an ethical committee appropriate to the purpose. For research in MOD Hospital Units (MDHUs), both Surgeon Generals and local NHS approval will be required. The Clinical Research Sub-Committee through the Medical Officer-inCharge, Institute of Naval Medicine. Defence Medical Research Approval Committee, Royal Defence Medical College, Fort Blockhouse, Gosport. The RAF Clinical Research Committee through the appropriate Adviser and Director of Primary Health Services (DPHS). Established Research Medical Ethical Committee as appropriate.

Navy:

Army:

RAF:

Dstl: RECORDS

59 Any records generated shall be retained in accordance with MOD record retention policy (see JSP392 Volume 1, Chapter 11).

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RELATED LEAFLETS 60 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 1 2 4 9 11 12 14 16 17 18 19 21 22 Leaflet Title

Procurement of sources of ionising radiation Risk Assessments Restriction of exposure to radiation Storage and accounting for radioactive materials Sale of radioactive and contaminated goods Accumulation and disposal of radioactive waste Investigation, notification and reporting of unusual radiation events Local orders for radiation safety Radioactive electronic valves Smoke detectors containing Am-241 Gaseous tritium light sources and devices Instrument check sources Radioactive luminised equipment

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LEAFLET 3 ANNEX A PRIOR AUTHORISATION FOR THE USE OF ELECTRICAL EQUIPMENT INTENDED TO PRODUCE X-RAYS IONISING RADIATIONS REGULATIONS 1999 Prior authorisation for the use of electrical equipment intended to produce X-rays 1 For the purposes of Regulation 5(2) of the Ionising Radiations Regulations 1999, the Health and Safety Executive (HSE) hereby authorises the type of practice referred to in paragraph 3 subject to any such practice being carried out in accordance with the conditions hereby approved by HSE as set out in paragraph 4. 2 Notwithstanding the prior authorisation given in paragraph 1, radiation employers must comply with all other relevant requirements of these Regulations, including notifying HSE of their intention to work with radiation in accordance with Regulation 6. 3 The type of practice referred to in paragraph 1 is:

The use of electrical equipment intended to produce X-rays ("X-ray sets") for: industrial radiography; processing of products; research; or exposure of persons for medical treatment. 4 The conditions referred to in paragraph 1 are as follows. The radiation employer shall: 4.1 As part of satisfying the general requirement in Regulation 8 of the Ionising Radiations Regulations 1999 to keep exposure as low as reasonably practicable, take specific steps before starting the work to provide engineering controls, design features, safety devices and warning devices which include at least the following: (a) Where the work is to be carried out in a room, purpose made structure, other enclosure or a cabinet: (i) Adequate shielding as far as reasonably practicable; and

(ii) Except in the use of X-ray sets for radiotherapy at or below 50kV, interlocks or trapped key systems or other appropriate safety devices in order to prevent access to high dose rate areas (e.g. in which employed persons could receive an effective dose greater than 20 mSv or an equivalent dose in excess of a dose limit within several minutes when radiation emission is underway). The control system for such safety devices should comply with paragraphs 4.4 or 4.5. (b) In other cases, adequate local shielding as far as reasonably practicable and, in the case of site radiography, a suitable system for ensuring that: (i) Persons other than those directly involved in the exposure are excluded from the area by means of a barrier or other suitable means. (ii) Where employees of another employer may be present in the same workplace, there is co-operation and co-ordination with the other employer(s) for the purposes of restricting access to the controlled area. (iii) Warning notices displayed at the perimeter of the controlled area; and

(iv) Monitoring of radiation levels to establish that controlled areas have been properly designated;

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(c) Where there is a risk of significant exposure arising from unauthorised or malicious operation, equipment which has been fitted with locking-off arrangements to prevent its uncontrolled use. (d) Initiation of exposures under key control, or some equally effective means, so as to prevent unintended or accidental emission of a radiation beam; and (e) Suitable warning devices which indicate when the tube is in a state of readiness to emit radiation and, except for diagnostic radiology equipment, give a signal when the useful beam is about to be emitted and a distinguishable signal when the emission is underway, unless this is impracticable. 4.2 Arrange for adequate and suitable personal protective equipment to be provided where appropriate. 4.3 Arrange for suitable maintenance and testing schedules for the control measures selected; and 4.4 Provide safety devices, as referred to in 4.1.1, which for routine operations should be configured so that the control system will ensure that an exposure: (a) Cannot commence while any relevant access door, access hatch, cover or appropriate barrier is open, or safety device is triggered. (b) Is interrupted if the access door, access hatch, cover or barrier is opened; and

(c) Does not re-commence on the mere act of closing a door, access hatch, cover or barrier; or 4.5 For non-routine operations such as setting up or aligning equipment, where the safeguards for routine operation are not in use, provide a procedure for an alternative method of working that affords equivalent protection from the risk of exposure which should be documented and incorporated into the local rules. Signed Dated Margaret Clare 6 March 2000 A person approved by the Health and Safety Executive to perform the functions under regulation 6(2) of the Ionising Radiations Regulations 1999. NOTES (1) Work referred to in paragraph 3 when carried out in accordance with the conditions in paragraph 4 is not subject to the requirement for individual prior authorisation pursuant to Regulation 5(1) of the Ionising Radiations Regulations 1999. (2) This authorisation is without prejudice to the requirements or prohibitions imposed by any other enactment, in particular, the Health and Safety at Work etc. Act 1974 and the Ionising Radiations Regulations 1999, and to the provisions of the Approved Code of Practice on the Ionising Radiations Regulations 1999.

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LEAFLET 3 ANNEX B PRIOR AUTHORISATION FOR THE USE OF ACCELERATORS (OTHER THAN ELECTRON MICROSCOPES) IONISING RADIATIONS REGULATIONS 1999 Prior authorisation for the use of accelerators (other than electron microscopes) 1 For the purposes of Regulation 5(2) of the Ionising Radiations Regulations 1999, the Health and Safety Executive (HSE) hereby authorises the type of practice referred to in paragraph 3 subject to any such practice being carried out in accordance with the conditions hereby approved by HSE as set out in paragraph 4. 2 Notwithstanding the prior authorisation given in paragraph 1, radiation employers must comply with all other relevant requirements of these Regulations, including notifying HSE of their intention to work with radiation in accordance with Regulation 6. 3 The type of practice referred to in paragraph 1 is:

The use of accelerators (other than electron microscopes). NOTE The scope covers all uses of accelerators (other than electron microscopes), including medical and veterinary purposes (an accelerator is an apparatus or installation in which particles are accelerated and which emits ionising radiation with an energy higher than 1 MeV). 4 The conditions referred to in paragraph 1 are as follows. The radiation employer shall: 4.1 As part of satisfying the general requirement in Regulation 8 of the Ionising Radiations Regulations 1999 to keep exposure as low as reasonably practicable, take specific steps before starting the work to provide engineering controls, design features, safety devices and warning devices which include at least the following: (a) Where the work is to be carried out in a room, purpose made structure, other enclosure or a cabinet: (i) Adequate shielding as far as reasonably practicable; and

(ii) Interlocks or trapped key systems or other appropriate safety devices in order to prevent access to high dose rate areas (e.g. in which employed persons could receive an effective dose greater than 20 mSv or an equivalent dose in excess of a dose limit within several minutes when radiation emission is underway). The control system for such safety devices should comply with paragraph 4.4. (b) In other cases, adequate local shielding as far as reasonably practicable and, in the case of site radiography, a suitable system for ensuring that: (i) Persons other than those directly involved in the exposure are excluded from the area by means of a barrier or other suitable means. (ii) Where employees of another employer may be present in the same workplace, there is co-operation and co-ordination with the other employer(s) for the purposes of restricting access to the controlled area. (iii) Warning notices are displayed at the perimeter of the controlled area; and

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(iv) Radiation levels are monitored to establish that controlled areas have been properly designated. (c) Suitable means to minimise exposure so far as is reasonably practicable from substances that have been activated by the accelerator. (d) A suitable assessment of the hazards arising from the production of adventitious radiation. (e) Where there is a risk of significant exposure arising from unauthorised or malicious operation, equipment which has been fitted with locking-off arrangements to prevent its uncontrolled use. (f) Initiation of exposures under key control, or some equally effective means, so as to prevent unintended or accidental emission of a radiation beam; and (g) Suitable warning devices which indicate when the accelerator is preparing to produce radiation and give a signal when the radiation is about to be produced and a distinguishable signal when the emission is underway, unless this is impracticable. 4.2 Arrange for adequate and suitable personal protective equipment to be provided where appropriate. 4.3 Arrange for suitable maintenance and testing schedules for the control measures selected; and 4.4 Provide safety devices, as referred to in 4.1.1, which should be configured so that the control system will ensure that an exposure: (a) Cannot commence while any relevant access door, access hatch, cover or appropriate barrier is open, or safety device is triggered. (b) Is interrupted if the access door, access hatch, cover or barrier is opened; and

(c) Does not re-commence on the mere act of closing a door, access hatch, cover or barrier Signed Dated Margaret Clare 6 March 2000 A person approved by the Health and Safety Executive to perform the functions under regulation 6(2) of the Ionising Radiations Regulations 1999. NOTES (1) Work referred to in paragraph 3 when carried out in accordance with the conditions in paragraph 4 is not subject to the requirement for individual prior authorisation pursuant to regulation 5(1) of the Ionising Radiations Regulations 1999. (2) This authorisation is without prejudice to the requirements or prohibitions imposed by any other enactment, in particular, the Health and Safety at Work etc. Act 1974 and the Ionising Radiations Regulations 1999, and to the provisions of the Approved Code of Practice supporting the Ionising Radiations Regulations 1999. (3) Electron microscopes are not covered by the authorisation as they do not need to be authorised under the Ionising Radiations Regulations 1999.

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LEAFLET 3 ANNEX C PARTICULARS TO BE PROVIDED TO THE HSE IN A NOTIFICATION UNDER REGULATION 6(2).

The following particulars are to be notified to the local Health and Safety Executive (HSE) office: 1.1 The name and address of the employer (e.g. CO, Head of Establishment) and a contact telephone, fax or e-mail address. 1.2 The address of the unit or establishment at which the work activity is to be carried out and a telephone, fax or e-mail address, at the premises. 1.3 1.4 The nature of the business of the employer. The category of the source of ionising radiation: 1.4.1 1.4.2 1.4.3 1.4.4 Sealed source. Unsealed radioactive substance. Electrical equipment (including X-ray equipment). An atmosphere containing the short-lived daughters of radon-222.

1.5 Whether or not the source is to be used at premises other than the address given in paragraph 1.1. 1.6 Dates of notification and commencement of the work activity.

2 The nature of the business of the employer shall contain the standard wording Defence of the United Kingdom, Overseas territories, our people and interests. 3 Should the HSE request additional information, then the TLB Safety Authority is to be informed and advice sought on the supply of further information, including from the RPA if appropriate.

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LEAFLET 3 ANNEX D EXEMPTION FROM NOTIFICATION TO HSE CONTENTS Table Page

D 1 Summary of quantity for notification of selected isotopes ...................................................................2 1 Units and establishments are exempt from notification to the Health and Safety Executive (HSE) where the only work with ionising radiation that is being carried out by the unit or establishment is in one or more of the following categories 1.1 Where the quantity of a radioactive substance does not exceed the concentration specified in column 2 of Schedule 8 of the Ionising Radiations Regulations 1999; 1.2 Where the quantity of radioactive substance involved does not exceed that specified in column 3 of Schedule 8 of the Ionising Radiations Regulations 1999; 1.3 Where apparatus contains a radioactive substance in a quantity exceeding the values in paragraphs 1.1 and 1.2 provided that it 1.3.1 1.3.2 Is a type approved by the HSE; Is constructed in the form of a sealed source;

1.3.3 Does not give rise to dose rates above 1 Sv h-1 at 0.1 metre from any accessible surface; and 1.3.4 Has disposal arrangements agreed with the appropriate environment agency;

1.4 Operation of electrical apparatus of a type already approved by the HSE and where the dose rate at 0.1 m from any accessible surface is less than 1 Sv h-1; 1.5 Operation of any cathode ray tube intended for the display of visual images or any other electrical apparatus operating at less than 30 kV, provided the maximum dose rate under normal operating conditions is less than 1 Sv h-1 at 0.1 m from any accessible surface; 1.6 Where the work involves material contaminated with radioactive substances resulting from authorised releases which the appropriate environment agency has declared not to be subject to further controls.

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A summary of common radionuclides used by MOD is given in Table 1 below. Table D 1 Summary of quantity for notification of selected isotopes Radionuclide Tritium (Hydrogen 3) Carbon 14 Chlorine 36 Cobalt 60 Nickel 63 Krypton-85 Strontium 90 Caesium-137 Promethium 147 Thallium 204 Radium 226 Plutonium 239 Americium-241 Concentration for Notification (Bq/g) 1x106 1x104 1x104 1x101 1x105 1x105 1x103 1x101 1x102 1x104 1x101 1x100 1x100 Quantity for Notification (Bq) 1x109 1x107 1x106 1x105 1x108 1x104 1x104 1x104 1x107 1x104 1x104 1x104 1x104

For radionuclides not specified refer to the Ionising Radiations Regulations, Schedule 8

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LEAFLET 3 ANNEX E HSE NOTIFICATION OF WORK WITH IONISING RADIATIONS

NOTIFICATION OF WORK WITH IONISING RADIATIONS To: Health and Safety Executive [ insert address]

a.

Unit name and address:

Telephone number: e-mail address (if applicable): b. Address of premises where the work is undertaken:

Fax number:

Telephone number: e-mail address (if applicable): c Nature of the business of the employer:

Fax number:

Defence of the United Kingdom, overseas territories, our people and interests. d. Categories of ionising radiation: (Tick boxes as appropriate) Sealed source(s) Unsealed radioactive substance Electrical equipment Atmosphere containing radon e. Is any source used at premises other than those given above? * Delete as appropriate f. Date of commencement of work: Name: Date of notification: Signature: Rank: Yes/No*

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LEAFLET 3 ANNEX F QUANTITIES OF RADIOACTIVE SUBSTANCES REQUIRING HAZARD IDENTIFICATION AND RISK EVALUATION CONTENTS Table Page

F 1 Quantities of radioactive material requiring a REPPIR assessment....................................................2 1 All quantities of radioactive materials exceeding the values in paragraphs 2 and 3 below will require hazard identification and risk assessment unless it is: 1.1 A non-dispersible source except for the transport of such a source.

1.2 Any radioactive substance which has an activity concentration of not more than 100Bqg-1 except for the transport of such a source. 1.3 Any special form radioactive substance.

1.4 Any radioactive substance, which is in a package which complies in every respect with either the requirements for Type B packages, or for Special Arrangements Transport Operations for the equivalent of a Type B package, within the meaning of the Regulations for the Safe Transport of Radioactive Materials published by the International Atomic Energy Agency as revised or reissued from time to time and is certified as complying with them. 1.5 The transport of any radioactive substance in the form of a low specific activity material conforming to the specifications for low specific activity materials (LSA) categories LSA-I, LSA-II or LSA-III within the meaning of the regulations in d above where the transport forms part of an international transport operation. 1.6 The transport of any radioactive substance in the form of a surface contaminated object (SCO) conforming to the specifications for SCO-I or SCO-II within the meaning of the regulations in d above where the transport forms part of an international transport operation. 1.7 The presence of a radioactive substance while it is in or on the live body or corpse of a human being or animal where that presence occurs otherwise than in consequence of a radiation emergency. 2 Specified masses of fissile material requiring a hazard identification and risk evaluation are: 2.1 Plutonium as Pu-239 or Pu-241 or as a mixture of plutonium isotopes containing Pu-239 or Pu-241, 150 grams. 2.2 2.3 2.4 Uranium as U-233, 150 grams. Uranium enriched in U-235 to no more than 1% but not more than 5%, 500 grams. Uranium enriched in U-235 to more than 5%, 250 grams.

3 Quantities of radioactive material that will require a hazard identification and risk evaluation are given in Table 1. Where more than one radionuclide is present, the fraction of the REPPIR limit must be determined for each radionuclide and if the sum of the fractions exceeds one, then a REPPIR assessment will still be required.

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Table F 1 Quantities of radioactive material requiring a REPPIR assessment (1) Radionuclide Tritium (H-3) tritiated water Tritium gas Tritium organically bound Carbon (C-14) vapour Carbon (C-14) monoxide gas Carbon (C-14) dioxide gas Manganese (Mn-54) Iron (Fe-55) Cobalt (Co-60) Nickel (Ni-63) Krypton (Kr-85) Strontium (Sr-90) Technetium (Tc-99m) Caesium(Cs-137) Iridium (Ir-192) Radium (Ra-226) Natural Thorium (Th-232) + daughters Uranium (U-238) Uranium (U-235) Plutonium (Pu-239) Americium (Am-241) Californium (Cf-252) (2) Site Total Activity Bq 7 1013 1 1018 1 1014 4 1013 1 1016 3 10 15 3 1011 8 1012 6 1010 1 1013 1 1016 8 1010 1 1013 1 1011 6 1011 2 109 2 108 3 109 3 10
9

(3) Transport operation Total Activity Bq 4 1013 4 1013 4 1013 3 1012 3 1012 3 1012 1 1012 4 1013 4 1011 3 1013 1 1013 3 1011 4 1012 6 1011 6 1011 3 109 Unlimited Unlimited Unlimited 1 109 1 109 3 109

2 108 3 108 1 109

For radionuclides not specified refer to Schedule 2 (site) or Schedule 4 (transport) of REPPIR2000. further advice can be sought from the RPA.

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LEAFLET 3 ANNEX G PARTICULARS TO BE INCLUDED IN A REPPIR HIRE ASSESSMENT REPORT

1 The following particulars are to be included in a REPPIR Hazard Identification and Risk Evaluation assessment (HIRE) report: 1.1 Name and address of the operator or carrier.

1.2 The postal address of the place where the radioactive substance will be processed, manufactured, used or stored, or where the facilities for processing, manufacture, use or storage exist or, in the case of transport, the postal address of the transport undertaking. 1.3 The date on which it is anticipated that the operation will commence or, if it has already commenced, a statement to that effect. 1.4 A general description of the premises or place including the geographical location, metrological, geological, hydrographic conditions and, where material, the history of the premises, except that in the case of transport a general description shall be given of either: 1.4.1 The starting and end points of the journeys, the mode of transport and transhipment points, or 1.4.2 The criteria to be used for route selection.

1.5 In the case of an assessment by an operator, a description of any radioactive substance on the premises which is likely to exceed any mass specified in Annex F or any quantity in column 2 of Table 1, which description shall where practicable include details of the radionuclides present and their likely maximum quantities. 1.6 In the case of an assessment by a carrier, a description of any radioactive substance which is likely to exceed any mass specified in Annex F or any quantity in column 3 of Table 1, which description shall where practicable include details of the radionuclides present and their likely maximum quantities.

1.7

Except in the case of an assessment relating to transport, a plan of the site in question and a map of the environs to a scale large enough to enable the site and any features which could affect the general risk in an emergency to be identified.

1.8 A diagram and description of any single plant or enclosed system containing more than the quantity of any mass specified in Annex F or any quantity in column 2 of Table 1 or, in the case of transport any mass specified in Annex F or any quantity in column 3 of Table 1, the nature of the containment for the radioactive substance, the type of vehicle and the means of securing the load within or on the vehicle. 1.9 Factors which could precipitate a major release of any radioactive substance and the measures to be taken to prevent or control such release and information showing the maximum quantity of radioactive substance which, in the event of a major failure of containment, would be released to the atmosphere including, in respect of premises, the identification of plant and other activities anywhere on the premises which could precipitate such release. 1.10 Factors which could precipitate a smaller but continuing release of any radioactive substance and the measures to be taken to prevent or control such releases to atmosphere. 1.11 Factors that could give rise to an incident involving the initiation of an unintended selfsustaining nuclear chain reaction or the loss of control of an intended self-sustaining nuclear chain reaction and, in either case, the measures to be taken to prevent or control any such incident.

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1.12 The management system and staffing arrangements by which the radioactive substance is controlled and by which the procedures are controlled. 1.13 Except in the case of an assessment relating to transport, information about the size and distribution of the population in the vicinity of premises to which the report relates. 1.14 An assessment of the area which is likely to be affected by the dispersal of any radioactive substance as a result of any radiation emergency and the period of time over which such dispersal is likely to take place. 1.15 An assessment of the likely exposures to ionising radiation of any person or class of persons as a result of any radiation emergency; and 1.16 An assessment of the necessity for an emergency plan to be prepared by the operator or carrier. 2 The Health and Safety Executive may request a further assessment and report containing the following: 2.1 The analysis carried out to establish the likely consequences of any hazard, including the likely doses of ionising radiation to which members of the public might be exposed, and the probability of the occurrence of such a hazard. 2.2 The number of persons whose health or safety might be affected by the hazard.

2.3 Management systems and staffing arrangements by which any hazard is to be or is controlled. 2.4 The safety systems and procedures and monitoring systems by which any hazard is to be or is controlled. 2.5 The qualifications, experience and training of staff concerned.

2.6 Design, construction, operation or maintenance of any equipment (including the incorporation of adequate safety or reliability features of such equipment) which is used for the purposes of intervention or which is used to control any hazard. 2.7 2.8 2.9 2.10 Design and operating documentation. The design and operation of containment and pressure systems. The protection of persons from the effects of loss of containment; and The procedures for reporting of and learning from radiation emergencies.

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LEAFLET 3 ANNEX H PRIOR INFORMATION TO BE SUPPLIED AND MADE PUBLICLY AVAILABLE

Basic facts about radioactivity and its effects on persons and on the environment.

2 The various types of radiation emergency covered and their consequences for the general public and the environment. 3 Emergency measures envisaged to alert, protect and assist the general public in the event of a radiation emergency. 4 Appropriate information on action to be taken by the general public in the event of a radiation emergency. 5 The authority or authorities responsible for implementing the emergency measures and action referred to in paragraphs 3 and 4 above.

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LEAFLET 3 ANNEX I EXEMPTION FROM NOTIFICATION UNDER THE RADIOACTIVE SUBSTANCES ACT 1993 CONTENTS Para 1 2 3 4 6 7 8 9 Table EXEMPTION FROM NOTIFICATION UNDER THE RADIOACTIVE SUBSTANCES ACT 1993 Smoke detectors Sealed sources for testing or measuring instruments Electronic valves Luminous equipment Luminous components Sources at exhibitions Gaseous tritium light sources Page

I 1 Activity limits - luminised components .................................................................................................2 I 2 Current exemption orders ....................................................................................................................4 EXEMPTION FROM NOTIFICATION UNDER THE RADIOACTIVE SUBSTANCES ACT 1993 1 The following list details the most common items within the MOD which do not require Notification under the Radioactive Substances Act 1993. Although Notification is not required, the general conditions in Annex D must still be complied with. Further exemptions from Notification exist for other materials and the requirements and implementation for these and those listed below are to be discussed with the appointed RPA. Smoke Detectors 2 Smoke detectors each containing less than 2.2 MBq of americium-241 that are installed in a unit or establishment. Smoke detectors that contain less than 40 kBq of americium-241, which are not installed and do not exceed 500 in total (see Leaflet 18). 3 Smoke detectors each containing less than 4 MBq of any radionuclide (other than americium-241) that are installed in a unit or establishment. RPA consultation advised. Sealed sources for testing or measuring instruments (see Leaflet 21) 4 One or more radioactive sources contained in testing or measuring instruments or loose sources used for instrument testing or calibration whose total maximum activities do not exceed the following: 4.1 4.2 4.3 4.4 4.5 Homogeneous sources Laminated sources and sealed sources Electrodeposited source containing iron-55 Electrodeposited source containing nickel-63 Tritium foil source NOTE * Items require registration when deployed as mobile radioactive apparatus. 400 kBq 4 MBq 200 MBq* 600 MBq* 20 GBq*

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Electronic valves (see Leaflet 17) 5 6 Class 1 radioactive valves. Class 2 radioactive valves subject to the conditions: 6.1 Not more than 10 loose radioactive valves (i.e. those not contained in equipments) are held at the unit or establishment. 6.2 The activity in each valve does not exceed the following values: Caesium-137 Cobalt-60 Nickel-63 Thallium Thorium Radium-226 37 kBq 37 kBq 37 kBq 37 kBq 37 kBq 37 kBq Uranium Carbon-14 Chlorine-36 Promethium-147 Krypton-85 Tritium (H-3) 37 kBq 370 kBq 370 kBq 1110 kBq 3700 kBq 5550 kBq

6.3 When not in use the valve is to be kept in a container legibly marked 'Radioactive Electronic Valve.' 6.4 Details and descriptions of Class 1 and 2 valves are given in Leaflet 17.

Luminous equipment (see Leaflet 22) 7 Luminous equipments (i.e. those luminised with paint), instruments and signs containing not more than 80 MBq of promethium or 4 GBq of tritium luminising compound in each which is covered by glass or some other protective covering. Luminous components (see Leaflet 22) 8 Luminous components (i.e. those luminised with paint) such as a component of a clock, watch, instrument or sign in which the aggregate activity of radionuclides does not exceed the values in Table 1 and whose individual activities do not exceed 80 MBq of promethium or 4 GBq of tritium. The exception is subject to the keeping of all luminous components in a container indelibly marked 'Radioactive Luminous Components' except when removed for testing, inspection or incorporation into another article. Table I 1 Activity limits - luminised components Maximum activity of all Components at an establishment 4 GBq 200 GBq

Radionuclide Promethium-147 Tritium (H-3) NOTE

Guidance on which radionuclide is in a particular component and/or its activity can be obtained from the RPA Sources at exhibitions 9 Radioactive sources used or displayed at exhibition to which the public or other persons are admitted subject to the following: 9.1 The total activity of all radionuclides in all sources does not exceed 37 MBq.

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9.2

Only sealed sources are present.

Gaseous tritium light sources (see Leaflet 19) 10 All articles are exempt from notification under the Radioactive Substances Act 1993 provided that they meet one of the following criteria. 10.1 The tritium activity does not exceed 20 GBq per item and no more than 5 TBq are held on any one premises. 10.2 It is an article containing GTLS which is installed or awaiting installation in a vessel aircraft, vehicle or equipment used or intended for use by the Armed Services. 11 The conditions attached to these exemptions are: 11.1 General conditions for all GTLS. 11.1.1 The activity of tritiated compounds including tritiated water does not exceed 2% of the total activity in a GTLS or for a GTLS containing only 5 GBq the activity of tritium compounds does not exceed 100 MBq. 11.1.2 The articles are kept in packages with markings or labels marked with the word radioactive and the radiation trefoil. 11.1.3 All reasonable steps are taken to prevent them from being lost, damaged or stolen. If suspected of being lost or stolen then reported actions described in Leaflet 14 are to be followed if the activity exceeds 20 GBq. 11.2 For GTLS exceeding 20 GBq covered by paragraph 10.2. 11.2.1 Uninstalled items are not to be stored for more than 1 month. 11.2.2 For articles held for more than 48 hours awaiting installation the local fire brigade is to be informed by telephone immediately and confirmed in writing as soon as possible. 11.2.3 All such articles are marked with the word 'radioactive' the trefoil, the total activity of the article, the date of receipt and method of disposal. 11.2.4 An entry is made on a Radioactive Source List for each article. 12 Advice regarding the application of the information above can be obtained from the RPA.

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CURRENT EXEMPTION ORDERS OF INTEREST TO MOD 13 The exemption orders shown in Table 2 remain current. Advice is to be sought from the RPA on application of these exemption orders. Table I 2 Current exemption orders Title The Radioactive Substances (Smoke Detectors) Exemption Order (as amended 1991) 1980 The Radioactive Substances (Electronic Valves) Exemption Order 1967 The Radioactive Substances (Luminous Articles) Exemption Order 1985 The Radioactive Substance (Testing Instruments) Exemption Order 2006 The Radioactive Substances (Waste Closed Sources) Exemption Order 1963 The Radioactive Substance (Prepared Uranium and Thorium Compounds) Exemption Order 1962 The Radioactive Substance (Hospitals) Exemption Order 1990 The Radioactive Substance (Gaseous Tritium Light Devices) Exemption Order 1985 The Radioactive Substance (Substances of Low Activity) Exemption Order (as amended 1992) 1986 The Radioactive Substances (Uranium and Thorium) Exemption Order 1962 The Radioactive Substances (Phosphatic Substances, Rare Earths, etc) Exemption Order 1962 The Radioactive Substances (Schools etc) Exemption Order 1963 The Radioactive Substances (Exhibitions) Exemption Order 1962 NOTE The above Exemption Orders apply to England and Wales. The corresponding Exemption Orders for Scotland and Northern Ireland have identical or similar wording, but carry different Statutory Instrument numbers Statutory Instrument 1980 No. 953 1991 No. 477 1967 No. 1797 1985 No. 1048 2006 No. 1500 1963 No. 1831 1962 No. 2711 1990 No. 2512 1985 No. 1047 1986 No. 1002 1992 No. 647 1962 No. 2710 1962 No. 2648 1963 No. 1832 1962 No. 2648

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LEAFLET 3 ANNEX J CONTROL OF HIGH ACTIVITY SEALED SOURCES (HASS)

1 Council Directive 2003/122/Euratom of 22 Dec 2003 requires Member States to put in place legislation on the control of high-activity sealed radioactive sources and orphan sources. Transposition to UK legislation took place via the HASS regulations during 2005. Since the Directive was made under the EURATOM Treaty, the legislation will not apply directly to MOD. However, MOD will put in place parallel arrangements in accordance with Secretary of States Policy statement. 2 High Activity Sealed Source means a sealed source containing a radionuclide whose activity at the time of manufacture is equal to or exceeds the activity levels specified in EC Directive 2003/122/Euratom ie that the activity equals or exceeds 0.01 of the corresponding A1 value given in the IAEA Regulations for the safe transport of radioactive materials. Table 1 gives the activity levels which apply to HASS for selected radionuclides. Gaseous tritium light sources, gaseous tritium light devices, nuclear fuel and radioactive waste are excluded from this definition and will not be treated as high activity sealed sources. Table 1 High activity sealed sources - activity levels for selected radionuclides Radionuclide Iron-55 Cobalt-60 Selenium-75 Krypton-85 Strontium-90 Caesium-137 Promethium-147 Iridium-192 Thallium-204 Radium-226 Americium-241 Californium-252 Activity Level (GBq) 400 4 30 100 3 20 400 10 100 2 100 0.5

3 For radionuclides not shown in Table 1, the relevant activity is one hundredth of the corresponding A1 value given in the IAEA Regulations for the safe transport of radioactive materials. 4 (To be updated following issue of a DIN).

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LEAFLET 4 RESTRICTION OF EXPOSURE TO RADIATION CONTENTS Para 1 2 3 4 5 6 7 8 14 15 18 19 25 26 29 31 33 37 38 39 40 41 42 43 44 49 50 57 59 65 66 Table 1 Annex A B C D E Contamination control guidance Radiological safety warning signs and labels Monitoring of designated and non-designated areas Guidance on personal protective equipment (including respiratory protective equipment) Annual dose limits Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees General approach to restricting exposure Radiation Dose constraints and ALARP investigations Dose constraints Formal ALARP investigations Notification and reporting of investigations Radiation dose limits Designation of controlled or supervised radiation areas Controlled areas Demarcation of controlled areas Access to controlled areas Wearing of dosemeters in controlled areas Permit to work Supervised areas Demarcation of supervised areas Temporary designated areas Pregnant and breastfeeding employees Safety signs Recording of designated areas Monitoring of designated areas Monitoring of non-designated areas Engineering controls, design features, safety features and warning devices Safe systems of work Personal protective equipment (including respiratory protective equipment) Records Related leaflets Page Related Leaflets.............................................................................................................................13

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SCOPE 1 Every radiation employer, in relation to any work with ionising radiation, must take all necessary steps to restrict, to as low as reasonably practicable (ALARP), the extent to which their employees and other persons are exposed to ionising radiation. The measures which contribute to the restriction of exposure are fundamental to radiation protection as is the quality of information and training provided to employees to enable the measures to be effective. Since exposure to radiation will only occur when work with ionising radiation is necessary, it follows that, if the use of radioactive material and ionising radiation can reasonably be avoided, measures to restrict exposure will not be necessary. Similarly, if work can be confined to the use of sealed sources of radioactive material or radiation generators (e.g. Xray sets), the hazards associated with the possible spread of loose radioactive material (i.e. contamination) and the associated contamination control measures can be minimised or avoided altogether. For the purposes of this leaflet, it is assumed that the particular practice using radioactive material or ionising radiation is necessary (i.e. justified). Leaflet 3 gives details of the requirements for justification of practices involving ionising radiation. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety, where the CO takes on the duties of the radiation employer for work with ionising radiation carried out by MOD. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure that: The measures detailed in this leaflet are considered in the context of the work undertaken, taking advice from the RPA as necessary. Measures to be taken to restrict exposure are documented and promulgated. Staff and other persons are provided with appropriate local training and information so that they understand and apply the measures to restrict exposure. Compliance audits are carried out. Ionising Radiations Regulations 1999 (IRR99) (apply directly). Personal Protective Equipment at Work Regulations 1992 (apply directly).

Radiation Protection Supervisor (RPS) 5 Where sites and establishments have controlled areas and, where appropriate having regard to the nature of the work carried out there, supervised areas, an RPS must be appointed for each such designated area (see further details later in this leaflet). The RPS is to ensure that work is carried out in accordance with the specific measures put in place to restrict exposure and in accordance with the general methods used to restrict doses to those which are as low as reasonably practicable (ALARP).

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Workplace Supervisor (WPS) 6 In cases where work with radioactive material is carried out but where the risk assessment shows that designated areas are not required, a WPS is to be appointed with duties to ensure that the work with radioactive material is carried out safely in accordance with the local orders for radiation safety and the measures required to ensure doses are kept ALARP. Employees 7 It is the responsibility of all employees to ensure that they are familiar with the dose restriction and minimisation measures to be taken in the work area and comply with them. Employees must also bring to the attention of the appropriate supervisor or manager any shortcomings in the measures that they identify, regardless of whether they are affected or not. GENERAL APPROACH TO RESTRICTING EXPOSURE 8 In general, the lower the activity of any radioactive sources or the lower the output of a radiation generator, commensurate with the work to be done, the easier it will be to ensure that exposure is adequately restricted. Similarly, where work requires the use of unsealed sources of radioactivity, measures to reduce the quantities routinely handled and to improve the immediate containment will make it easier to restrict exposure to external radiation and to minimise the possibility of internal exposure arising from any spread of contamination. 9 Radiation monitoring data and personal dosimetry data provides a valuable tool for evaluating the success of control measures to restrict exposures it should be possible to review working conditions against this data and to identify individuals whose exposures may not be ALARP because they are higher than those of colleagues doing similar work. 10 Systems of work employers must ensure that working methods, local orders and work instructions take restriction of exposure into account. In the case of work in controlled and supervised areas, local orders must also satisfy additional statutory requirements (see Leaflet 16). 11 Training provision of general and site-specific information and training is a vital component of any arrangements for restriction of exposure. 12 Restriction of external radiation exposure in addition to the general measures outlined above a number of simple methods are to be employed and are to be covered in general radiation protection training and also in site specific briefs to employees as follows: 12.1 12.2 12.3 Minimising the quantity of radioactive material kept in the working area. In the case of X-ray radiography, using the minimum appropriate kV and mA settings. Provision of information e.g. diagrams showing variation of radiation levels in the work area

12.4 Minimising time spent in the vicinity of the source of radiation or in areas where radiation levels are higher. 12.5 12.6 Maximising distance from the source. Use of shielding where reasonably practicable.

12.7 Radioactive materials, including those in the form of sealed sources must not be held or directly manipulated in the hand (or close to the hand) if it is practicable for the task to be completed by other means for example, the use of tongs or tweezers unless the skin of the hand is unlikely to receive a significant dose and the employee is unlikely to become significantly contaminated.

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12.8 Dose sharing is not to be used as a primary means of restricting exposure to individuals. Rather, priority is to be given to improving engineering controls and other means of restricting exposure, including changing the methods of work. 12.9 Employers are to take particular steps to restrict the exposure of any employee who does not normally work with radiation to a (whole body) effective dose of less than 1 mSv per year. Similarly doses to parts of the body are not to exceed the relevant limit for other persons (see Annex E). 13 Restriction of internal radiation exposure (contamination control) is normally only an issue where work with open radioactive sources (including some naturally occurring radioactive material) must take place or where the work has the potential to generate contamination (e.g. machining of materials with radioactive constituents). Also, some work activities may have associated reasonably foreseeable accidents with the potential to lead to damage to sealed radioactive sources and consequent release of contamination in these cases, contingency plans (see Leaflet 40) are to address contamination control. Where work must be carried out with unsealed sources or in contaminated areas, it will be usually necessary for the area to be designated as controlled or supervised (see below). Where contamination is likely to be an issue, radiation employers are to address the following points and promulgate safety instructions and procedures as necessary (detailed guidance is provided at Annex A): 13.1 Consult an RPA as to the requirements for contamination control and the need for area designation. 13.2 Ensure that priority is given to the containment of radioactive substances to prevent dispersal. Where containment is not sufficient to give adequate protection, ventilation is to be provided. 13.3 Ensure that work procedures and containment arrangements are such as to minimise the raising and spread of contamination this must also address cleaning arrangements. 13.4 Ensure that provision is made for the safe decommissioning or dismantling of equipment, in particular internal surfaces that may become contaminated. 13.5 Ensure that local orders are drawn up with reference to the area concerned (see Leaflet 16). 13.6 Ensure that access to contamination areas is appropriately controlled and that such areas are clearly demarcated. 13.7 Ensure that the work conditions of an employee who is breastfeeding are restricted so as to prevent significant bodily contamination in practice, this will usually mean that she is to be excluded from entry to areas where there is a significant presence or risk of contamination. 13.8 Identify and provide appropriate personal protective equipment (including respiratory protective equipment where appropriate). 13.9 Provide and maintain suitable and sufficient washing, monitoring and changing facilities for persons who enter or leave contamination areas 13.10 Provide hygiene rules (no eating drinking, smoking etc) to minimise the possibility of employees being contaminated internally or externally. 13.11 Ensure that contingency plans are drawn up and rehearsed which include plans to deal with the spread of contamination by breakage or spillage, with the removal of personal contamination and with the treatment of cuts or breaks in the skin (see Leaflet 40).

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13.12 Ensure that arrangements for clearance and removal of items from contaminated areas are identified. MOD has adopted a nuclear industry code of practice entitled Clearance and Exemption Principles, Processes and Practices for Use by the Nuclear Industry. The RPA is likely to base their advice on this document. Units and establishments, in consultation with the RPA, are to develop a system of administrative controls and documentation to control the movement of potentially radioactive items or contaminated items. 13.13 Ensure that arrangements for monitoring and exit of personnel from contaminated areas are identified and that advice is taken on the need for any routine sampling (e.g. urine sampling) of employees to be carried out for the purposes of dose assessment. 13.14 Ensure that area monitoring arrangements including measurement and sampling within the area are identified and carried out and that monitoring is conducted outside the area to identify the possibility of any spread of contamination beyond the area concerned. 13.15 Ensure the prompt removal of contamination from personnel who become contaminated.

RADIATION DOSE CONSTRAINTS AND ALARP INVESTIGATIONS Dose constraints. 14 A dose constraint is an upper level of individual dose specified by the employer at the design or planning stage and is a level which ought to be achieved in a well managed practice. For most nonnuclear work in MOD, it will not be necessary to set dose constraints, however, for specific projects such as decommissioning an active area, where exposure may be significant, then RPA advice is to be sought as to a suitable dose constraint to be used. Formal ALARP investigations 15 In order to ensure that dose restriction methods are being effective, there is a statutory requirement for a formal dose level to be set by the employer, which, when exceeded, will trigger a formal investigation. MOD policy requires that a level no higher than 6 mSv in any calendar year be used. The RPA is to be consulted as to the setting of an appropriate investigation level. 16 If the effective dose to any individual exceeds the formal investigation level, a locally conducted investigation is to be carried out on behalf of the CO to determine that all reasonable steps are being taken to minimise radiation exposure and identify any additional measures which should reduce dose. One investigation is normally sufficient where a group of employees has been engaged in similar tasks in the same environment and have each received radiation doses in excess of formal investigation level. Except in the case of an accidental exposure (see below), no reporting action is required external to the unit. This investigation is a statutory requirement (see paragraph 19 below). 17 Once an investigation level has been set and specified in local orders, the investigation, if this level is exceeded, becomes a statutory requirement. Investigation reports are to be retained they may be required as input to further investigations or to demonstrate to HSE that an adequate investigation has been carried out. The procedures for and content of an investigation are covered in Leaflet 14. Notification and reporting of investigations 18 Where a whole body dose resulting from an accident exceeds 6 mSv, there is a requirement for a statutory dose assessment (see Leaflet 6) and a report to MOD authorities (see Leaflet 14).

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RADIATION DOSE LIMITS 19 In addition to the requirements to ensure that radiation exposures from ionising radiation are kept ALARP (by following the instructions and guidance elsewhere in this leaflet and annexes), the employer must also ensure that statutory dose limits are not exceeded. Dose sharing is not to be used as a primary means of keeping exposures below dose limits. However, if a choice has to be made between restricting doses to individuals or groups of persons, priority is always to be given to keeping individual doses as far below dose limits as is reasonably practicable. 20 The statutory annual effective dose limit (sometimes described as the whole body dose limit) from occupational exposure to ionising radiations for an employee of 18 years of age or above is 20 mSv in any calendar year. The total effective dose is the summation of the weighted equivalent dose in all tissues and organs of the body from internal and external radiation. Occupational exposure excludes the dose from any exposure to medical/dental procedures as a patient or from natural background radiations apart from workplace exposure to radon and its daughters. 21 In addition to the effective dose limit, there are separate dose limits to specific parts of the body as follows: 21.1 The equivalent dose received by the hands, forearms, feet and ankles or the skin is not to exceed 500 mSv in any calendar year. 21.2 The dose received by the lens of the eye is not to exceed 150 mSv in any calendar year.

21.3 Women employees of reproductive capacity are subject to an equivalent dose limit to the abdomen of 13 mSv in any consecutive 3 month period. 22 In addition to the limits for employees aged 18 years or over described above, there are separate limits for the following categories of person (the RPA can provide further advice as necessary): 22.1 22.2 Trainees aged 16-18. Other persons including individual members of the public.

23 There is also a special rule for dose limitation for employees who have been overexposed in a particular year. Information on this rule, together with a summary of all the dose limits is provided at Annex E. Further information is given in Leaflet 6 and the RPA can provide further advice if need be. 24 Overexposure - the exposure of a person to ionising radiation to the extent that the dose received by that person causes the dose limit relevant to that person to be exceeded. The radiation employer has a statutory requirement to inform the Health and Safety Executive of any person (other than a member of a visiting force described in part 1 of the Visiting Forces Act 1952 or a member of a visiting force attached to a headquarters or an organisation) who is believed to have exceeded a dose limit. The requirement for investigation, notification and reporting is covered in Leaflet 14. The Health and Safety Executive may be expected to visit any establishment where an overexposure occurs. DESIGNATION OF CONTROLLED OR SUPERVISED RADIATION AREAS 25 This section defines the requirements for designation of controlled or supervised areas, together with the requirements for demarcating and restricting access to such areas. This section does not apply to operational nuclear submarines where the requirements of BR 3030(2) are to be followed. Controlled areas 26 It is a statutory requirement that an RPA be consulted as to the implementation of requirements as to a controlled area (or make changes to the area or work to be carried out in that area). A controlled radiation area is to be designated whenever:

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26.1 Any person entering the area has to follow special procedures designed to restrict significant radiation exposure or prevent or limit the probability and magnitude of radiation accidents or their effects, or 26.2 Any person working in the area is likely to receive an effective whole body dose greater than 6 mSv in a year or an equivalent dose greater than three-tenths of the dose limits (see below and Annex E). 27 The Approved Code of Practice to IRR99 states that an employer is to designate a controlled area in the following circumstances: 27.1 The external dose rate is liable to exceed 7.5 Sv h-1 averaged over the working day;

27.2 The hands of an employee can enter an area and the 8 hour time average dose rate in that area exceeds 75 Sv h-1; 27.3 There is a significant risk of spreading contamination outside the working area;

27.4 It is necessary to prevent, or closely supervise, access to the area by employees who are unconnected with the work with ionising radiation while that work is underway; or 27.5 Employees are liable to work in the area for a period sufficient to receive a whole body dose in excess of 6 mSv a year. 27.6 Note that an employer must not intentionally create, in any area, conditions that would require that area to be designated as a controlled area, unless that area is for the time being under the control of the employer. 28 In addition, an area is to be designated as a controlled area if the dose rate averaged over a minute exceeds 7.5 Sv h-1 and 28.1 Site radiography is carried out, or

28.2 Employees untrained in radiation protection are likely to enter that area, unless the only work with ionising radiation involves a radioactive substance dispersed in a human body and none of the conditions in paragraph 31 apply. Demarcation of controlled areas 29 Controlled areas are to be demarcated where practicable by the erection of effective barriers that are at least adequate to impede inadvertent unauthorised entry. Where this is not reasonably practicable, controlled areas must be delineated by some other suitable means. Controlled areas that are liable to contain high activity sealed sources are to be bounded by barriers that are secure against deliberate unauthorised entry (see Leaflet 3). Use is to be made of permanent structures where practicable, such as walls of buildings, to provide such boundaries. 30 Suitably worded signs are to be posted at all boundaries to a controlled area stating that the area is a controlled area (see Annex B). The signs are to include details of the nature of radioactive sources and the risk arising from such sources. Such signs are to be supported by prohibition signs with the legend - No unauthorised entry. Access to controlled areas 31 Access to controlled areas is to be limited to: 31.1 31.2 Classified persons. Outside workers further information is detailed in Leaflet 6.

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31.3 Unclassified persons working under written arrangements applicable to the controlled area (see Leaflet 5). 31.4 31.5 Persons undergoing a medical or dental exposure. Visitors entering under written arrangements (see Leaflet 5).

32 Classified persons who are required to enter a controlled area which is operated by an employer other than their own, are to provide their radiation passbook (see Leaflet 6) to the RPS who is responsible for the controlled area. Wearing of dosemeters in controlled areas 33 All classified persons entering controlled areas are to wear dosemeters issued by an Approved Dosimetry Service (ADS), normally the Dstl ADS. The type of dosemeter, for example, whole body TLD, skin/extremity TLD or neutron is to be specified in the local orders. 34 Unclassified persons are to be issued with dosemeters where this is specified in the written arrangements (see Leaflet 5). Where dosemeters are not issued to individuals, an alternative means of dose assessment is required to be specified in the written arrangements. 35 Direct-reading dosemeters, normally an electronic personal dosemeter (EPD), are to be worn by all workers in areas where high radiation doses may be received, in order to manage the restriction of radiation dose on a day-to-day basis. Setting of appropriate dose and dose rate alarms can also greatly assist ALARP management. 36 Where a risk assessment (see Leaflet 2) indicates that an accident or incident may occur in which the personnel involved could receive a dose in excess of 6 mSv (or greater than 3 tenths of any relevant dose limit as detailed in Annex E), IRR99 requires special arrangements for dosimetry and the rapid assessment of dosemeters by an ADS. In some cases an additional dosemeter, known as an accident dosemeter, is required. Where an unclassified person is not required to wear a dosemeter, an appropriate alternative means of accident dose assessment must be provided. Further details of accident dosimetry requirements are given in Leaflet 6. Permit-to-work 37 In circumstances where it would be possible for a person working in a controlled area to receive a significant proportion of a dose limit, or be exposed to a significant risk of contamination, entry is to be prohibited to all persons except those who have received written permission (permit-to-work) to enter the area, signed by a person authorised to do so on behalf of the CO. The permit-to-work is to contain the following information: 37.1 37.2 The name of the person or persons in respect of whom it is issued. The name of the person directly responsible for the work to be carried out.

37.3 The place to which it relates, the designation of the area, and a description of the work to be undertaken. 37.4 The procedure to be followed, and the precautions taken to ensure that the doses received by each of those persons are kept to the minimum that is reasonably practicable and do not in any event exceed the appropriate dose limits. 37.5 37.6 NOTE The period for which it is valid. The date of its issue.

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Some establishments, such as nuclear submarine establishments, operate a system of Radiological Control Certificates. A radiological control certificate is considered to constitute a permit-to-work, if it includes the information detailed above. Supervised areas 38 The RPA must be consulted on the implementation of requirements as to a supervised radiation area. A supervised radiation area is to be designated whenever: 38.1 It is necessary to keep the conditions of the area under review to determine whether the area should be designated as a controlled area, or 38.2 Any person in the area is likely to receive an effective whole body dose greater than 1 mSv a year or an equivalent dose greater than one-tenth of any relevant dose limits. (See below and Annex E). Signage of supervised areas 39 Supervised areas may be indicated by the use of suitably worded signs (see Annex B) stating that the area is a supervised area and details of the nature of the radioactive sources and the risk arising from such sources. The requirement for posting signs is to be determined by the unit or establishment in consultation with the RPA. Temporary designated areas 40 Areas in which radioactive materials are used occasionally or radiation emission is not continuous are only required to remain as controlled or supervised areas while the potential for radiation emissions exist and access is to be restricted accordingly. Pregnant and breastfeeding employees 41 Following notification of pregnancy, access to controlled or supervised areas for a pregnant employee must be restricted such that the radiation exposure to the foetus is limited to an equivalent dose of 1 mSv or less for the remaining term of the pregnancy (see Leaflet 6). An employee who is breastfeeding is to be excluded from entry to controlled areas where there is a significant risk of bodily contamination of that employee. Safety signs 42 Safety warning signs and prohibition notices, used to mark controlled and supervised areas, are to conform to the Health and Safety (Safety Signs and Signals) Regulations 1996. Employers may add supplementary text or cautionary notices to make the sign appropriate to their situation, including text in the appropriate language of the host nation if units are overseas. Units and establishments are responsible for obtaining sufficient quantities of the required signs, either from commercial sources or manufactured locally. Examples of the types of sign that may be used are shown in Annex B. Recording of designated areas 43 All controlled and supervised areas are to be shown on establishment plans. A copy of these plans, denoting such areas, is to be contained in local orders. In addition, copies are to be posted at the entrance to controlled and supervised areas whenever practicable, and are to be routinely issued to the Fire Officer or their equivalent at each unit and establishment.

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MONITORING OF DESIGNATED AREAS 44 Employers must ensure, for each designated area, that levels of ionising radiation are adequately monitored using suitable instruments and that working conditions in those areas are kept under review. For areas designated on the basis of external radiation, adequate monitoring is to include measurement of dose rates (averaged over a suitable period if necessary). For areas designated on the basis of radioactive contamination, monitoring is to include measurements of air activity and surface contamination where appropriate, taking into account the physical and chemical states of the contamination. In either case, the monitoring is to be sufficient to indicate whether levels of radiation and contamination are satisfactory for continuing work with ionising radiation. 45 Monitoring programmes are to be designed to indicate any reasonably foreseeable breakdown in controls or systems and to detect significant changes in radiation or contamination levels. Monitoring is necessary both inside and outside the boundaries of controlled and supervised areas, especially at the access/egress to contamination areas. 46 Employees are to be familiar with the correct operating procedures for monitoring instrumentation and how to interpret and record the monitoring results correctly. 47 It is a statutory requirement that the RPA is consulted regarding the regular calibration of equipment provided for monitoring levels of ionising radiation and the regular checking that such equipment is serviceable and correctly used. Monitoring equipment is to normally be tested and thoroughly checked at least once every year. Further detail on radiation monitoring instruments is at Leaflet 8. 48 Guidance on monitoring of designated areas is at Annex C.

MONITORING OF NON-DESIGNATED AREAS 49 Monitoring of non-designated areas may also be necessary. This should also be designed to indicate any reasonably foreseeable breakdown in controls or systems and to detect significant changes in radiation or contamination levels. The requirement for monitoring non-designated areas will be identified at the risk assessment stage and is to be sufficient to indicate whether levels of radiation and contamination are satisfactory for continuing work with ionising radiation. ENGINEERING CONTROLS, DESIGN FEATURES, SAFETY FEATURES AND WARNING DEVICES 50 First and foremost, in any work with ionising radiation, radiation employers are to take action to control the doses received by their employees and other persons by engineered means. Usually, the most effective restriction of exposure will be achieved by incorporation of control mechanisms at the design and construction stage of a project. These engineering controls and design features will usually be intrinsic to the equipment or facility, for example the construction of suitable containment and shielding for sources and the incorporation of safety features which ensure that radiation sources are accessible to no greater extent than is necessary. Safety features are intended to help ensure the safe use of the equipment in both normal and failure modes. 51 Where reasonably practicable, work involving exposure to external radiation is to be done in a room, enclosure, cabinet or purpose built structure which is provided with adequate shielding. In other cases, local shielding is to be used as far as reasonably practicable. Design is to be such that dose rates beyond the room, enclosure or cabinet do not exceed 7.5 Sv h-1 for classified persons. If unclassified persons or members of the public can access the area beyond the room or enclosure, the dose rates are to be sufficiently low to avoid the need to designate that area as a supervised area. 52 Where an employee could receive a dose in excess of any dose limit within several minutes, interlocks or trapped key systems are to be provided to ensure an exposure: 52.1 Cannot commence while the access door, access hatch, cover or appropriate barrier to the enclosure is open;

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52.2 52.3

Is interrupted if the access door, hatch or barrier is opened; and Does not recommence on the mere act of closing the access door, hatch or barrier.

53 Where there is a risk of significant exposure arising from unauthorised or malicious operation of Xray generators or source containers, the equipment is to be fitted with locking off arrangements to prevent its uncontrolled use. Similarly, the initiation of exposures is to be under key control or by some equally effective means so as to prevent unintended or accidental emission of a radiation beam or exposure of a source. 54 Sources of ionising radiation which can give rise to significant exposure in a very short time are to be fitted with suitable warning devices which indicate the status of equipment in normal operation and alert operators to faults or failures which might reduce the safety of the installation. For X-ray generators, other than those used for diagnostic radiology, the warning devices are to be automatic and fail-safe i.e. if the device fails, the exposure will not proceed. Warning devices must be able to be seen or heard by all those people who need to know the status of the equipment for protection purposes. 55 The employer must ensure that any engineering control, design feature, safety feature or warning device is properly maintained and, where appropriate, that thorough examinations and tests of such controls, features or devices are carried out at suitable intervals. Records are to be kept sufficient to enable the employer to identify which controls, features or devices have been examined or tested and what action is required to maintain them and when the next test or examination is due. 56 In the context of this section, it is a statutory requirement for the RPA to be consulted in the following matters: 56.1 The prior examination of plans for installations and the acceptance into service of new or modified sources of ionising radiation in relation to any engineering controls, design features, safety features and warning devices provided to restrict exposure to ionising radiation. 56.2 The periodic examination and testing of engineering controls, design features, safety features and warning devices and regular checking of systems of work provided to restrict exposure to ionising radiation. SAFE SYSTEMS OF WORK 57 Once engineered features have been applied, it is important that they are supported by systems of work to be followed by employees and other persons when present in the vicinity of radiation equipment. Safe systems of work can include those specified in local orders, work instructions, method statements, detailed procedures and, where a significant exposure could occur in a short period of time, permit to work systems. The employer must take all reasonable steps to ensure that systems of work are applied and followed - in all cases, appropriate supervision is an essential feature. 58 In the case of high dose rate sealed source equipment, systems of work are to include a monitoring check to ensure that the equipment has been restored to a safe state before access to that area is permitted. PERSONAL PROTECTIVE EQUIPMENT (INCLUDING RESPIRATORY PROTECTIVE EQUIPMENT) 59 Once engineering controls and the application of safe systems of work have been applied, radiation employers are to provide personal protective equipment (PPE) to further restrict exposure where this is reasonably practicable. PPE must be adequate to provide the protection required and suitable for both the job and person who must wear it. 60 Any personal protective equipment provided by an employer to restrict exposure must comply with any provision in the Personal Protective Equipment at Work Regulations 1992. Respiratory protective equipment must be of a type or conform to a standard, approved in either case by the HSE. The employer must ensure that appropriate accommodation is provided for personal protective equipment when it is not being worn.

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61 Every person entering a controlled area designated on the basis of contamination is to wear any personal protective equipment provided for their use as specified in the local orders. The employer must take all reasonable steps to ensure that it is properly used. Detailed guidance on the requirements for use and maintenance of personal protective equipment are given in Annex D. 62 Respiratory protective equipment (RPE), whether in the form of passive respirators, air-fed respirators, air-fed hoods or blouses, air-fed suits, or self-contained breathing apparatus is to be worn as directed in local orders or as instructed by the RPS. Guidance on the requirements for use and testing of RPE is given at Annex D. 63 X-ray protective equipment (lead aprons and/or gloves), where appropriate, is to be worn by personnel in accordance with local orders. Such equipment is to be stored and maintained as detailed at Leaflet 26. This equipment is designed for the protection of workers against low-energy X-rays (such as scattered radiation from diagnostic X-ray sets and similar sources); it affords little protection from higher energy X-rays (above about 150 kV), such as from industrial radiography equipment, and is not to be used for this purpose. 64 The employer must ensure that all PPE is, where appropriate, thoroughly examined at suitable intervals and is properly maintained and, in the case of RPE, a suitable record of the examination is made and kept for at least 2 years. The record must include a statement on the condition of the equipment at the time of the examination. RECORDS 65 The following records and retention periods are relevant to this leaflet: 65.1 All investigation reports are to be kept for at least 5 years from the date on which they were made. 65.2 Routine and special monitoring surveys for designated areas are to be kept for at least 2 years. 65.3 Records of all inspections, examinations maintenance and testing of engineering controls and respiratory protective equipment are to be kept and retained for at least 2 years from the dates on which the examinations were made. 65.4 Records are to be kept of all RPE training received by personnel these are to be kept for a period of 2 years from ceasing work with RPE.

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RELATED LEAFLETS 66 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 2 3 Leaflet Title

Risk assessments Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Written arrangements for unclassified persons entering controlled areas Dosimetry and personal dose records Radiation detection and monitoring equipment Radiation protection aspects of transport and movement of radioactive materials Accumulation and disposal of radioactive waste Investigation, notification and reporting of unusual radiation events Local orders for radiation safety Dental X-ray machines Medical diagnostic X-ray machines and fluoroscopes Veterinary Diagnostic X-ray machines Contingency plans

5 6 8 10 12 14 16 25 26 27 40

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LEAFLET 4 ANNEX A CONTAMINATION CONTROL GUIDANCE CONTENTS Para 1 2 4 5 6 7 9 11 13 15 Restriction of entry Containment and prevention of spread of contamination Personal protective equipment Rules for employees working in contamination areas Treatment of cuts or beaks in the skin Cleaning of designated contamination areas Removal of items from designated contamination areas Clearance of radioactively contaminated items Exit of personnel from contamination areas Air sampling

Appendix 1 2 MOD Form 34D Radioactive transfer (internal) label Personal contamination report

RESTRICTION OF ENTRY 1 Restriction of entry to controlled and supervised areas, including the need for signs and barriers, is addressed in the main body of this leaflet and at Annex B. The RPA is to be consulted on the requirements as to controlled and supervised areas. CONTAINMENT AND PREVENTION OF SPREAD OF CONTAMINATION 2 Work liable to give rise to a radioactive vapour, spray, dust or gas is to be conducted whenever reasonably practicable in a fume cupboard, glove box, tented enclosure or other suitable containment. 3 In order to prevent the spread of contamination the following is to be adhered to: 3.1 Equipment provided specifically for the safe handling of unsealed radioactive substances is not to be removed from the controlled contamination area. 3.2 All tools and equipment used in the controlled contamination area are to be clearly marked and where necessary appropriately packaged and labelled. 3.3 The working area is to be kept free from articles that are not required.

3.4 The total activity handled or stored in a controlled or supervised area, designated on the basis of potential for spread of contamination, is to be kept to a minimum. For laboratories designated as controlled or supervised areas, an activity limit is to be set and specified in local orders. PERSONAL PROTECTIVE EQUIPMENT 4 Every person entering a controlled or supervised area, designated on the basis of contamination, is to wear the personal protective equipment provided for their use as specified in the local orders and instructions. The requirements for use and maintenance of personal protective equipment are given in Annex D.

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RULES FOR EMPLOYEES WORKING IN CONTAMINATION AREAS 5 In any contamination area the individual is not to: 5.1 5.2 Eat, drink, smoke or any similar activity. Place their mouth in contact with any piece of apparatus (e.g. pipettes).

5.3 Use personal pocket handkerchiefs. An adequate supply of suitable paper tissues is to be provided for the use of all persons and when used they are to be treated as radioactive waste. 5.4 Enter having any cut or other break in their skin unless it is covered so as to prevent entry of radioactive substances. TREATMENT OF CUTS OR BREAKS IN THE SKIN 6 When any person entering a controlled or supervised area, designated on the basis of contamination, sustains a cut or other break in the skin they are to promptly inform a suitable person who can summon a first-aider trained in the treatment of contaminated wounds to ensure that appropriate first aid treatment is given. Any such injury sustained while working with radioactive materials is to be reported to the medical department and the person affected is to be sent for treatment. Investigation, notification and reporting of such incidents is covered in Leaflet 14. CLEANING OF DESIGNATED CONTAMINATION AREAS 7 Working areas are to be kept clear and uncluttered to prevent the build-up of contamination and facilitate clean-up in the event of a spillage. All controlled areas and equipment therein are to be cleaned often enough to keep the levels of surface contamination to a minimum, noting the requirement to keep total radiation exposures ALARP. The cleaning techniques used should, as far as practicable, avoid the spread of contamination and prevent unsealed radioactive substances becoming airborne. 8 Any articles and materials used for cleaning in controlled areas are to be appropriately marked and are to be used only for that purpose. When not in use they are to be treated as contaminated items. REMOVAL OF ITEMS FROM DESIGNATED CONTAMINATION AREAS 9 No material or equipment is to be removed from a supervised or a controlled contamination area unless it has first been appropriately monitored for radioactivity. Unless the item can be cleared (see below) it can only be moved to another area, whether or not a controlled area, in accordance with written procedures for that movement (see Leaflet 10). Transport of items off site must comply with the instructions in JSP 800 Vol. 4b. 10 The radioactive material or equipment is to be marked to indicate that it is radioactive. MOD Form 34D (see Appendix 1) is suitable for this purpose. Locally produced forms may be used but must contain at least as much information as is on this form. It must be understood that the arrangement to move a radioactive item within a ship or establishment does not confer approval for the item to be transferred to another establishment or contractor. Items to be transferred to other establishments or contractors are to meet the requirements for transport outside an establishment as detailed in JSP 800 Vol. 4b.

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CLEARANCE OF RADIOACTIVELY CONTAMINATED ITEMS 11 Situations may arise where vehicles, materiel or equipment are suspected of being contaminated with radioactive material. Where practicable, any such items are to be quarantined until they can be monitored for radioactive contamination. The levels of contamination identified will dictate whether it is appropriate to dispose of, reuse or recycle the item and whether further controls or restrictions will be required. Advice on monitoring of such items and clearance levels for unrestricted use is to be sought from the RPA. 12 The MOD has adopted a Nuclear Industry Code of Practice (COP) entitled Clearance and Exemption Principles, Processes and Practices for Use by the Nuclear Industry. The RPA is likely to base their advice on the contents of this document. EXIT OF PERSONNEL FROM CONTAMINATION AREAS 13 Protective equipment that has been worn in controlled or supervised areas is to be monitored, removed and placed in a receptacle or space provided for that purpose. Protective equipment is to be removed in such a way as to prevent as far as possible the spread of contamination. Normally overshoes are to be removed at a clearly defined barrier, such that the wearer's personal shoes do not touch the ground on the contaminated side of the barrier and other protective equipment removed so that as far as practicable the outside surfaces are not touched with the bare hand. Following removal of protective equipment, personnel are to wash in facilities specifically provided for that purpose and undergo monitoring for contamination using contamination monitoring instruments that are provided. Where a person is found to be contaminated, decontamination procedures are to be followed (see Leaflet 16 Annex C) and details of any contamination are to be provided on form S/D 1954 (see Appendix 2 to this leaflet). 14 Where personal protective equipment is contaminated, it is to be placed in a special receptacle and the RPS is to be informed. The equipment is not to be re-used until it has been decontaminated to a level advised by the RPA. AIR SAMPLING 15 Where there is a risk of airborne contamination, air sampling is to be carried out for the duration of the work. This is normally done using static samplers, but where high concentrations are expected in the immediate vicinity of the individual exposed personal air samplers which are designed to sample air from immediately beside the users face are to be used. If subsequent measurement of the filter paper activity gives a positive reading, it may be necessary to determine the associated committed dose and include it on the individuals dose record, as advised by the RPA. 16 Air sampling should also be undertaken at the access/egress points to contamination areas to confirm there has not been a spread of contamination to areas not designated as contamination areas,

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LEAFLET 4 ANNEX A APPENDIX 1 MOD FORM 34 D RADIOACTIVE TRANSFER (INTERNAL) LABEL

Actual size: 7in x 4 in; colour: yellow

THIS LABEL IS ONLY TO BE USED FOR INTERNAL TRANSFERS OF RADIOACTIVE MATERIAL.

RADIOACTIVE
Ref. No. Date .. Description .. .. Fill in as necessary according to nature of hazard. Surface dose rate .. Dose rate I metre from centre Surface contamination . Remarks .. . . To ... . From... . tear off here Ref. No. Date .. From .. . To . Received...
MOD Form 34d 56/Dd8276104

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LEAFLET 4 ANNEX A APPENDIX 2 SYMBOL USED TO DENOTE THE PRESENCE OF IONISING RADIATION

STANDARD PROPORTIONS OF TREFOIL SYMBOL 1. The areas shown in black shall be coloured and shall be placed on a yellow background (Colour No 309 of BS 381C) except in the case of Category I transport label, in which case the background shall be white. Any lettering necessary is to be in black. The symbol shall be prominent on notices as is practicable and of a size proportionate with the size of the equipment or material to which it is affixed or attached, provided that the standard proportions are maintained and that the symbol can be seen from a safe distance. The basic symbol shall be accompanied by additional symbols or words where necessary to particularise the danger.

2.

3.

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LEAFLET 4 ANNEX A APPENDIX 3 PERSONAL CONTAMINATION REPORT S. 1954 (Revised 6/83) Ship or establishment ... PERSONAL CONTAMINATION REPORT To: The Medical Officer . Date ... .. Copy to: ... . Name and Initials Service/Yard Number Rank/rating/Grade Department

Contamination Report by Monitor at

(time)using

(instrument)

Parts of body Levels in cps

Cause of contamination .. 2 Action taken to remove Contamination Method or, Contamination levels (c.p.s.) after decontamination Parts of body (time)

Result sent to SURGERY/DECONTAMINATION CENTRE Signature .. 3 To be completed at Surgery/Decontamination Centre Particulars of action taken by or recommendations of the responsible officer at the Surgery/Decontamination Centre The above named was re-monitored and found CLEAR/CONTAMINATED RECHECK Date ... Time ...... Signature .. and rank If person is found contaminated or recheck, give details The above named was re-monitored and found FINAL CLEARANCE Date ... Time ... Signature . and rank

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4.

DEPARTMENT INVESTIGATION

Signature Grade . Date

5.

COMMENTS BY HEALTH PHYSICS DEPARTMENT

Date ..

. Health Physicist

040273 Rep S(PP)I (Y)

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LEAFLET 4 ANNEX B RADIOLOGICAL SAFETY WARNING SIGNS AND LABELS CONTENTS Para Signs Procurement of signs Warning labels

1 2

SIGNS

Figure 1 Controlled radiation area sign

Figure 2 Controlled contamination area sign

Figure 3 Controlled area sign

Figure 4 Controlled X-radiation area sign

Figure 5 supervised area sign

Figure 6 Supervised contamination area sign

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Figure 7 Supervised radiation and controlled contamination area sign

Figure 8 Supervised contamination and controlled radiation area sign

Figure 9 Radioactive materials store sign

X-Ray Area X-ray


Area

Figure 10 X-ray area sign

Figure 11 Basic radiation warning sign

Figure 12 Universal radiation warning symbol

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Entry Prohibited

No Unauthorised Entry

No Entry when red light Is flashing

Figure 12 Entry Prohibited sign

Figure 13 No unauthorised entry sign

Figure 14 Prohibition sign used for radiography areas

CAUTION RADIOACTIVE MATERIAL

CAUTION RADIOACTIVE MATERIAL

Figure 15 Adhesive tape incorporating the radiation trefoil PROCUREMENT OF SIGNS 1 Radiation warning signs need to be purchased from a commercial supplier or manufactured locally.

WARNING LABELS 2 The following trefoil labels are detailed in JSP 466 Forms Catalogue and are available from DSDA 3a, Defence Storage and Distribution Agency, Llangennech, Llanelli, Carmarthenshire, SA174 8YP: 2.1 F Sign 919 2.2 F Sign 804 2.3 F Sign 803 25mm x 25mm 75mm x 75mm 150mm x 150mm Roll of 50, appropriate for equipment or marking shelves in cabinet Appropriate for marking racking Appropriate for marking racking Sheet of 100, appropriate for marking equipment

2.4 NSN 9905-99-965-0441 10mm circular

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LEAFLET 4 ANNEX C MONITORING OF DESIGNATED AND NON-DESIGNATED AREAS CONTENTS Para

1 2 3 4

Responsibility for monitoring designated areas Purpose of monitoring Adequate monitoring Role of the Radiation Protection Adviser (RPA)

RESPONSIBILITY FOR MONITORING AREAS 1 The responsibility for monitoring rests with the employer in control of that area.

PURPOSE OF MONITORING 2 The main purposes of monitoring are to: 2.1 Check that areas have been (and remain) correctly designated where applicable.

2.2 Help determine radiation levels and contamination from particular operations, so that appropriate control measures for restricting exposure can be proposed. 2.3 Detect breakdowns in controls or systems, so as to indicate whether conditions are satisfactory for continuing work in that area. 2.4 Provide information on which to base estimates of personal dose for unclassified persons, outside workers and classified persons for whom a dose assessment could not be made by the Approved Dosimetry Service. ADEQUATE MONITORING 3 In order to establish whether adequate monitoring is being achieved, the following need to be considered: 3.1 What kinds of measurements are to be made (e.g. dose rates, surface or air contamination). 3.2 3.3 The nature of the radiation and the physical/chemical state of likely contamination. Where the measurements are to be made.

3.4 How frequently and on what occasions the monitoring is to be carried out, including measurements to be made as part of contingency arrangements. 3.5 Method of measurement e.g. direct measurement with an instrument, collection of air samples, smear or wipe samples and what type of instrument to be used. 3.6 Who should carry out the measurements and what training they need.

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3.7 3.8 3.9 3.10 3.11

How to ensure that the equipment continues to work correctly. What records are to be kept. How to interpret and review the results. The selection of action levels and what to do if they are exceeded. When the monitoring procedures must be reviewed.

ROLE OF THE RPA 4 The radiation employer must consult the RPA about the implementation of requirements for controlled areas and supervised areas. These requirements include: 4.1 4.2 The type and extent of the monitoring programme. The selection and suitability of instruments to be used for monitoring.

4.3 The regular calibration and checking of monitoring equipment to ensure it is serviceable and correctly used. MONITORING RECORD 5 Suitable monitoring records are to include the date time and place of monitoring and confirm that, where applicable, controlled and supervised areas are correctly designated and show where levels are being approached which may require investigatory or remedial action to be taken. The results are to indicate the nature of the radiation or contamination being monitored. The records of area designation shall be kept for at least 2 years from the date on which they were made. A summary of the information that should be included in a monitoring report is given below: 5.1 5.2 Details of locations where measurements are taken The type of radiation or contamination detected, as appropriate

5.3 The dose rate or contamination levels measured, as appropriate. These could be indicated on a diagram of the area. 5.4 The name and designation of the person actually undertaking the survey together with the name and designation of the officer responsible for ensuring the proper conduct of the survey 5.5 Date and time of the survey 5.6 Details (type and serial number) of the instrument(s) used 5.7 Details of any significant unusual conditions observed during routine monitoring 5.8 Any action level and action required, following discussion with the appointed RPA 5.9 Any other appropriate information

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LEAFLET 4 ANNEX D GUIDANCE ON PERSONAL PROTECTIVE EQUIPMENT (INCLUDING RESPIRATORY PROTECTIVE EQUIPMENT) CONTENTS Para 1 4 10 29 30 Introduction Personal protective equipment for controlled contamination areas Respiratory protective equipment Use of service respirators Training for the supervisor and wearer of respiratory protective equipment (RPE)

INTRODUCTION 1 Where appropriate, personal protective equipment (PPE) (including respiratory protective equipment (RPE)) are to be provided to reduce radiation exposure of personnel. PPE is to be regarded as supplementary to, and not as a substitute for, other measures for the control of sources of ionising radiation. 2 The different forms of PPE used by operators are: 2.1 2.2 Clothing and other items for personal protection against contamination. RPE for protection against airborne particulate or gaseous radioactive materials.

2.3 X-ray PPE (medical, dental and veterinary) guidance on this type of PPE is not covered in this leaflet (see Leaflet 26). 3 PPE for use against external sources of energetic gamma radiation, such as from Cobalt-60, is not practicable. Advice is to be sought from the RPA for protection from such sources. PERSONAL PROTECTIVE EQUIPMENT FOR CONTROLLED AREAS DESIGNATED ON THE BASIS OF CONTAMINATION 4 Personnel entering such a controlled area are to wear the PPE specified in the local orders and provided for use. When leaving the controlled area, the equipment is to be monitored, removed and placed in a suitable location as detailed in the local orders. Any person finding PPE in poor repair is to inform the RPS. 5 Items of PPE worn in such areas is to be treated as potentially contaminated and is to be retained in an area separate from those in which personal clothing and other uncontaminated items are deposited. 6 The type of provision of PPE is to be agreed with the RPA. PPE must be sufficient to provide protection during normal operations and against any reasonably foreseeable accident within the controlled area. The normal type of PPE for controlled contamination areas would be an overall or laboratory coat, gloves, such as surgical gloves, cap and protective footwear or overshoes. 7 All PPE is to be clearly distinguishable from normal work clothing. Units and establishments having small numbers of regular wearers may mark the PPE to identify it as belonging to named individuals. 8 All PPE is to be inspected and tested for damage at intervals specified in the local orders. PPE is to be replaced at appropriate intervals or is to be washed in segregated laundries designated for contaminated protective clothing only; in this instance consideration must be given to the need to dispose of the liquid generated by the laundry as radioactive waste.

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9 PPE with contamination exceeding levels specified in local orders (as advised by the RPA), where the contamination cannot be removed by washing, is to be withdrawn from use and disposed of as radioactive waste as described in Leaflet 12. RESPIRATORY PROTECTIVE EQUIPMENT 10 Suitable RPE is to be provided where advised by the RPA or where, during normal or abnormal conditions, a significant airborne hazard exists. 11 For some work involving radioactive materials in low concentrations, such as thorium alloys or thoriated tungsten welding electrodes, RPE provided against the non-radiation hazard may provide adequate protection against the radiation hazard. Advice is to be sought from the RPA on the most suitable RPE for the radiation hazard. 12 An adequate assessment of the degree of respiratory protection required is to be made before any attempt is made to select the type of RPE to be used. For RPE in regular use, a full assessment is to be made prior to first use and thereafter reviewed regularly dependent upon the hazard. In selecting RPE the following factors are to be taken into account: 12.1 12.2 Nature of the hazard (particulate, vapour or gas). Protection factor required.

12.3 Ergonomic factors (reduced mobility, increased resistance to breathing, reduced field of vision, high air temperatures and high relative humidities). 12.4 When considering the need for wearing respiratory protection, the dose rate in the area is to be taken into consideration as wearing respiratory protection may impede work and result in a higher external radiation dose for a small saving in internal dose. 12.5 12.6 12.7 12.8 12.9 12.10 Duration of wear. Potential for damage of RPE. For respirators, closeness of fit to provide a good seal. Compatibility of use with other safety equipment that may need to be worn. Adequacy of facilities to maintain RPE. Dangers from falling or tripping, particularly at heights.

13 It is a requirement to comply with relevant legislative requirements if RPE is provided for use against ionising radiations. This requires the equipment to be adequate and suitable. The term adequate refers to the ability of the equipment to protect the wearer. The term suitable refers to the correct matching of the equipment to the job and person. To select equipment which is adequate and suitable, an assessment is to be carried out and recorded. Advice on undertaking such an assessment is to be sought from the RPA. 14 Adequate training for the wearer of the RPE and their supervisor is described below. Refresher training is to be provided at no greater than an interval of 6 months for all wearers of RPE. 15 RPE intended for daily use is to be thoroughly examined before being brought into use to ensure that it is in good condition. After the initial examination the RPE can be used without re-examination for periods of up to one month. A system for regular inspection is to be set up and respirators are to be marked accordingly. In addition to the initial examination the user is to carry out a daily examination of the equipment prior to use.

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16 RPE intended for routine but not daily use is to be kept in sealed packs and can be used for up to a year from the previous examination. It is however subject to the following requirements: 16.1 It is properly stored (see paragraph 21-22);

16.2 It is checked before use to verify that the pack has remained sealed and no deterioration has taken place; 16.3 Arrangements are made to withdraw it for examination within one month of its being brought into use. 17 For respirators kept in sealed packs it should be sufficient to see by examination of a representative sample that no obvious deterioration has taken place since last used, provided that a quality control check is carried out at least annually. 18 Worn and defective components are only to be replaced using spare parts supplied specifically for the RPE under repair. Simple replacement of the filter, cartridges and batteries can be made by the RPE wearer after suitable instruction. 19 After use the RPE is to be monitored for radioactive contamination. Equipment is to be decontaminated to a level that is as low as reasonably practicable. Where equipment cannot be fully decontaminated, the RPA is to be consulted on its retention or disposal. 20 RPE is to be cleaned and disinfected after each use. Disinfectants which adversely affect the RPE are not to be used. Advice on suitable disinfectants can be obtained from the manufacturer. Such disinfectants must be thoroughly rinsed from masks before they are used. 21 Stores holding RPE are to be designed to protect against dust, excessive moisture, heat (above 60C), cold, UV light (including sunlight) or corrosive substances and kept secure from unauthorised personnel. In such stores, ready for use equipment is to be clearly segregated. 22 RPE not held in a designated store is also to be protected against the above deleterious effects.

23 A maintenance programme is to be drawn up for each type of RPE used. For positive pressure respiratory protective equipment the examination is to include a check on the condition of the air supply. The maintenance programme and the frequency of the maintenance are to be based upon information supplied by the manufacturer, and included in local orders. 24 RPE is to be replaced at intervals specified by the manufacturer, unless testing has shown that the RPE continues to provide adequate protection for extended periods. Spare parts are to be clearly identified and labelled with the date beyond which they are not to be used. 25 Repairs are only to be carried out by adequately trained personnel. Personnel undertaking this work are to have received training on the maintenance and repair of the equipment by attending a training course appropriate to the equipment. Local training may be provided by personnel who have previously attended such a course or other appropriate training. Records are to be kept of all RPE training received by personnel. Details of this training are to be kept for a period of 2 years from ceasing work with RPE.

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26 Records of all inspections, examinations maintenance and testing of respiratory protective equipment are to be kept and retained for 2 years from the dates on which the examinations were made. The record of examination is to contain the following or equivalent: 26.1 26.2 26.3 26.4 26.5 26.6 26.7 26.8 26.9 26.10 Name of the establishment. Description of the respiratory protective equipment. Distinguishing number. Description of the examination carried out. Result of the examination. Details of any contamination. Statement on the condition of the RPE at the time of the examination. Name and rank or description of the person making the examination. Date of the examination. Signature of the person examining the equipment.

27 Regular reviews are to be undertaken to ensure that use of the RPE is the most suitable means of control and the best RPE is being used. Regular audits are to be carried out to ensure that: 27.1 27.2 27.3 Personnel are adequately trained. RPE is being inspected, cleaned, maintained and tested at appropriate intervals. The record keeping system is operating satisfactorily.

28 Incidents involving failure or potential failure of the RPE are to be investigated and information gained from such investigations is to be used to further improve the effectiveness of the RPE. Such incidents are to be reported, where necessary, in accordance with the requirements in Leaflet 14. USE OF SERVICE RESPIRATORS 29 Service respirators Type S10 are primarily intended for operational use rather than for use in routine work with radioactive materials and, as such, are not subject to a formal approval by the HSE. However, they may be used in some circumstances e.g. trials of operational equipment RPA advice is always to be sought regarding the use of the S10 for routine work with radioactive materials. Similarly, respirators connected to Emergency Breathing Systems are intended for use in emergencies and should not normally be used for routine work.

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TRAINING FOR THE SUPERVISOR AND WEARER OF RESPIRATORY PROTECTIVE EQUIPMENT (RPE) 30 The following is the recommended training for persons wearing RPE and for persons supervising its use: 30.1 30.2 30.3 30.4 Details of the hazard presented by the radionuclide. Explanation why RPE is needed for control. Criteria for type of RPE selected. Capabilities and limitations of the RPE.

30.5 Arrangements for the use, maintenance and storage of the equipment and associated written procedures. 30.6 30.7 30.8 30.9 Conditions that are likely to be encountered when wearing RPE. Behaviour required during use of the RPE. Emergency situations and remedial actions to be taken. Practice in putting on, wearing and removing the RPE.

30.10 Checking the face fit of equipment which has a facepiece, including the requirement for a fit test appropriate to the RPE. 30.11 30.12 30.13 Practice in cleaning and inspecting equipment. Practice in replacement of parts requiring regular replacement during normal use (filters). Instruction on the safe storage of the RPE.

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LEAFLET 4 ANNEX E ANNUAL DOSE LIMITS CONTENTS Table 1 Annual dose limits .......................................................................................................................... 1

Table 1 Annual dose limits Employees (18 years of age or over) 20 500 500 150 Trainees aged 16-18 6 150 150 50 Any other person 1* 50 50 15

Part of body Whole body (effective dose) Skin (equivalent dose)** Hands, forearms, feet and ankles (equivalent dose) Lens of the eye (equivalent dose)

NOTES (1) See Leaflet 4 paragraphs 24

(2) *The dose limit for any person (not being a comforter or carer) who may be exposed to ionising radiation resulting from the medical exposure of another is limited to 5 mSv in any 5 consecutive calendar years. (3) **The equivalent dose limit for skin is applied to the average dose over any area of 1 cm2, regardless of the area exposed. ANNUAL DOSE LIMITS 1 Classified persons - employees (aged 18 years or over) are to be designated as classified persons (see Leaflet 6) if they are likely to receive an effective dose in excess of 6 mSv or an equivalent dose in excess of three-tenths of the relevant dose limits in the table above. In practice, this means that only classified persons should be likely to receive doses approaching the dose limits. 2 Dose limitation for overexposed employees - the dose limitation for the remainder of a calendar year for an employee who has been overexposed in that year and has not been withdrawn from radiation work by the recommendation of the Appointed Doctor, is the proportion of the calendar year remaining from the end of the dose assessment period multiplied by the appropriate annual dose limit.

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LEAFLET 5 WRITTEN ARRANGEMENTS FOR UNCLASSIFIED PERSONS ENTERING CONTROLLED AREAS CONTENTS Para

1 3 4 5 6 7 8 9 14 16 19 20 Table 1 Annex A B

Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Employees Unclassified persons Written arrangements Dose monitoring for unclassified persons Co-operation between employers Records Related leaflets Page Related leaflets................................................................................................................................4

Content of written arrangements Information exchange between employers for an unclassified employee working with ionising radiation

SCOPE 1 Where an employer has designated an area as a controlled area, IRR99 requires that they must not permit access to any unclassified person unless that person enters or remains in the area in accordance with suitable written arrangements. The purpose of this leaflet is to provide instruction and guidance on the requirements for such written arrangements to cover unclassified persons employed by the employer in question, to cover unclassified employees of another employer and to cover other persons and visitors. 2 The scope of this leaflet does not extend to the requirements for classified persons. Nor does this leaflet cover the written arrangements required in a hospital environment for access of comforters and carers to a controlled area the RPA is to be consulted for advice on such arrangements (see Leaflet 26). STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly).

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DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 5 The Radiation Safety Officer (RSO) is to ensure that: Written arrangements are produced, are kept under review and up to date, taking into account any changes in the work or other details covered by the written arrangements. Personnel entering controlled areas under written arrangements are provided with all necessary information, instruction and training. Information is exchanged with other employers as required by this leaflet. Sufficient means of assessing radiation exposure is provided and that records of exposure are kept, as specified later in this leaflet. Radiation exposures are kept as low as reasonably practicable.

Radiation Protection Supervisor (RPS) 6 The prime duty of the RPS is to ensure compliance with the IRR99 in respect of work carried out in the controlled area in practice, the RPS will achieve this by ensuring that work is carried out in accordance with the local orders for radiation safety (see Leaflet 16) and the written arrangements described in this leaflet normally, the written arrangements will be incorporated into local orders. The RPS will also provide assistance to the RSO, as required, in respect of the RSO duties described above. Employees 7 It is the responsibility of all unclassified employees to ensure that they comply with the conditions for entry and working in controlled areas as specified in the written arrangements. UNCLASSIFIED PERSONS 8 Unclassified persons for which written arrangements are required may include the following: Employees over 18 years who work with ionising radiation but are most unlikely to receive an effective dose exceeding 6 mSv or any of the other levels that would trigger the need for a person to be classified (see Leaflet 38). Employees of another employer who are not classified and who are to work in the controlled area. Trainees (aged between 16 and 18 years) such persons cannot become classified persons. Employees who do not normally work with ionising radiation. Persons under 16 years of age whether employees, trainees or visitors should be treated as other persons below.

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Other Persons e.g. members of the public visiting the site.

WRITTEN ARRANGEMENTS 9 Written arrangements are a set of arrangements laid down by the unit or establishment, in consultation with the RPA, to permit unclassified persons to enter a controlled area. IRR99 requires that the arrangements ensure that: In the case of an employee aged 18 years or over, that employee does not receive in any calendar year a cumulative dose of ionising radiation which would require that employee to be designated as a classified person (see Leaflet 38), or In the case of a trainee or any other person, the person does not receive in any calendar year a dose of ionising radiation exceeding any relevant dose limit (see Annex E of Leaflet 4).

10 Written arrangements may apply to a single person, process or controlled area or may apply to specific groups or types of person. 11 Unclassified persons must only be allowed conditional access to controlled areas these conditions must be set out in the written arrangements. In addition to the strict requirements in paragraph 9, the written arrangements are also to be aimed at ensuring adequate restriction of exposure to ionising radiation (see Leaflet 4) and may include close supervision, the use of PPE and restrictions on the type of work being done or the time spent in the area. Detailed guidance on the content of written arrangements is set out at Annex A. 12 13 Written arrangements are to be incorporated into local orders (see Leaflet 16). Written arrangements are to be reviewed whenever: There is a change to the details in the arrangements. The arrangements are found to be defective, for example by virtue of an individual reaching a maximum dose level allowed by the arrangements.

DOSE MONITORING FOR UNCLASSIFIED PERSONS 14 It is a requirement of IRR99 that an employer who has designated a controlled area, shall not permit a person to enter or remain in such an area in accordance with the written arrangements unless they can demonstrate by personal dose monitoring or other suitable measurements, that the doses are restricted in accordance with the written arrangements. It is essential that suitable estimates of dose are made for each individual this will often be by the use of personal dosimetry but, where appropriate, may be made by other measurements such as area monitoring, or by use of a single electronic dosemeter held by one member of a group of people. 15 The employer must keep the results of the monitoring or measurements above and must make them available, at the request of the person to whom the monitoring or measurements relate. MOD policy requires indefinite retention of these records. CO-OPERATION BETWEEN EMPLOYERS 16 IRR99 requires that where work with ionising radiation undertaken by one employer is likely to give rise to the exposure to ionising radiation of the employee of another employer, the employers concerned shall co-operate by the exchange of information or otherwise to the extent necessary to ensure that each employer is enabled to comply with the Regulations. Employers also have duties to co-operate under MHSWR 99.

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17 In the context of this leaflet, employers in control of the work area need information about the unclassified worker including dose history and training details. Dose information is to be passed between MOD employers using MOD Form FMed291D Radiation Record Summary Card (available from Dstl Approved Dosimetry Service, see Leaflet 6). 18 The employer of the unclassified worker will need information in advance about the work to be done and estimates of the dose likely to arise from the work. Estimates of the dose actually received will be required on return of the employee. Detailed guidance on the information to be exchanged is at Annex B. RECORDS 19 As for local orders (see Leaflet 16), reference copies of written arrangements are to be retained for a minimum period of 2 years after they are superseded. At the end of this period, an assessment on the relevance of retaining the document is to be made in accordance with MOD policy at Volume 1 Chapter 11. As detailed above, MOD policy requires records of monitoring data, relating to unclassified persons working under written arrangements, to be retained indefinitely. RELATED LEAFLETS 20 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 4 6 16 38 Restriction of Exposure to Radiation Dosimetry and personal dose records, including medical surveillance of classified persons Local Orders for Radiation Safety Classified persons and outside workers Leaflet Title

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LEAFLET 5 ANNEX A CONTENT OF WRITTEN ARRANGEMENTS CONTENTS Para

1 3

Introduction Content of written arrangements

INTRODUCTION 1 Written arrangements are a set of arrangements laid down by the unit or establishment, in consultation with the RPA, to allow unclassified persons to enter controlled areas. The primary aim of such written arrangements is to ensure that any exposure is effectively restricted and under no circumstances exceeds a relevant dose level or limit for the individual concerned (see paragraph 8 of the main body of this leaflet). 2 Written arrangements need to be specific to the type of employee, trainee or other person to whom they relate and may need to be specific to the type of work or visit being undertaken. Thus there may need to be more than one set of such written arrangements for a controlled area. CONTENT OF WRITTEN ARRANGEMENTS 3 Written arrangements are to contain the following information: 3.1 3.2 3.3 3.4 3.5 Name and address of the unit or establishment. Details of controlled area(s) to which the arrangements apply. Details of date(s), time(s) or period(s) to which the arrangements apply. Details of type of person covered (e.g. trainee, visitor). Details of type of work (or visit) covered.

3.6 Maximum cumulative dose(s) permitted may also be specified in terms of maximum dose per entry, per shift, per week etc. 3.7 The means of assessing and monitoring personal dose to include both external and, where appropriate, internal dose. 3.8 3.9 Investigation levels and procedures. Conditions for entry and working in the controlled areas e.g. Prior training and information required. PPE. Dosimetry. Supervision. Time to be spent in area.

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Local orders and instructions to be complied with. Emergency arrangements.

3.10 Special conditions and arrangements for sub-sets of individuals (e.g. requirements for pregnant or breast feeding workers to inform local management) are to be stated and also any additional restrictions on the type of work they may carry out. In some cases, it may be more appropriate to have a separate set of written arrangements. 3.11 Details of records to be made and retention periods.

3.12 Details of dose information to be provided to persons covered by the arrangements and their employers (if not own employee).

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LEAFLET 5 ANNEX B INFORMATION EXCHANGE BETWEEN EMPLOYERS FOR AN UNCLASSIFIED EMPLOYEE WORKING WITH IONISING RADIATION CONTENTS Para 1 2 4 Introduction Duties of the workers employer Duties of the operator of the controlled area

INTRODUCTION 1 This Annex applies only where an unclassified employee is to be deployed to work in a controlled area of another employer. DUTIES OF THE WORKERS EMPLOYER 2 Prior to commencement of radiation work, the employer is to: 2.1 Obtain, from the operator of the controlled area, information about the radiological risks and dose estimates relevant to the work to be carried out. 2.2 Obtain details of the written arrangements under which the employee will be working and consider whether these are adequate and acceptable it may be appropriate to consult an RPA in this respect. 2.3 Ensure that the employee to be sent is suitable to carry out the work, taking into account the type of work, the risks involved and the conditions under which the employee will be working. 2.4 Obtain details of any special training that is required before arrival on site and information about training that is to be delivered by the operator of the controlled area. 2.5 Provide the employee with the necessary information and training that the employee requires before arrival on site. 2.6 Provide the operator of the controlled area with an estimate of the radiation dose received by the employee to date in the calendar year (if any), details of the employees relevant training record and any other relevant particulars of the employee. 3 On return of the employee, the employer is to: 3.1 3.2 Ensure that the estimate of dose received by the employee is recorded and retained. Provide the employee with an estimate of the dose received if requested.

DUTIES OF THE OPERATOR OF THE CONTROLLED AREA 4 Prior to commencement of the work in the controlled area, the operator is to: 4.1 Provide the relevant information to the employer of the worker (see above).

4.2 Ensure that the worker has received any specific training and information required for the work including training on the use of any PPE, emergency arrangements and information on the conditions, specified in the written arrangements, under which they are to work.

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4.3 5

Ensure that the worker remains suitable and fit to undertake the work.

During the period whilst the work is being carried out, the operator is to: 5.1 Ensure that the worker is supervised so that local orders and the written arrangements are complied with. 5.2 Conduct further information exchange with the workers employer where any material circumstances of the work or the worker are likely to change or have changed. 5.3 Make estimates of the dose received as specified in the written arrangements.

On completion of the work, the operator is to: 6.1 Ensure that an estimate of the dose received is provided to the workers employer and directly to the worker (if requested).

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LEAFLET 6 DOSIMETRY AND PERSONAL DOSE RECORDS, INCLUDING MEDICAL SURVEILLANCE OF CLASSIFIED PERSONS CONTENTS Para 1 2 4 6 7 8 12 15 16 18 24 27 31 34 35 37 40 43 46 54 55 Table 1 Annex A Guidance for line managers and employees on types of dosemeter, dosemeter care, the administrative arrangements for dosimetry supply, the associated dosimetry records and medical documents Guidance for line managers and employees on estimated doses and special entries Dosimetry arrangements for outside workers Guidance for line managers and employees on the National Registry for Radiation Workers Guidance for line managers and employees on medical surveillance of classified persons Scope Statutory requirements and parallel arrangements Duties Commanding Officers (CO) Radiation Safety Officer (RSO)/Radiation Protection Supervisor (RPS)/Dosimetry Co-ordinators Employees Engaging suitable approved dosimetry services Personal radiation monitoring and assessment Appropriate dose assessment periods Supply of personal dosimetry Accident and emergency doses Suspected high dose Assessment of radiation dose from intakes of radioactive material Radiation overexposures Dose limitation for overexposed workers Dosimetry records Outside workers Compensation scheme and counselling scheme National registry for radiation workers Medical surveillance and Appointed Doctor Record retention periods Related leaflets Page Related leaflets..............................................................................................................................11

B C D E

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SCOPE 1 This leaflet is intended to assist line managers and employees within the MOD to comply with current legislation, guidelines and standards concerned with assessing and recording all significant doses of ionising radiation. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards. There is a statutory requirement for radiation dose assessment and recording to be kept in accordance with the following specific legislation: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR2001) (apply directly). Ionising Radiation (Medical Exposures) Regulations 2000 (IRMER2000) (apply directly).

3 There is a statutory requirement to ensure that all classified persons are certified as fit for their intended type of work and also that arrangements are made for continuing medical surveillance with appropriate records maintained in accordance with the Ionising Radiations Regulations 1999. DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. contractors and members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements including the provision of dosimetry may be delegated to line managers and other appropriate personnel, such as a Radiation Safety Officer (RSO). 5 Commanding Officers are responsible for: 5.1 Engaging a suitable Approved Dosimetry Service (ADS) for dose assessment and record keeping. 5.2 Making an assessment of all significant doses for personnel designated as classified persons and ensuring that such assessments are recorded. 5.3 At the request of a classified person, providing them with a copy of their dose summary or dose record. 5.4 Ensuring that outside workers are provided with a current individual radiation passbook and that arrangements are made to ensure that it is kept up to date. 5.5 Ensuring that classified persons are provided with a copy of their termination record.

5.6 Retaining a copy of the summary of the dose record received from an ADS for at least 2 years. 5.7 Conducting an investigation and report the findings to the relevant authorities after an overexposure or whenever estimated doses or special entries are required.

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5.8 Ensuring that personal dosimetry is available for classified persons or other persons where appropriate. 5.9 Ensuring that a registered medical practitioner (adequately trained and appointed by the HSE), usually a unit or establishment medical officer, is available to carry out the duties of the Appointed Doctor. 5.10 Ensuring that personnel who require adequate medical surveillance by an Appointed Doctor or employment medical adviser for the purpose of determining their fitness for work with ionising radiations receive such surveillance. 5.11 Ensuring that the Appointed Doctor undertaking medical surveillance is provided with all appropriate information on the personnel they are seeing to allow an appropriate decision on fitness to be made. 5.12 Ensuring that a health record is maintained for personnel who require medical surveillance and a copy of that record is retained until the person to whom the record relates has or would have attained 75 years of age or at least 50 years (from the date of the last entry) whichever is the later. 5.13 Ensuring that employees who have been subjected to an overexposure have their subsequent exposure to radiation adequately managed and that they are informed of the dose limit applicable for the remainder of the calendar year. Radiation Safety Officer (RSO)/Radiation Protection Supervisor (RPS)/Dosimetry Co-ordinators 6 Radiation Safety Officer/Radiation Protection Supervisor/Dosimetry Co-ordinators are responsible for: 6.1 6.2 6.3 6.4 Employees 7 Employees are responsible for: 7.1 Ensuring that they wear the personal dosimetry whenever they are working with ionising radiation. 7.2 Ensuring that they do not damage or interfere with their own or other employees personal dosimetry. 7.3 Informing their dosimetry co-ordinator if their personal dosimetry has been lost, damaged or stolen. 7.4 7.5 Storing their personnel dosimetry securely in a low background area when not in use. Attending health surveillance or required medical review. Ensuring that personnel are provided with the correct dosimetry. Completing the dosimetry administration. Instructing personnel in the correct method of wearing the dosimetry. Notifying the ADS of changes in circumstances.

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ENGAGING SUITABLE APPROVED DOSIMETRY SERVICES 8 Dosimetry services are approved by the HSE for one or more of the following specific purposes: 8.1 Measurement and assessment of whole-body or part-body doses arising from external radiation. 8.2 8.3 8.4 Assessment of doses from intakes of radionuclides. Assessment of doses following an accident or other incident. Assessment of intervention doses following a REPPIR accident.

8.5 Co-ordination of individual dose assessments, making, maintaining and keeping dose records and the provision of summary information. 9 Line managers at units which employ classified persons must have an ADS for dose assessment and dose record keeping. The RPA can provide advice about the type of radiation exposures that need to be assessed and the types of ADS that are required. Any ADS is to provide clear advice on the use of any dosemeter or other equipment supplied for making measurements and assessing dose. The ADS must be provided with sufficient information about employees to enable assessments to be made and records to be kept. 10 Details of the arrangements which must be made with the ADS are at Annex A.

11 Dstl ESD provides an integrated range of approved dosimetry services, which are approved by the Health and Safety Executive for assessing and recording dose results. Enquiries about these services can be made by telephoning Portsmouth (023) 9276 8278 or (023) 9276 8177. PERSONAL RADIATION MONITORING AND ASSESSMENT 12 Workers carrying out certain types of work or likely to receive exposures in excess of three tenths of any dose limit (see Leaflet 4) are to be designated as classified persons. Details of the requirements for classified persons are given at Leaflet 38 further information and advice is to be sought from the RPA. Once a person is classified, it is a statutory requirement that radiation exposures of that person are assessed and recorded for external radiation doses, this normally includes the use of personal radiation dosemeters issued by an ADS. 13 Within MOD, it is normal practice that unclassified persons, entering controlled areas (see Leaflet 4), are also issued with personal radiation dosemeters supplied by an ADS. Unclassified persons must only enter controlled areas under written arrangements (see Leaflet 5). In some cases, however, personal radiation dosemeters are unnecessary in these cases, the doses must still be assessed by alternative methods which must be specified in the written arrangements. RPA advice must always be sought regarding the arrangements for controlled areas (see Leaflet 7). 14 In addition to the use of personal dosemeters for external radiation exposure, there are a number of other methods of assessing personal dose which may need to be considered, particularly for internal radiation exposure. The choice of method will depend on the circumstances of individual cases, including the nature of the work and the type of radionuclide and ionising radiation involved. Assessment of committed doses arising from intakes of radionuclides into the body generally involves a combination of techniques including: biological sampling, monitoring part or whole of the body using a whole body monitor or personal air sampling.

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APPROPRIATE DOSE ASSESSMENT PERIODS 15 Often the dose assessment period will be one month, but longer periods, such as three months, may be appropriate where doses are very low. For external radiation, the choice of assessment period will depend on the dose rates to which employees are exposed, the ability of the dosemeter to measure low doses, the magnitude of the expected dose and stability of the stored image or signal on the dosemeter over time. More frequent assessment will be appropriate where there is a significant risk of accidental exposure. The longer the assessment period the more difficult it becomes to determine when and why an individuals dosemeter has received an unusually high dose in the event of an accident or other incident. SUPPLY OF PERSONAL DOSIMETRY 16 Line managers at units and establishments are to inform the Dstl ESD ADS or other ADS by signal, facsimile, telephone or in writing of their requirements for dosemeters. Requests for dosemeters are to be sent to the Dstl ESD ADS or can be made by telephoning (023) 9276 8278 or 9276 8177. 17 A description of dosimetry forms, associated documentation and their function is given in Annex A. Stocks of most of these forms are held by the Dstl ESD. ACCIDENT AND EMERGENCY DOSES 18 Under IRR99, when an accident or other occurrence takes place which is likely to result in a person receiving an effective dose (whole body dose) exceeding 6 mSv or an equivalent dose (eyes, skin, hands etc) exceeding three tenths of the relevant dose limit, immediate arrangements must be put in place for a dose assessment to be made by the ADS. Contingency planning requirements (including the need for accident dosimetry) are included in Leaflet 2. (In cases where dosimetry was not worn, the dose must be assessed by an appropriate means as soon as possible having regard to the advice from an RPA). All reasonably practicable steps must be taken to inform the employee of the result of that assessment and a record of the assessment must be kept until the employee has, or would have, attained the age of 75 or for 50 years whichever is the later. 19 Under REPPIR2001 (see Leaflet 3) when a situation necessitates an emergency plan and this plan concludes that it is reasonably foreseeable for an employee to receive an emergency exposure then the employer is to in relation to dosimetry: 19.1 19.2 Identify those employees who may be subject to emergency exposures. Provide suitable training to enable those employees to understand the associated risks.

19.3 Make arrangements for medical surveillance to be carried out without delay for employees who may have received emergency exposures. 19.4 Make arrangements with an ADS for dose assessments of emergency dosimetry for those employees who may potentially receive an emergency exposure (separate to other dose assessment systems in place). 20 In the unlikely event of a nuclear reactor accident at any of the MOD sites, the accident whole body dosemeters (normally thermoluminescent dosemeters (TLDs), which are worn by all personnel within the Exclusion Zone must be collected and urgently transported to Dstl ESD ADS. The arrangements in place to meet this objective must be clearly stated in local accident orders. 21 Emergency dosimetry (issued for the purposes of assessment of emergency exposures) must also be urgently transported to Dstl ESD ADS. The arrangements in place to meet this objective must be clearly stated in local accident orders. The ADS must send the results of the accident and emergency exposure dose assessments without delay to the employer and then the Appointed Doctor, employment medical adviser, or in the case of a nuclear reactor accident the radiation medical specialist.

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22 The ADS is to send the results of the accident/emergency exposure dose assessments without delay to the employer and then the Appointed Doctor or employment medical adviser. 23 A member of staff from the Dstl ESD dosimetry section is permanently on call and is available to assess any accident/emergency TLDs within one hour's notice. Dstl ESD ADS can be contacted on (023) 9276 8278 or 9276 8177 during normal working hours and (023) 9276 8020 at all other times. SUSPECTED HIGH DOSE 24 Whenever it is suspected that the wearer of a dosemeter has received a significant unintended whole-body, skin, extremity or eye dose, the dosemeter is to be returned to Dstl ESD dosimetry section for urgent processing. Consideration must also be given to returning a dosemeter to Dstl ESD for early processing, if the results of control dosimetry indicate that the wearer may be approaching the specified investigation levels (see Leaflet 4) or any of the annual dose limits. Such dosemeters are to be accompanied by a copy of their respective Issue Lists with the remarks column of the Issue List annotated accordingly. Furthermore, as a safeguard against irradiation of the dosemeters in transit, the outside of the package used to return either whole body or skin (extremity) TLDs is to be clearly labelled CAUTION - RADIATION DOSEMETERS - DO NOT X-RAY. 25 A Dosimetry Scientist and a Dosimetry Technician are permanently on call at Dstl ESD ADS and are available to assess any accident/emergency TLDs, normally within one hour's notice. Dstl ESD ADS can be contacted on 023 9276 8278/9276 8177 during normal working hours and 023 9276 8020 at all other times. 26 For suspected high doses the Dstl ESD ADS will normally signal or telephone the results to the unit or establishment on the day of receipt of whole body or skin TLDs at Dstl ESD ADS. Emergency assessment neutron or radon dosemeters will be processed within 7 working days. ASSESSMENT OF RADIATION DOSE FROM INTAKES OF RADIOACTIVE MATERIAL 27 Where a unit or establishment in consultation with the RPA decides that it is necessary routinely to measure biological samples from personnel working with unsealed radioactive substances or to carry out whole body monitoring, then written application is to be made to the ADS, usually Dstl ESD ADS. The procedure to be followed is to be agreed by the unit or establishment and the ADS. Dstl ESD ADS routinely undertakes tritium in urine dose assessments as part of a routine assessment of doses to personnel who may be at risk of taking in amounts of tritium during the course of their work. 28 The establishment will receive a report containing the results of assessment of radiation dose resulting from the intake of radioactive material and where appropriate the information will be recorded on the individual's dose record where it is held by the ADS Record Keeping Service, (ADRKS) usually Dstl ESD ADS. 29 If a person's skin becomes contaminated by a radioactive substance which is not readily removable by usual means, or if an intake of radioactive materials into the body is known or suspected, then a local investigation is to be undertaken involving the RPA to assess the radiation dose. 30 The Line Manager of the unit or establishment is to produce a report containing the following information: 30.1 30.2 30.3 A record of the external radiation dose sustained in the incident. An estimate of the intake or levels of skin contamination and the radionuclide(s) involved. Results of any biological monitoring tests and/or external body radioactivity monitoring test.

30.4 Circumstances of the intake or skin contamination incident and methods of physical surveillance.

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RADIATION OVEREXPOSURES 31 Where a radiation overexposure is being investigated, the individual involved must not be allowed to continue working with radiation until the results of the investigation are known. The individual is to be informed of the results of the investigation and assessment. 32 Special medical surveillance is to be carried out where a person has received a radiation overexposure in excess of 100 mSv whole body dose in a year or an equivalent dose at least twice any relevant dose limit. This person is to be referred to the Appointed Doctor regardless of whether they are a classified person, without delay. 33 A copy of each report of investigations into overexposures is to be forwarded to the ADS, usually the Dstl ESD ADS, for inclusion in the individual's FMed 291-A (envelope containing radiation dose records). These reports are to be kept indefinitely. DOSE LIMITATION FOR OVEREXPOSED WORKERS 34 The dose limitation for the remainder of a calendar year for a radiation worker who has been overexposed in that year and has not been withdrawn from radiation work by the recommendation of the Appointed Doctor, is the proportion of the calendar year remaining from the end of the dose assessment period multiplied by any annual dose limit. DOSIMETRY RECORDS 35 Units and establishments are to maintain the following radiation dose records: 35.1 An FMed 291A, medical envelope for each classified person and unclassified person wearing dosimetry employed at the unit or establishment. The envelope is to contain: 35.1.1 All Radiation Dose Record Summaries. 35.1.2 FMed 291E - copies of personal details forms. 35.1.3 Copies of results of any internal dose assessments. 35.1.4 Copies of reports of investigations made. 35.1.5 FMed 291F Health Record. 35.1.6 Transfer records. 35.1.7 Copies of the results of dose assessments of personal dosemeters issued by an Approved Dosimetry Service. 35.1.8 Copies of the results of assessment doses received while working under written arrangements and while not wearing dosemeters issued by the establishment ADS, usually the Dstl ESD ADS. 35.2 Where appropriate maintain a radiation passbook for classified persons if employed as an outside worker. 35.3 Laboratory Certificates issued by the ADS, usually the Dstl ESD ADS, for each person, including visitors and classified persons and unclassified persons, who have worn a dosemeter at the unit or establishment at any time during the previous two years. 35.4 Dose assessments by personal dosemeters issued by an ADS, for workers who are not classified persons. 35.5 Any assessments of doses of unclassified persons working under written arrangements.

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35.6 Any assessment of biological samples provided by classified persons or unclassified persons. If an FMed 291A has been raised it is to contain copies of these assessments. 36 The PD2 label readily identifies that the individual has been employed as a classified person and must be attached to their FMed 291A dosimetry record and their central personnel file and, in the case of uniformed personnel, the personal medical documents, to ensure that a termination record is raised. OUTSIDE WORKERS 37 MOD classified persons required to carry out services in a controlled area designated by another employer are referred to as outside workers. Similarly, when classified persons who are not employed by the MOD are required to enter a MOD designated controlled area, the non-MOD classified person would be the outside worker. Line Managers are to seek advice from the RPA on the circumstances in which classified persons should be designated as outside workers. The responsibilities and duties of the outside worker, their employer and the operator of the controlled area must be formally agreed before any work is undertaken. 38 Any employee who fulfils the criteria for outside workers will need an approved radiation passbook. These can be obtained from the ADS, usually Dstl ESD ADS. The radiation passbook is to be kept up to date at all times. 39 Units and establishments that allow outside workers of other employers to enter or work in their controlled areas will need to provide quick and simple estimates of the doses they receive while working in those controlled areas and arrange to enter those estimates in radiation passbooks as soon as practicable. COMPENSATION SCHEME AND COUNSELLING SCHEME 40 The MOD at the request of the trade unions is a member of The Compensation Scheme for Radiation Linked Diseases (the Scheme). The Scheme provides an agreed method of determining whether compensation should be paid in relation to MOD radiation workers who have developed certain types of cancer or cataracts which may be linked with exposure to ionising radiation at work. 41 The Scheme is entirely voluntary; claimants can choose whether to use the scheme or to take legal action. The use of the Scheme is recommended by the trade unions. Potential claimants may apply through the appropriate trade union or (as with Armed Services Claimants) to the Compensation Scheme Executive Secretary, British Nuclear Fuels plc, Risley, Warrington, Cheshire WA3 6AS (Telephone Number: 01925 - 832706). It should be noted that former service men and women are also entitled to apply to the Veterans Agency, though any award would take account of compensation received from other sources. The address is: Veterans Agency, Norcross, Blackpool, FY5 3WP (Helpline: (UK) 0800 1692277, (abroad) +44 1253 866043). 42 All Ministry of Defence radiation workers, former radiation workers and their families who have concerns about health effects arising from their exposure to radiation during MOD employment are eligible for counselling and may obtain radiation dose summaries. Radiation workers who do not want counselling but wish to obtain a summary of their radiation exposure may also do so under these arrangements. Counselling will provide an opportunity to discuss concerns with someone medically qualified to advise. The counselling does not involve any medical examination, or any form of medical surveillance or screening. NATIONAL REGISTRY FOR RADIATION WORKERS 43 A National Registry for Radiation Workers (NRRW) is maintained by the Health Protection Agency. Arrangements have been made for radiation workers in HM Forces and MOD civilian employees in possession of a National Insurance Number to participate in the National Register, subject to security safeguards and the right of an individual to opt out.

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44 Annex D provides an explanation of the arrangements for participating in the NRRW scheme, and a copy is to be given to each radiation worker whether Service or civilian personnel on commencement of radiation work. Any radiation workers may, if they wish, choose not to join the National Registry, otherwise at the end of the calendar year their name and information listed in Annex D will be made available to the National Registry. 45 Individuals wishing to opt out of the scheme are to write to their CO who will forward their request together with the individual's Personal Dosimetry (PD) number to Dstl ESD within 2 weeks of its receipt. Copies of requests to opt out will be incorporated in the individuals FMed 291A (radiation history envelope). MEDICAL SURVEILLANCE AND APPOINTED DOCTOR 46 COs of units where classified persons are employed or where employees, classified or otherwise, have received an overexposure or where employees are engaged in work with ionising radiation subject to conditions imposed by an Appointed Doctor (AD) must ensure that they have a registered medical practitioner available to carry out the duties of the AD. 47 The CO must ensure that each of the employees described above is under adequate medical surveillance by an AD for the purposes of determining the fitness of each employee for the work with ionising radiation which they are to carry out. Adequate medical surveillance, taking into account the nature of the work and the individuals state of health, includes: 47.1 47.2 A medical examination before first being designated as a classified person. Periodic health reviews at least once per year.

47.3 Special medical surveillance of an employee when a relevant dose limit has been exceeded. 47.4 Determination of whether specific work conditions are needed.

47.5 A review of health after cessation of work where this is necessary to safeguard the health of the individual. 47.6 A special medical examination for any person exceeding an effective dose of 100 mSv in a year or an equivalent dose of twice any relevant annual dose limit. 48 Only persons certified fit for radiation work by the signed entry of the AD in the health record within the preceding 12 months (+ or 1 month) are to be employed as classified persons. Where the AD certifies that an employee should be subject to certain conditions, the CO must ensure that work is carried out in accordance with those conditions. 49 The Appointed Doctor must, in the UK, be appointed by the Senior Medical Inspector (SMI) at the Health and Safety Executive (HSE) area office. The HSE certificate of appointment specifies the site or undertaking for which the appointment is valid. The AD does not necessarily have to be employed permanently at the site. More than one doctor maybe appointed by the HSE for any particular site. 50 MDG(N), DGAMS and DGMS(RAF) will provide details of the appropriate AD for any particular location. All appointments are to be notified to the appropriate single service Medical Directorates. The tri-Service focal point for all radiation medicine issues is located at the Institute of Naval Medicine. The focal point can be contacted on 023 9276 8085 or 9276 8026 during normal working hours and 023 9276 8020 at all other times.

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51 The minimum requirement to satisfy the relevant SMI is attendance on a one day course covering the Ionising Radiations Regulations 1999 (IRR99), the health effects of ionizing radiations and the practical aspects of providing medical surveillance to a syllabus set out by the HSE. The tri-Service Senior Medical Officers Radiation Medicine Course and the Appointed Doctors one day course cover this syllabus. Course details and application for attendance are to be addressed to the tri-Service focal point. 52 Outside the UK, doctors who would otherwise require appointment are to receive the same information, instruction and training. 53 Detailed guidance on medical surveillance is provided at Annex E.

RECORD RETENTION PERIODS 54 IRR99 specifies retention periods for certain records, in some cases MOD policy requires records to be kept for a longer period. Record retention periods are as follows: 54.1 Retained indefinitely: 54.1.1 Dose assessments for unclassified persons (MOD policy). 54.1.2 Dose assessments for unclassified persons working under written arrangements, forward to archive on closure of unit (MOD Policy). 54.1.3 Medical envelope and contents FMed 291A (forward to Dstl ADS when worker leaves the unit (MOD policy). 54.1.4 Record of investigations carried out to make special entries in the dose record. 54.2 Retained until worker attains, or would have attained, 75 years or for 50 years, whichever is longer: 54.2.1 Health Record (statutory). 54.2.2 Dose assessments for classified persons (statutory). 54.2.3 Termination records - copy provided to worker on leaving employment (statutory) retained until worker attains 75 years, or for 50 years if longer by ADS (MOD policy). 54.2.4 Dose assessments made as a result of an accident or incident (statutory). 54.2.5 Record of investigations carried out to make special entries in the dose record. 54.3 Retained for 2 years: 54.3.1 Record of investigations carried out to make special entries in the dose record (2 years from date of investigation) (statutory). 54.3.2 Summary dose record (i.e. monthly radiation dose reports) (2 years from the end of the calendar year to which the report relates) (statutory).

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RELATED LEAFLETS 55 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related leaflets Leaflet Number 2 3 Leaflet Title

Risk Assessments Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Restriction of exposure to radiation Written arrangements for unclassified persons entering controlled areas Radiation Protection Adviser consultation and advisory visits Classified persons and outside workers Contingency plans

4 5 7 38 40

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LEAFLET 6 ANNEX A GUIDANCE FOR LINE MANAGERS AND EMPLOYEES ON TYPES OF DOSEMETER, DOSEMETER CARE, THE ADMINISTRATIVE ARRANGEMENTS FOR DOSIMETRY SUPPLY, THE ASSOCIATED DOSIMETRY RECORDS AND MEDICAL DOCUMENTS CONTENTS Para

2 3 8 18 20 21 24 26 27 32 34 35 36 38 40 Table A1

Introduction For classified persons For other persons Commencement of radiation work Supply of dosemeters and personal dosimetry forms Types of dose assessment provided by Dstl ESD Approved Dosimetry Services Use of DSTL ESD radiation dosemeters Dosemeter wear Care of radiation dosemeters Lost or damaged dosemeters Irradiated dosemeters Issue and return of dosemeters Completion of the Dstl ESD dosemeter issue list Issue of Dstl ADS dosemeters to personnel in receipt of dosemeters issued by another employer Casual visitors Notification of changes in circumstances Completion of radiation work at an establishment Description of Dstl ESD ADS forms and associated medical forms and documents Page Period of wear for personnal dosemeters ....................................................................................7

INTRODUCTION 1 Dstl ESD Record Keeping service is approved by the Health and Safety Executive under the terms of the Ionising Radiations Regulations (1999). The scope of the services provided is summarised below: For Classified Persons 1.1 Dstl ESD will make and maintain dose records in accordance with the requirements of the Ionising Radiations Regulations 1999 (IRR99) and will keep those dose records (or a copy) until the person to whom the record relates has or would have attained the age of 75 years but in any event for at least 50 years from the last entry. The onus is on the unit or establishment to furnish Dstl ESD with completed record keeping registration forms (FMed 291E forms) to initiate this process. These forms will be provided by Dstl ESD. 1.2 Following the assessment of personal dosemeters, Dstl ESD will provide summaries (Laboratory Certificates) of the doses assessed. Shortly after the end of each calendar quarter, individual Radiation Dose Record Summary Reports will be issued for each person monitored during the period. 1.3 Dstl ESD will provide the unit or establishment with such copies of the dose records relating to any of their employees as they may require.

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1.4 Dstl ESD will notify the unit or establishment in the form of a warning report when any individual exceeds 30% of any legal dose limit. In addition, a warning report will be issued when any individual exceeds 30 mSv whole body dose in any 5 year period. Dstl ESD will also inform the unit or establishment by a warning report when any assessed individual's annual cumulative whole body radiation dose exceeds 4.5 mSv and at 6 mSv or greater. For pregnant females, a warning report will be issued when the whole body radiation dose exceeds 0.75 mSv over the declared term of the pregnancy. 1.5 Dstl ESD will notify the unit or establishment in the form of an over-exposure report when any individual exceeds a legal dose limit as detailed in Leaflet 4. In addition, the unit or establishment will be immediately notified of an over-exposure by telephone or signal. 1.6 If the employer has agreed to participate in the National Registry for Radiation Workers, Dstl ESD will provide the necessary data to the Health Protection Agency to service the scheme for their employees. 1.7 Dstl ESD, when advised by the unit or establishment of termination of employment, will raise a termination record relating to a person who ceases to be an employee. Dstl ESD will send that record to the Health and Safety Executive as required by the legislation, and a copy to the employee. 1.8 Dstl ESD will, within 3 months of the end of each calendar year, send to the Health and Safety Executive summaries of all current dose records relating to employees for that year. 1.9 At the request of the Health and Safety Executive, Dstl ESD will provide them with copies of any employee's dose record. Dstl ESD will notify the establishment and the appropriate TLB safety authority (e.g. the CESO for the TLB area) that HSE have made this request. 1.10 Where a unit or establishment requires an employee to be designated as a classified person and that employee has records relating to previous employment in radiation work, Dstl ESD will enter the recorded historical doses on to Dstl ESD ADS Database. The unit or establishment is responsible for providing Dstl ESD with a detailed breakdown of previous radiation exposures. For Other Persons 1.11 For persons who are not designated as classified persons but are registered with the Dstl ESD ADS, Dstl ESD will undertake Paragraph 1.1-1.6 inclusive. The Dstl ESD ADS will notify the unit or establishment when an unclassified individual receives an annual cumulative whole body dose exceeding 2 mSv and at 4.5 mSv or greater. For pregnant females, a warning report will be issued when the whole body radiation dose exceeds 0.75 mSv over the declared term of the pregnancy. 1.12 For persons such as casual visitors and persons working under written arrangements who are not registered with the Dstl ESD ADS, the assessed doses will be provided on monthly dose summaries (Laboratory Certificates). No Radiation Dose Record Summaries will be issued for these personnel. COMMENCEMENT OF RADIATION WORK 2 The following actions are to be taken by the unit or establishment for all persons whose radiation doses are assessed and radiation records maintained by the ADS, usually Dstl ESD ADS; 2.1 Submit a fully completed Personal Details Form (FMed 291E) to the ADS. Where appropriate, annotate NEW WEARER - FMed 291E ENCLOSED, PUT ON REGULAR ISSUE on the remarks section of the Dstl ESD Dosemeter Issue List. 2.2 Provide the person with a copy of Annex D.

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2.3 For personnel involved in radiation work with another employer, obtain written details of their radiation dose histories (broken down by year) from their previous employer and forward to the ADS for inclusion on their current dose records. It is essential that as much dose information as possible is forwarded to the ADS. For radiation workers who have been employed as classified persons by their previous employer, the actions specified in paragraph 2.4.3 will fulfil this obligation. 2.4 For classified persons commencing radiation work: 2.4.1 If the person is to become a classified person, the employer (Commanding Officer) must notify them in writing to that effect. 2.4.2 Arrange for a medical examination, if required, as described in Annex E.

2.4.3 For persons previously employed as classified persons by outside organisations obtain a copy of the termination record and forward it to the Dstl ESD Record Keeping Service. A copy of the termination record should be in the person's possession but a copy may be obtained either from their previous employer or from: The Health and Safety Executive Central Index of Dose Information Health Protection Agency Chilton Didcot Oxon OX11 ORQ 2.4.4 For persons employed as classified persons who wore Dstl ESD personal dosemeters obtain the FMed 291A envelope containing dose records from the previous unit or establishment or from Dstl ESD Record Keeping Service. 2.4.5 For personnel being designated as classified persons for the first time, ensure that a PD2 label is attached to their FMed 291A dosimetry record and their central personnel file and, in the case of uniformed personnel, the personal medical documents. This will ensure that a termination record is raised when they leave MOD employment. 2.4.6 Where appropriate, request a radiation passbook be issued to the individual by Dstl ESD Record Keeping Service if the classified person will be employed as an outside worker (see Annex C). SUPPLY OF DOSEMETERS AND PERSONAL DOSIMETRY FORMS 3 Units and establishments are to inform the Dstl ESD ADS or other ADS as appropriate, by signal, facsimile, telephone or in writing of their requirements for dosemeters. Dosemeter Issue Lists returned to the ADS may be used for this purpose and these Issue Lists are to contain sufficient information to enable the ADS to anticipate the unit or establishments future dosemeter requirements. It should be noted that information provided on a Issue List returned to the Dstl ESD ADS might not be processed until after a further two issues have been dispatched. Therefore this option is not to be chosen for cases where an immediate change is required. 4 Normally, orders for dosemeters will be treated as monthly standing orders until countermanded. Whenever possible, one month's notice should be given of changes in dosemeter requirements. Issue Lists are to be scrutinised routinely by the unit or establishment to prevent under/over-ordering of dosemeters. 5 Establishments with only unclassified personnel, who wear dosemeters infrequently and irregularly, may by arrangement with Dstl ESD ADS, receive and return dosemeters at specified time periods other than one month. 6 A description of dosimetry forms, associated documentation and their function is given below. Stocks of most of these forms which are required by the user are held by Dstl ESD ADS.

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7 Requests for dosemeters, radiation passbooks or dosimetry forms are to be sent to the Dstl ESD ADS, or can be made by telephoning 023 9276 8278 or 9276 8177. TYPES OF DOSE ASSESSMENT PROVIDED BY DSTL ESD APPROVED DOSIMETRY SERVICE 8 Line managers and employees are to be aware of the types of dosemeter available from the Dstl ESD ADS, however the RPA should provide the advice on which type of dosemeter that is suitable for a particular task. Employees are to be made aware of their duties and responsibilities for the correct method of wear and care of the dosemeters. 9 The Dstl ESD ADS supply: 9.1 9.2 9.3 9.4 9.5 9.6 9.7 9.8 9.9 9.10 10 Whole-body TLDs. Accident TLDs. Emergency whole-body TLDs. Skin/extremity TLDs. Planar neutron dosemeters. Personal radon dosemeters. Environmental radon dosemeters. Tritium-in-urine sampling kits. Uranium-in-urine sampling kits. Whole body monitoring.

Instructions are supplied by the Dstl ESD dosimetry section for use of the above dosemeters.

11 Whole-body TLDs contain a 4-element TLD card inserted in to a filtered holder are pre-assembled by Dstl ESD ADS . These dosemters are used to assess personal exposure from , and X-radiation to the skin, and from and X-radiation to the whole body. Instructions for wearing and taking care of whole-body TLDs are given below. 12 Dstl ESD issues two types of whole-body TLD, the Harshaw 8840 and 8814, which are described below: 12.1 The 8840 TLD is issued for routine whole-body dose assessment. detection of 20 Sv and is distinguished by the blue stripe on front of the holder. It has a limit of

12.2 The 8814 TLD is issued for accident and emergency whole-body dose assessment. It has a limit of detection of 50 Sv and is distinguished by the white stripe on the front of the holder. 13 Skin/extremity TLDs are provided for assessing personal exposure from , and X-radiation to the hands, forearms, feet and ankles or to the lens of the eye. Instructions on how to wear the skin TLD are given below. 14 Dstl ESD neutron dosemeters in their holders assess personnel exposure of personnel to neutron radiation. Instructions on how to wear the neutron dosemeter is given below. 15 Whole-body and skin TLDs can be used for the majority of experimental purposes. Advice can be obtained from the Dstl ESD or the RPA on the suitability of each TLD.

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16 Personal radon dosemeters are used to assess personal exposure to radon gas. Environmental radon dosemeters are used to assess radon exposure at work or in married quarters. Instructions on how to wear the radon dosemeters are given below. 17 For all practical purposes, doses of radiation are additive and the assessment of personal dose is to include, whenever necessary, the assessment of external dose, and the assessment of dose from any intake of radionuclides into the body. USE OF DSTL ESD RADIATION DOSEMETERS 18 The RSO or RPS is to ensure that any special instructions issued by the Dstl ESD ADS with regard to the use and care of dosemeters are carried out. 19 Every effort must be made, to prevent wilful or negligent misuse of radiation dosemeters.

DOSEMETER WEAR 20 Specific instructions are issued by Dstl ESD ADS on how each of the dosemeters is to be worn: 20.1 Whole Body TLDs. These dosemeters are used for measuring whole-body dose and are normally to be worn on the front of the chest outside the normal coverall or other protective clothing (this does not include protective lead-rubber aprons). RSOs and RPSs are to instruct and periodically check that users wear the holder correctly. 20.2 Dstl ESD Neutron Dosemeters. These dosemeters are used for measuring whole-body dose and are normally to be worn on the front of the chest outside the normal coverall or other protective clothing (this does not include protective lead-rubber aprons). RSOs and RPSs are to instruct and periodically check that users wear the holder correctly with the window showing the dosemeter number facing away from the body of the wearer. 20.3 Skin/Extremity TLDs. These dosemeters are to be attached to the relevant extremity or skin area to be monitored. Dedicated attachments are provided when they are used to assess doses to the fingers. If tape is used to attach the dosemeter, then care is to be taken to ensure that it does not cover the central part of the dosemeter containing the TLD element. 20.4 Radon Dosemeters. These dosemeters should either be attached to a helmet (if worn) or to a belt on outer clothing to enable the radon gas to enter the detector. CARE OF RADIATION DOSEMETERS 21 The following precautions are to be taken with all Dstl ESD radiation dosemeters. The individual wearing the dosemeter must: 21.1 Wear it properly in the radiation area.

21.2 Store it in a low background area, remote from any known sources of ionising radiation when not being worn. 21.3 Not shield it in any way. Pens, rulers or other metallic objects may shield the dosemeter.

21.4 Not immerse the dosemeter in any liquid. Particular care is to be taken to remove dosemeters from clothing before laundering. Divers are to wrap their dosemeter in two plastic bags and wear the dosemeter inside their wet suit. 21.5 21.6 21.7 Keep the dosemeter away from high temperatures, e.g. pipes and radiators. Not share the dosemeter with anyone else. Not damage the dosemeter or holder in any way.

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21.8

Not carry the dosemeter in close proximity to luminized watches or other luminized articles.

21.9 Return the dosemeter promptly at the correct time, ensuring that a replacement is available before giving up the old one, if necessary. 21.10 Notify the supervisor, RSO or RPS immediately, if it is lost or mislaid, especially in a radiation area (even if it is later found) as the employer may need to estimate the individual's dose. 21.11 Ensure that the dosemeter is not worn inadvertently during medical/dental X-ray examinations. 22 In addition, for whole-body TLDs, consideration is to be given to encapsulating the dosemeter in polythene (approved by the Dstl ESD dosimetry section) whenever the dosemeter is worn in areas where: 22.1 22.2 Significant contamination exists. Humid or damp conditions occur.

22.3 Corrosive or chemically reactive gases or vapours including tear gas or hydrogen sulphide are present. 23 Radon dosemeters must be kept away from any neutron sources and equipment with high EHT operating voltages. LOST OR DAMAGED DOSEMETERS 24 When dosemeters have been lost, damaged or destroyed during the normal wear period, the unit or establishment is to annotate the Remarks/Changes Required column of the Dosemeter Issue List accordingly. The unit or establishment is to investigate the circumstances of the loss, damage or destruction of the dosemeter and forward an estimate of the dose to the ADS, usually Dstl ESD ADS using ADS Form 94, covering the period that the dosemeter was worn (further guidance on dose investigations is given at Annex B). The estimated dose is to be supported by readings from other dosemeters worn during the period or by documented evidence that would permit the ADS to insert an estimated dose in the record. For example, if there has been no significant change to either the type or frequency of radiation work undertaken by the above personnel during the specified wear period and previous wear periods, an estimated dose may be obtained by averaging the individual's three previous dose results. The unit or establishment is to ensure that any measurements used to estimate dose are recorded and kept for a period of at least two years and take reasonable steps to inform the employee of the dose estimate to be entered on to the dose record. If the lost dosemeter is subsequently found, it must be forwarded to the ADS, usually Dstl ESD ADS, accompanied by an investigation report giving all relevant details. When the recovered dosemeter has been lost in a suspected high radiation area the ADS must be informed as soon as possible and advised not to incorporate the dose result into the individual's dose record. 25 Where the unit or establishment has investigated the loss or damage to a dosemeter and no estimated dose can be provided, the ADS will enter a notional dose into the individual's radiation record. A notional dose is obtained from the proportion of the annual dose limit for the dosemeter issue period. Notional doses will only be entered into individual dose records in exceptional circumstances when it has not been possible to provide proper estimates of dose.

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IRRADIATED DOSEMETERS 26 If it has been suspected that a dosemeter has been inadvertently irradiated, the unit or establishment is to annotate the Remarks / Changes Required column of the Dosemeter Issue List with the following note; This dosemeter has been irradiated, please see attached ADS Form 94. An estimated dose form is to be completed and returned at the same time as the dosemeter to allow the estimated dose to be entered. Failure to do so may result in a special entry dose being awarded in replacement of the assessed dose - see guidance in Annex B to this leaflet. ISSUE AND RETURN OF DOSEMETERS 27 The RSO or RPS is to co-ordinate all arrangements for personal monitoring.

28 The normal wear period for each type of personal dosemeter is detailed in Table 1. Dosemeters are normally to be worn starting from the calendar month for which they have been issued, unless advised specifically otherwise by the RPA. Dedicated accident or emergency dosemeters, which are not used for routine personal monitoring purposes, are issued every six months by Dstl ESD ADS. The previous issue of dosemeters is to be returned immediately to the Dstl ESD ADS following receipt of the next issue. Table A1 Period of wear for personal dosemeters Dosemeter Type
(1) (2)

Wear Period 1 month 6 months Duration of intervention 1 month 3 months 3 months

Whole-body (routine) TLD Whole Body (accident) TLD

Whole body (emergency) TLD Skin/extremity TLD


(3)

Dstl neutron dosemeter Radon dosemeter

(4)

NOTES (1) Routine whole body TLDs are generally issued for one month although this may be extended to cover two or three monthly periods. Whole body TLDs used for environmental monitoring may also be issued over an extended periods. (2) Dedicated accident whole body TLDs, which are not used for routine personal monitoring are generally issued every 6 months by Dstl ESD unless an accident occurs in that period. (3) (4) Routine neutron dosemeters may also be issued over one monthly periods but see below. Environmental radon detectors are generally issued for a 3 month period.

29 As stipulated above, Dstl ESD personal neutron dosemeters are generally worn for three months. For instances where it is anticipated that an issue period greater than three months may be required, it is recommended that the extended wear period is kept to a minimum and is never to exceed a total of four months. This is because it is very difficult to make an accurate dose assessment beyond the normal wear period due to the methods which must be used for the calibration of neutron dosemeters.

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30 All dosemeters (including those unused or damaged) are to be returned promptly for assessment to Dstl ESD ADS together with the completed Dosemeter Issue Lists at the end of the wear period. The returned Dosemeter Issue Lists are to be clearly annotated to indicate any changes which the unit or establishment requires to be made to the original Issue List. These changes are to be annotated in the Remarks/Changes Required column of the Issue List. Dosemeters which will not to be used for the wear period are not be returned early. 31 Units and establishments are to inform Dstl ESD dosimetry section, before dispatch, of any dosemeters that are considered to be contaminated. Advice is to be sought from Dstl ESD on the method of returning such dosemeters. COMPLETION OF THE DSTL ESD DOSEMETER ISSUE LIST 32 Instructions for completing Dstl ESD Dosemeter Issue Lists are contained on the form itself. Further advice on completing the Dosemeter Issue List may be obtained from the Dstl ESD ADS. 33 Female workers who have declared their pregnancy to the employer are subject to a radiation dose constraint such that the dose to the foetus does not exceed 1 mSv during the remainder of the pregnancy. Units and establishments are therefore to inform the Dstl ESD ADS by annotating the Remarks/Changes Required column of the Dosimetry Issue List with the expected date of delivery. Dstl ESD ADS will annotate the remarks section of the Radiation Dose Record Summary with the radiation dose received during the pregnancy term, to enable the employer to monitor the individual throughout the term of her pregnancy. ISSUE OF DSTL ESD ADS DOSEMETERS TO PERSONNEL IN RECEIPT OF DOSEMETERS ISSUED BY ANOTHER EMPLOYER 34 Personnel in receipt of dosemeters issued by another employer (such as Territorial Army, Royal Naval Reserve and Royal Air Force Reserve staff who work for other employers as well as MOD) must be issued with dosemeters provided by the ADS for the period of working with ionising radiation when attached to the MOD. These personnel are to complete a Personal Details Form FMed 291E which is to be forwarded to the Dstl dosimetry section. The completion of this form will facilitate co-operation between employers and ADS to ensure that radiation doses records and dose limits are maintained. CASUAL VISITORS 35 Units and establishment are to issue radiation dosemeters to casual visitors unless alternative instructions are contained in local orders. For each casual visitor issued with a Dstl ESD ADS personal dosemeter the following actions are to be taken: 35.1 The visitor is to complete a Personal Details Form FMed 291E which is to be forwarded to the Dstl ESD ADS, or, 35.2 The number 4 is to be entered into the category column of the Dstl ESD Dosemeter Issue List for the dosemeter. 35.3 Accident dosemeters may be issued to visitors and contractors in submarines. These dosemeters are not issued for routine dose assessment purposes and may be reissued to other visitors during the six monthly issue period. NOTIFICATION OF CHANGES IN CIRCUMSTANCES 36 A completed Personal Details Form (FMed 291E) is to be forwarded to Dstl ESD when any of the following occur for personnel registered with Dstl ESD Record Keeping Service: 36.1 There is a change in personal details, such as surname on marriage or job as described in the job code, or change of permanent employer address. 36.2 A worker restarts radiation work.

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36.3 An individual who is designated as a classified person leaves MOD employment for any reason. In such circumstances a termination record for the individual is to be requested from the Dstl ESD Record Keeping Service and a forwarding address is to be provided to enable a copy of the termination record to be forwarded to the individual. 36.4 36.5 On notification of death of a current radiation worker. The Dstl ESD personal dosimetry number or alternatively service number is unknown.

36.6 The worker has been redesignated from an unclassified radiation worker to a classified person. 36.7 An individual becomes unclassified.

37 In circumstances where it can be stated in writing by the RSO or RPS of the unit or establishment concerned that an individual who has been declassified is extremely unlikely to resume work with ionising radiations during their future employment with the MOD a termination record for the individual is to be requested from the ADS. Individuals may only be declassified at the end of the calendar year, unless an Employment Medical Adviser or Appointed Doctor states otherwise in the health record or the individual is no longer employed in a capacity which is likely to result in significant exposure to ionising radiation during the remainder of the relevant calendar year. Any further occupational radiation exposure received by any such person must be monitored using a radiation dosemeter issued by the ADS and the dose recorded in the individual's dose record. COMPLETION OF RADIATION WORK AT AN ESTABLISHMENT 38 Classified persons. The unit or establishment is to undertake the following tasks for each classified person registered with an ADS, usually Dstl ESD ADS, who ceases radiation work at an establishment: 38.1 For individuals leaving MOD employment, submit a Personal Details Form FMed 291E to the Dstl ESD ADS requesting a termination record including a forwarding address and the date of employment termination. This also applies to persons who have previously been designated as classified persons, which is to be indicated by the attachment of a PD2 label to their central personnel file or FMed 291A if uniformed personnel. 38.2 If the individual is leaving MOD employment, delete their name from the pre-printed Dstl ESD ADS Issue List and add the following text in the remarks column Left MOD - Please take off regular issue. If the individual is ceasing radiation work at an establishment but continuing employment with MOD, delete their name from the pre-printed Dstl ESD Issue List and add the following text in the remarks column; Posted/transferred - please take off regular issue. 38.3 Forward the individual's dose records and radiation passbook (if issued) to the employees next employer if known or if not return the documents to the Dstl ESD ADS. 38.4 Inform the individual in writing if they have ceased to be a classified person. Classified persons are only to be declassified at the end of a calendar year, unless otherwise required by the Appointed Doctor or they are going to be employed in a capacity unlikely to result in significant exposure to ionising radiation during the remainder of the year. 38.5 For classified persons continuing employment with MOD, ensure that a PD2 label is attached to the relevant documents for the individual. 38.6 Individuals who are ceasing employment and have never been designated as classified persons may receive a Radiation Dose History report from Dstl ESD ADS. 39 Unclassified persons For any individual who has at any time during their MOD employment been employed as a classified person, the RSO at the unit or establishment is to submit a Personal Details Form FMed 291E for the individual to Dstl ESD ADS to request a termination record. A forwarding address for the individual is also to be included.

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DESCRIPTION OF DSTL ESD APPROVED DOSIMETRY SERVICE FORMS AND ASSOCIATED MEDICAL FORMS AND DOCUMENTS 40 The Dstl ESD ADS produces several dedicated forms to assist MOD personnel with the administration of dosimetry services. The Dstl RPS forms and related MOD medical documents together with their uses are described as follows: 40.1 Dstl ESD Laboratory Certificate This form is issued to each unit or establishment following assessment of returned dosemeters or input of internal dose assessments on to the Dstl ESD ADS Database. The Laboratory Certificate provides a summary of all the dose assessments and must be retained by the unit or establishment for 2 years from the date of issue. 40.2 Radiation Dose Record Summary Reports (formerly Quarterly Dose Reports) Dstl ESD issues these person-specific reports shortly after the end of each calendar quarter for all individuals who have been monitored during that period. In addition, the fourth quarter's report is produced for individuals having any dose assessments included on their dose record during that calendar year. The Radiation Dose Record Summary report is forwarded automatically to the RSO or RPS. For classified persons the form is to be filed in the separate radiation FMed 291A envelope. In the case of other personnel it can be destroyed after 2 years. The form shall be available to the RSO or RPS and the Appointed Doctor and may be inspected on request by the individual to whom it refers. 40.3 Form FMed 291F (Health Record) The health record is used to report on the fitness of an employee for designation as a classified person. In the UK the second part can only be completed only by an Appointed Doctor. The record is to be kept in the custody of an appropriate person and is to be made available to any person who is authorised to examine it. 40.4 Form FMed12 (request for special medical examination (or its civilian equivalent) This form is to be used for blood-examination reports and is to be dealt with as follows: 40.4.1 The Appointed Doctor shall enter the result of the examination on Form FMed 291C and take appropriate action. 40.4.2 The original form is to be placed in the FMed 4. 40.5 Form FMed 291A (medical envelope) This form is provided for establishments to retain all the relevant radiation dose records and associated documents. The unit or establishment is to maintain a Form FMed 291A for classified persons or persons who have previously been designated as classified persons. On transfer of such individuals within the MOD, the FMed 291A and all the enclosures held by the unit or establishment are to be forwarded to the next establishment if they are to continue radiation work, or returned to the Dstl ESD ADS. 40.6 Form PD2 (gummed slip for FMed 291A and central personnel file) The PD2 label readily identifies that the individual has been employed as a classified person and must be attached to their FMed 291A dosimetry record and their central personnel file and, in the case of uniformed personnel, the personal medical documents, to ensure that a termination record is raised. To facilitate this, Dstl ESD will issue copies of form PD2 on request from the RSO or RPS, and must be used on the first occasion that an individual is designated a classified person. 40.6.1 This form is a small gummed label which specifies that: This person has been employed as a classified person. On discharge from service, Dstl ESD Approved Dosimetry Service is to be informed in accordance with the Regulations so that a termination record can be raised. PD No......... This slip is to be attached to the personal file of the individual concerned. The original file held in the employing department is to be used for this purpose, and it is the responsibility of the employing department to inform the Dstl ESD when the individual leaves the service as part of their discharge procedure.

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40.7 Form FMed 291C (medical examination record) This form shall be treated as RESTRICTED-MEDICAL and shall be used to record the following information for classified persons: 40.7.1 Pre-engagement medical examination. 40.7.2 Annual health reviews. 40.7.3 Special medical examination (e.g. ophthalmic). 40.8 Form FMed 291D (radiation record summary card) This form must be completed by the parent establishment and issued to all relevant persons working away from their normal MOD station or when such persons are transferred temporarily or permanently to a different MOD place of work. It shall carry the PD number of its bearer. The RSO or RPS issuing dosemeters to classified persons or workers under written arrangements shall examine this card, use the PD number as necessary and complete the appropriate columns before the individual returns to their normal MOD station. 40.9 Radiation Passbooks Radiation passbooks are issued to classified persons who are required to undertake work in a controlled area designated by another employer. These are available from the Dstl ESD ADS for MOD classified persons, they are either allocated directly to an individual or issued to MOD establishments who will allocate them. The radiation passbook has a unique serial number and is not transferable. Further information on the use of radiation passbooks is given in Annex C. 40.10 Form FMed 291E (personal details form) This form is used to register MOD radiation workers with the Dstl ESD Record Keeping Service. The form must be completed by the individual before any radiation dose assessments are undertaken. Full instructions are given on this form which must be completed as fully as possible and forwarded to the Dstl ESD Record Keeping Service. Personal Details Forms do not need to be raised if the individual has previously been registered with the Dstl ESD Record Keeping Service provided that their PD number is known and forwarded to Dstl ESD ADS, however, changes to occupational codes or classification are to be notified on an FMed 291E. 40.11 Dstl ESD Dosemeter Issue List The purpose of the Dstl ESD Issue List is to ensure that the results of radiation dose assessments, as recorded by personal dosemeters, are recorded in the correct radiation dose record. The Dstl ESD Dosemeter Issue List is issued together with Dstl ESD dosemeters. The Issue List contains details of the dosemeter type, dosemeter serial number, issue period and where appropriate, details of the dosemeter wearer. Generally, dosemeters which have not been pre-allocated to an individual may be issued to visitors, newly posted individuals or used for environmental monitoring purposes. 40.12 ADS Form 94 This form is used to provide the ADS with an estimated dose in the event that a dosemeter is lost or damaged. 40.13 Dstl ESD Warning Reports/Overexposure Reports In addition to the monthly summaries (Laboratory Certificates) of dose results provided to each customer, Dstl ESD ADS also provides Over-exposure Reports and Warning Reports for any person registered with the Record Keeping Service who has exceeded a relevant dose threshold. These reports are dispatched with the Laboratory Certificates.

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40.14 Termination Records There is a statutory requirement for the Dstl ESD ADS to raise a Termination Record whenever a person who is or has been designated a classified person leaves the MOD. The Termination Record summarises the radiation exposure for the individual during the period of employment. Generally, if a person has ever been classified, a PD2 label is to be attached to their central personnel file and their FMed 291A dosimetry record. Requests for Termination Records are to be made by completing a Personal Details Form (FMed 291E) for the individual which is to be forwarded to Dstl ESD ADS. The form is to have a tick placed in Box 18 and must include details of a forwarding address for the employee and date of termination of employment. Dstl ESD ADS will send a copy of the termination record to the HSE as required by IRR99.

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LEAFLET 6 ANNEX B GUIDANCE FOR LINE MANAGERS AND EMPLOYEES ON ESTIMATED DOSES AND SPECIAL ENTRIES CONTENTS Para 1 2 5 6 8 10 Introduction Amendment of radiation doses allocated to a radiation dosemeter Definition of doses much greater or less than that recorded in the dose record Adequate investigation Approved dosimetry service action Employee consultation

INTRODUCTION 1 The ADS will amend dose records in accordance with the special entry arrangements specified in IRR99. Where appropriate, the unit or establishment is responsible for applying for such special entries. AMENDMENT OF RADIATION DOSES ALLOCATED TO A RADIATION DOSEMETER 2 Classified persons. Whenever any person has reasonable cause to believe that the radiation dose recorded on a Laboratory Certificate issued by the ADS, usually Dstl ESD ADS, for a classified person is much greater or much less than the dose received by the relevant individual, the circumstances are to be reported to the RPS or RSO. An investigation is to be undertaken by the unit or establishment, and, where the investigation confirms the belief that the dose recorded is incorrect, the following action is to be taken: 2.1 Application is to be made for a special entry to the individuals dose record by submitting full details of the investigation through normal channels to the appropriate TLB safety authority for radiation safety, for onward transmission to the ADS. For those establishments with a resident full time RPA, application is to be made for a special entry by submitting full details of the investigation to the Radiation Protection Adviser, for onward transmission to the ADS, and a copy sent to the appropriate TLB safety authority. A copy of the investigation report is to be retained for at least 2 years. 2.2 Consent for a special entry is required from the Health and Safety Executive in any case where the cumulative recorded dose exceeds a legal dose limit as detailed in Leaflet 4. 2.3 Doses assessed from dosemeters that were lost in high radiation areas, if recorded, will remain on an individual's personal dose record until notification of special entry approval is received by the ADS. 3 Special entries so approved are to be entered in the relevant individual's record and a copy is to be supplied to the individual. 4 Other radiation workers. For other radiation workers who are not designated as classified persons, application is to be made for a dose amendment to be made to the individual's dose record by submitting full details of the investigation through normal channels together with a fully completed ADS Form 94 (Estimated Dose From) to the appropriate TLB safety authority who will approve the amendment to the radiation dose record and inform the ADS.

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DEFINITION OF DOSES MUCH GREATER OR LESS THAN THAT RECORDED IN THE DOSE RECORD 5 The RSO or RPS is to review the investigation to ensure that it is sufficient to produce an estimate of the dose received by a classified person. That estimate is to be regarded as much greater or less than the original entry in the dose record for a particular period if: 5.1 The dose received differs from the original entry by at least 1 mSv for recorded doses of 1 mSv or less: or 5.2 The dose received differs from the original entry by a factor of 2 or more for recorded doses in excess of 1 mSv but less than the relevant dose limit: or 5.3 The dose received differs from the original entry by a factor of 1.5 or more for recorded doses at or above the relevant dose limit. ADEQUATE INVESTIGATION 6 An adequate investigation is one that is sufficiently thorough to show there is reasonable cause to believe that the dose entry in the dose record is substantially incorrect. The investigation is to at least take account of: 6.1 Relevant information provided by the ADS.

6.2 Details of the pattern of work of the individual such as the time spent in particular controlled and supervised areas. 6.3 Measurements from any additional dosemeter or direct reading device worn by the person concerned. 6.4 Individual measurements made on other employees undertaking the same work with ionizing radiation; and 6.5 7 The results of monitoring for controlled and supervised areas carried out.

In addition, it is worth considering: 7.1 A credible reconstruction of the exposure conditions for the employees dosemeter to demonstrate that there is reasonable cause to believe that the exposure it received was likely to have occurred when not being worn. 7.2 The layout of the working area, the radiation sources in it and any shielding or other controlled measures available to restrict exposure. 7.3 The reliability of engineering controls, design features, safety features and warning devices specifically provided to restrict exposure. 7.4 7.5 Details of any radiation monitors/alarms and their reliability. Training records and experience of employees.

7.6 Arrangements for storage / security of dosemeters against risks of inadvertent / malicious exposure or contamination.

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7.7 Systems of receipt, handling of dosemeters including the use of security X-ray devices at the unit or establishment. APPROVED DOSIMETRY SERVICE ACTION 8 On receipt of a request for a special entry the Dstl ESD ADS will forward an ADS form 94 which is to be used to request the ADS to make the changes to the classified or non classified persons dose record. 9 Dstl ESD ADS may be reluctant to act on a request for special entry if the information provided appears to be inadequate to support a change to the recorded dose. Dosimetry services are only approved to make special entries requested by units and establishments which satisfy the requirements of the IRR99. In such circumstances the Dstl ESD ADS will request further and better details to support the case. EMPLOYEE CONSULTATION 10 The classified person must be consulted during the investigation and notified of any special entry proposed. If the classified person is aggrieved by the decision to apply for special entry they can request the HSE to review that decision within 3 months of being informed. For other persons it is not required. 11 The HSE can direct the unit or establishment to arrange for the original entry to be restored if it is not satisfied with the investigation, or a reasonable estimate of the dose has not been established.

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LEAFLET 6 ANNEX C DOSIMETRY ARRANGEMENTS FOR OUTSIDE WORKERS CONTENTS Para 1 2 Introduction Radiation passbooks

INTRODUCTION 1 The responsibilities and duties of the outside worker, their employer and the operator of the controlled area must be formally agreed before any work is undertaken. The responsibilities of these individuals are detailed in Leaflet 38 and the specific arrangements for dosimetry are below. RADIATION PASSBOOKS 2 MOD units and establishments with classified persons intending to undertake radiation work in a controlled area at another establishment or at a non-MOD site are to ensure that those employees are each provided with an individual radiation passbook. The radiation passbooks are available from the ADS and may be issued to named individuals by the ADS or issued to their employer who will then allocate them to their outside workers. A record is to be kept by the ADS and the employer of the issue of radiation passbooks and of any losses. Such records are to be kept for a period of 5 years after the passbook has ceased to be used by the outside worker. 3 The radiation passbook has a unique serial number and is not transferable between individuals and the employer is to ensure that the particulars entered are kept up to date. The outside worker can retain the passbook when transferring to employment with another employer. Information is to be entered into the passbook by a person who has been authorised, in writing, by the employer, the operator of the controlled area or the ADS. The authorised person is to have direct responsibility for the outside worker or have responsibilities for radiological protection, such as the RSO or RPS. Particulars to be entered in the radiation passbook are given below. 4 In the event of the loss of a passbook the circumstances are to be investigated by the employer and an assessment or estimate made of the radiation dose received by the outside worker. The result of the investigation is to be entered into the record referred to above. A passbook issued to replace a lost passbook is to be clearly marked with the word 'replacement'. 5 Radiation passbooks which are full or which have been withdrawn are to be forwarded by the employer to the ADS where they will be stored for the statutory period. When the passbook is full a new passbook is to be requested from the ADS. 6 In the event of a classified person becoming declassified the radiation passbook is to be returned to the ADS where it will be stored for 5 years. If a worker becomes redesignated as a classified person within that 5 year period, the last radiation passbook will be re-issued to the worker until full when a new passbook will be issued, or if previously if issued before 30 April 2000, a new passbook will be issued. If a classified person leaves MOD employment, the passbook is to be returned to the ADS. 7 Particulars to be entered into the radiation passbook are as follows: 7.1 7.2 Serial number of the passbook. A statement that the passbook has been approved by the Health and Safety Executive.

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7.3 7.4

Date of issue of the passbook by the ADS. The name, telephone number and mark of endorsement of the issuing ADS.

7.5 The name, address, telephone and telex/facsimile number of the outside workers employer. 7.6 Full name (surname and forename), date of birth, gender, Personal Dosimetry (PD) number and National Insurance number of the outside worker to whom the passbook has been issued. 7.7 Date of the last medical review of the outside worker, the relevant classification in the health record as fit, fit subject to conditions (which shall be specified) or unfit. 7.8 The relevant dose limits applicable to the outside worker to whom the passbook has been issued. 7.9 The cumulative dose assessment (external and/or internal) in mSv for the year to date for the outside worker, and the date of the last assessment period. 7.10 In respect of work undertaken by the outside worker, the employer responsible for the controlled area must ensure that the following particulars are entered in the radiation passbook by people authorised by the ADS or employer: 7.10.1 The name and address of the employer responsible for the controlled area. 7.10.2 The period covered by the performance of the services. 7.10.3 Estimated dose information, which shall be, as appropriate. 7.10.3.1 An estimate of any whole body effective dose in mSv received by the outside worker. 7.10.3.2 In the event of non-uniform exposure, an estimate of the equivalent dose in mSv to organs and tissues as appropriate. 7.10.3.3 In the event of internal contamination, an estimate of the activity taken in or the committed dose. 7.10.4 The passbook must be made available to the worker on request.

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LEAFLET 6 ANNEX D GUIDANCE FOR LINE MANAGERS AND EMPLOYEES ON THE NATIONAL REGISTRY FOR RADIATION WORKERS CONTENTS Para 1 2 4 7 8 9 10 12 Introduction Purpose of the registry Eligibility Benefit of inclusion of the historic data Information supplied Data confidentiality Advantages of the registry Opt out arrangements

INTRODUCTION 1 The Health Protection Agency (HPA) has set up a National Registry for Radiation Workers (NRRW) and you are invited to collaborate in the provision of certain personal information to the Registry. It is hoped that the notes below will help you in your consideration of this matter. PURPOSE OF THE REGISTRY 2 The MOD safety standards for radiation workers are based on the recommendations of the International Commission on Radiological Protection (ICRP) as endorsed by the Medical Research Council (MRC) and the HPA for application in the UK. Exposure to radiation is carefully monitored to ensure that these internationally accepted standards are complied with. Nevertheless, the MOD has fully supported the establishment of the NRRW and expects that the information it collects, when analysed, will bear out the confidence they have in their radiation protection standards. 3 The MOD supports the Registry scheme to collect accumulative information on radiation exposures in order to study, over the long term, whether there is any evidence of differences in the cause of, and the age at, death of workers exposed to different levels of radiation at work including the lowest dosage levels recorded. ELIGIBILITY 4 The HPA has concentrated successively on employees in British Nuclear Fuels Limited, the UK Atomic Energy Authority, the Electricity Generating Board and now the MOD. In due course they expect to extend the Registry to include other groups of employees working with radiation. 5 The Registry started with information on employees who were radiation workers (including workers with radioactive materials separately identified) on 1 January 1976 or who have become radiation workers since that date. 6 The historical radiation worker dose records held for periods prior to 1979 have been computerised and have been transferred to the NRRW. This brought MOD into line with other employers who have already supplied their employees historical data to the NRRW.

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BENEFIT OF INCLUSION OF THE HISTORIC DATA 7 These data are considered particularly important by the HPA because radiation doses received in the 1960s and 1970s tend to be larger than those received more recently, and employees who started radiation work several decades ago would have had a longer time to accumulate doses than those who started work in the 1980s and 1990s. Moreover, because these early workers tend to be older than more recently employed workers, and mortality rates increase with increasing age, there will be more deaths in this group. Any effect of radiation exposure, if indeed one exists, is more likely to be identified by the inclusion of this group of workers in the study population. INFORMATION SUPPLIED 8 The only information which will be given to the Registry by the MOD is the following: 8.1 8.2 8.3 8.4 8.5 8.6 8.7 Family name, initial (if necessary, full name, title and previous family name, if any). Sex. Name of employer. Date of birth, and if necessary place of birth. National Insurance number. Service/pay number. Dockyard Number (if appropriate).

8.8 National Health Service number (i.e. the number on the National Health card used in connection with registering with a doctor), and, if necessary, permanent home address. 8.9 8.10 8.11 Job code. Entry date. Rank/Title.

8.12 Accumulated radiation dose data up to the end of the previous year, including an indication of exposure to specific radioactive materials, updated annually. 8.13 Information about any occupational and environmental exposure conditions relevant to radiation health effects as necessary. 8.14 NOTE There is no question of supplying other details of personal medical history. A note showing involvement in radiation incidents.

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DATA CONFIDENTIALITY 9 The HPA will hold the data on a computer; and has guaranteed complete confidentiality of individual records and has satisfied the MOD that their safeguards are reliable. No information on specified individuals contained in the Registry will be communicated to anyone other than the employer supplying the original entries or to any individual radiation worker at their own request. NOTE The radiation records maintained at your place of employment will provide much more detail than that maintained or needed by the Registry. ADVANTAGES OF THE REGISTRY 10 It is in the interest of all that reliable information is to be available about the age, accumulated radiation dosage, if any, and cause of death of those who have been employed in the nuclear industry. By studying the data, particularly that concerning low levels of radiation dosage, comparison can be made with the safety standards set both nationally and internationally and thus permit a more meaningful interpretation to be put on these recommended standards. 11 The Staff Side of the MOD Whitley Council and the Trade Union Side of the MOD Joint Industrial Whitley Council have been consulted on the details of the scheme and have agreed that it would be in the interests of MOD employees to participate in the scheme. Unless, therefore, you specifically request in writing that your name be excluded from the Registry you will automatically participate in these arrangements. OPT OUT ARRANGEMENTS 12 Anyone who has been employed on radiation work and who does not wish to have their records transferred, may opt out by writing to The Dosimetry Manager, Dstl ESD, INM, Crescent Road, Alverstoke, Gosport, Hants PO12 2DL.

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LEAFLET 6 ANNEX E GUIDANCE FOR LINE MANAGERS AND EMPLOYEES ON MEDICAL SURVEILLANCE OF CLASSIFIED PERSONS CONTENTS Para 1 2 7 8 12 13 14 Introduction Medical surveillance Special medical surveillance Suspension from employment as a classified person Transfer of establishment for classified persons Statistical returns Female classified persons

INTRODUCTION 1 The main purpose of medical surveillance is to determine an individuals fitness or continuing fitness for the intended work with ionizing radiation. In this context, fitness of the person is not restricted to possible health effects from exposure to ionising radiation. The Appointed Doctor (AD) or employment medical adviser will need to take account of the specific features of the work with ionizing radiation and must be allowed to inspect the workplace if they require it. MEDICAL SURVEILLANCE 2 The AD is to be provided with adequate facilities to carry out medical examinations. They are to be provided with copies of dose summary records, sickness/absence records and the health record of personnel being examined and allowed access to working areas so that they may be inspected. The AD is to determine the form of this examination, taking account of the nature of the work, the individuals state of health and guidance provided by the HSE. However, at the initial medical examination, a description of the work to be undertaken, past medical, family and occupational and social histories should be carefully taken and positive findings with the results of physical examination notated on the FMed 291C. The outcome is to be entered and signed in the Health Record (FMed 291F). Unless indicated by medical history or the clinical findings an X-ray examination of the chest or full blood count are not prerequisites for either the initial medical examination or for subsequent reviews. 3 Every classified person is to have a health review conducted by the AD annually. This review should be conducted in the presence of the classified person who should provide current details of the medical histories so that any recent changes may be noted. If it is not practicable for the classified person to be present then the review must, as a minimum, include an assessment of the current job title(s), content(s), sickness absence and dose records for the preceding 12 months. Where the AD considers it necessary, they are to insist on the classified person being present for the review and determine whether and what medical examination and, or medical tests may be appropriate to the circumstances. The review represents, also, an opportunity to provide general health advice and to discuss the significance of doses accrued. 4 As industrial radiographers have an increased risk of accidental and unsuspected overexposure, all MOD classified persons undertaking industrial radiography must attend for review and be examined for signs of deterministic effects with especial attention directed at the skin and nails of the upper extremities. 5 In all cases, the content of the review must be clearly documented on the FMed 291C (or equivalent HSE form MS 101). Classified persons considered fit to continue radiation work are to be recertified as fit by signed entry, by the AD, in the health record (FMed 291F or equivalent HSE form 2067).

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6 The AD may undertake health reviews of classified persons at any time within the 12-month period if it is considered necessary. Those whose classified status has lapsed, and/ or have not undergone health review by an AD and been certified fit within the preceding 13 months are to be treated as persons starting their first employment as classified persons. SPECIAL MEDICAL SURVEILLANCE 7 The AD is to conduct special medical surveillance on any worker who has received a radiation dose more than any statutory relevant dose limit detailed Leaflet 4. Guidance on the form of this examination is provided in the Guidance for Appointed Doctors (Revised 2003) IRR99. The AD is to inform the local Senior Medical Inspector (SMI) of any known or suspected overexposure. SUSPENSION FROM EMPLOYMENT AS A CLASSIFIED PERSON 8 The AD may, by signed entry in the health record, suspend from employment as a classified person any worker they have examined and found unfit for radiation work. The AD is to notify, immediately, the following of any suspension: 8.1 8.2 8.3 8.4 NOTE * The HSE need only be informed if suspension results from overexposure and that notification will usually be made by the RPA or RSO, though the AD may also find it useful to enter into discussion with the local SMI. When suspension is due solely to medical factors then there is no requirement to inform HSE, though again, there may be benefit in discussing with the local SMI, especially if an appeal is thought likely to result. 9 A classified person who has been suspended is not to be re-employed as a classified person until re-certified fit by signed entry of the AD in the health record. The AD is then to inform the CO, RSO (or RPS) and ADS of each case. 10 Where full suspension is deemed unnecessary, the AD may impose appropriate restrictions in the health record, either upon initial employment or at annual or earlier review, of a classified person. The person is to be employed by the CO only under the prescribed restrictions. 11 Should any civilian worker disagree with the decision of the AD, they may, within 3 months of notification of the decision, apply in writing to the HSE for the decision to be reviewed. The result of such a review is to be notified to the worker and entered on their health record. Service personnel should not appeal directly to the HSE in the first instance, but are to represent their cases through the normal Service procedures. Should they remain dissatisfied, they still have the right to refer their cases to the HSE for resolution. The CO of the unit. The RSO or RPS. The ADS. The HSE*.

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TRANSFER OF ESTABLISHMENT FOR CLASSIFIED PERSONS 12 The AD at, or for, an establishment to which a classified person has been transferred permanently or for periods of detachment exceeding 3 months is to request a copy of the entry in the health record from the previous establishment. The classified person is not to undertake radiation work at the new establishment until the AD has received this documentation. STATISTICAL RETURNS 13 ADs are required to submit statistical returns on a prescribed form, supplied by the local SMI, at the frequency specified by HSE. This information will include details of the AD, number of examinations performed by that doctor and the number of unfit assessments. FEMALE CLASSIFIED PERSONS 14 Women deemed for the purposes of the Regulations of reproductive capacity are limited to a maximum dose of 13 mSv to the abdomen in any consecutive 3 month period. The likelihood of this occurring is to be entered into Part A of FMed 291F (or HSE form 2067) prior to the initial or subsequent review. Every prospective female classified person must be reminded that she is to notify her employer, in writing, that she is pregnant or breastfeeding. Thereafter, or as soon as the employer might otherwise reasonably become aware, the conditions of exposure must be modified, as necessary, to ensure that: 14.1 The equivalent dose to the foetus is unlikely to exceed 1 mSv during the remainder of the pregnancy, and that 14.2 Significant contamination by ingestion or inhalation of radioactive substances is prevented whilst breastfeeding.

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LEAFLET 7 RADIATION PROTECTION ADVISER CONSULTATION AND ADVISORY VISITS CONTENTS Para 1 2 3 4 5 6 7 8 10 12 13 15 17 19 20 21 22 Table 1 Annex A SCOPE 1 This leaflet sets out those aspects of working with ionising radiation where there is a statutory requirement for consultation with a Radiation Protection Adviser (RPA), and where consultation is expected or advised. Information is also provided on the need for advisory visits by an RPA. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Work not requiring appointment of or consultation with a Radiation Protection Adviser Scope Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Work Place Supervisor (WPS) Employees Radiation protection adviser consultation and appointment Statutory consultation Statutory requirement for RPA consultation on critical examination by installer/erector Consultation requirements for observance of IRR99 Radiation protection advisory visits Frequency of radiation protection advisory visits Additional advisory visits Notification of inspections by other government departments Records Related leaflets Page Related Leaflets...............................................................................................................................1

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DUTIES Commanding Officer and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO), on behalf of the Commanding Officer, may consult with the RPA and ensure that appropriate actions are taken following the receipt of the advice. Radiation Protection Supervisor (RPS) 5 Where sites and establishments have controlled or supervised areas, an RPS must be appointed. Where an RPS is appointed, they must ensure that local orders are adhered to (see Leaflet 16) and revised to take account of advice received from the RPA. Where appropriate the RPS is to also assist the RSO to ensure that an RPA is consulted on the matters set out in the following sections. Workplace Supervisor (WPS) 6 In cases where work with radioactive material is carried out but where the risk assessment shows that designated areas are not required, a WPS is to be appointed with duties to ensure that the work with radioactive material is carried out safely in accordance with the local orders for radiation safety and the measures required to ensure doses are kept ALARP. A WPS may consult with the RPA, the WPS is to ensure that appropriate actions are taken following the receipt of the advice. Employees 7 It is the responsibility of all employees to ensure that the WPS, RPS or RSO is made aware of any changes to working conditions or practices that may require RPA consultation. RADIATION PROTECTION ADVISER CONSULTATION AND APPOINTMENT 8 An RPA is to be appointed in writing at TLB level (and also provided with the scope of advice required) in accordance with the policy at Volume 1 Chapter 8. Before appointing an RPA, the suitability of the RPA, in terms of the required knowledge, experience and competence for giving the type of advice required, must be established. 9 Where there is no on-site RPA, RPA visits will be made on a periodic basis as decided by the TLB. Decisions on the required day to day level of consultation with an RPA are to be made at unit or establishment level. Provided that the only work with ionising radiation being undertaken is included at Annex A then there is no requirement to consult or appoint an RPA. However, the appointed RPA will normally be available to advise on any aspect of radiation protection, whether or not required under IRR99. Statutory consultation 10 There is a statutory requirement for the radiation employer (CO) to consult an RPA on each of the following matters: The implementation of requirements to controlled and supervised areas.

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The prior examination of plans for installations and the acceptance into service of new or modified sources of ionising radiation in relation to any engineering controls, design features, safety features and warning devices provided to restrict exposure to ionising radiation. The regular calibration of equipment provided for monitoring levels of ionising radiation and the regular checking that such equipment is serviceable and correctly used (see also Leaflets 4 & 8) The periodic examination and testing of engineering controls, design features, safety features and warning devices and regular checking of systems of work provided to restrict exposure to ionising radiation.

11 It is a statutory requirement that the employer (CO) must provide the appointed RPA with adequate information and facilities for the performance of their functions. Statutory requirement for RPA consultation on critical examination by an installer or erector 12 Whenever an article is erected or installed for use in work with ionising radiation, the erector/installer must, where appropriate, undertake a critical examination of the way in which the article was erected or installed regarding, in particular, that safety features and warning devices operate correctly and that there is sufficient protection for persons from exposure to ionising radiation. As part of this process, the installer/erector must consult with their RPA or with the RPA of the radiation employer (CO) regarding the nature and extent of the critical examination and the results of it. See also Leaflet 1. Consultation requirements for observance of IRR99 13 In addition to those areas set out above consultation is required where advice is necessary for compliance with IRR99. This includes: Procurement of new equipment involving ionising radiation or radioactive substances (see Leaflet 1) Undertaking the risk assessment required by regulation 7 (see Leaflet 2). Designation of controlled and supervised areas required by regulation 16 (see Leaflet 4) Undertaking investigations required by IRR99 (see Leaflet 14). Developing contingency plans required by regulation 12 (see Leaflet 40) Dose assessment and recording required by regulation 21 (see Leaflet 6). Quality assurance programme for medical equipment or apparatus required under regulation 32 (see Leaflet 26) . In addition to these areas the advice of a RPA may be needed in other areas such as: Selection and use of personal protective equipment where required (see Leaflet 4) Designation of classified persons (see Leaflet 6) Arrangements for outside workers, i.e. arrangements for classified persons who are required to enter a controlled area of any employer (other than that of their own employer). Appointments and training. Compliance with other legislation relating to ionising radiation or radioactive substances (see also Leaflet 3)

14

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RADIATION PROTECTION ADVISORY VISITS 15 All MOD units and establishments holding radioactive materials or using equipment emitting ionising radiation, which have appointed or wish to consult with an RPA should normally receive visits from their RPA. The Dstl RPA Body will generally be able to conduct such visits and provide radiation protection advice, if appointed. 16 The RPA, usually the Dstl RPA Body, will liaise with each Navy, Army, RAF and Defence Agency establishment to agree a mutually convenient date for the visit. The RPA will provide details of aspects to be examined during the visit. Frequency of radiation protection advisory visits 17 The frequency of advisory visits will depend upon the degree of potential radiation hazard likely to be involved. Visits are to be arranged as part of a predetermined programme, and will typically be undertaken at a frequency of between one and three years. 18 The RPA is to be consulted for advice on the particular visit frequency for an individual unit or establishment. The visit frequency may be varied at the discretion of the RPA, in agreement with the appropriate TLB. Additional advisory visits 19 In addition to the programmed advisory visits described above, COs of units and establishments under single Service arrangements may request additional advisory visits and support from the appointed RPA to provide assistance on specific aspects of radiation protection. Notification of inspections by external regulatory bodies 20 Any unit or establishment which has been notified by HSE, or any other statutory inspecting body, that they wish to make a radiation protection inspection are to immediately inform the RPA and where appropriate the TLB safety authority. RECORDS 21 Following each advisory visit the RPA is to provide a summary of the advice given and any recommendations made. Generally the RPA will provide written advice. The radiation employer (CO), or their representative, is to maintain records of all advice received, including details of any advice provided verbally.

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RELATED LEAFLETS 22 Leaflets relevant to this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 1 2 3 Leaflet Title

Procurement of sources of ionising radiation Risk assessments Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Restriction of exposure to radiation Dosimetry and personal dose records Radiation monitoring and radiation protection instruments Investigation, notification and reporting of unusual radiation events Local orders for radiation safety Medical diagnostic X-ray machines and fluoroscopes Contingency planning

4 6 8 14 16 26 40

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LEAFLET 7 ANNEX A WORK NOT REQUIRING APPOINTMENT OF OR CONSULTATION WITH A RADIATION PROTECTION ADVISER

1 Consultation with or appointment of a radiation protection adviser shall not be required when the only such work being carried out is in one or more of the following categories 1.1 Where the concentration of activity per unit mass of a radioactive substance does not exceed the concentration specified in column 2 of Part I of Schedule 8; 1.2 Where the quantity of radioactive substance involved does not exceed the quantity specified in column 3 of Part I of Schedule 8; 1.3 Where apparatus contains radioactive substances in a quantity exceeding the values specified in sub-paragraphs 1.1 and 1.2 above provided that: 1.3.1 1.3.2 The apparatus is of a type approved by the Executive; The apparatus is constructed in the form of a sealed source;

1.3.3 The apparatus does not under normal operating conditions cause a dose rate of more than 1Svh-1 at a distance of 0.1m from any accessible surface; and 1.3.4 Conditions for the disposal of the apparatus have been specified by the appropriate Agency; 1.4 The operation of any electrical apparatus to which these Regulations apply other than apparatus referred to in sub-paragraph 1.5 below provided that 1.4.1 The apparatus is of a type approved by the Executive; and

1.4.2 The apparatus does not under normal operating conditions cause a dose rate of more than 1Svh-1 at a distance of 0.1m from any accessible surface; 1.5 The operation of 1.5.1 1.5.2 30kV. Any cathode ray tube intended for the display of visual images; or Any other electrical apparatus operating at a potential difference not exceeding

provided that the operation of the tube or apparatus does not under normal operating conditions cause a dose rate of more than 1Svh-1 at a distance of 0.1m from any accessible surface; 1.6 Where the work involves material contaminated with radioactive substances resulting from authorised releases which the appropriate Agency (EA, SEPA or equivalent) has declared not to be subject to further control.

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LEAFLET 8 RADIATION DETECTION AND MONITORING EQUIPMENT CONTENTS Para RADIATION DETECTION AND MONITORING EQUIPMENT Scope Statutory requirements and Parallel Arrangements Duties Commanding Officer Radiation Safety Officer Radiation Protection Supervisor (RPS) Workplace Supervisor (WS) Selection RDME(H&S) RDME(OP) Use Procurement General Requirements RDME(H&S) RDME(OP) Testing Test Categories Approved MOD / Defence Contractor Radiation Facilities and Equipment Documentation Certificate of Calibration Instrument Log Records Contact Details Related leaflets Page Table 1 Related leaflets...................................................................................................................9

1 7 8 9 10 12 13 18 19 20 23 26 29 35 46 53 56 60 62 65 Table 1 Annex A

Approved MOD / Defence Contractor Radiation Calibration Facilities

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RADIATION DETECTION AND MONITORING EQUIPMENT SCOPE 1 Radiation Detection and Monitoring Equipment (RDME) is split into three categories: 1.1 RDME used for Health and Safety (H&S) and Nuclear Accident Response Organisation (NARO) is identified in this leaflet as RDME(H&S) 1.2 RDME(MED&DENT) used in support of medical, dental and veterinary equipment testing should be managed in accordance with JSP473 Joint Service Regulations For The Engineering Support Of Medical, Dental And Veterinary Equipment. JSP473 outlines the policies and procedures to be adopted in the inspection and maintenance of medical equipment used by the UK Armed Forces and its Agencies. 1.3 RDME used to meet operational war fighting requirements is identified in this leaflet as RDME(OP). 2 All equipment provided for the purpose of carrying out radiation detection and monitoring of ionising radiation for personal protection is required to be properly maintained, thoroughly examined and tested annually and have its performance established in tests before it is taken into use for the first time. (Ref. Ionising Radiations Regulations 1999 (IRR99) Regulation (19)). 3 This leaflet describes the selection, testing, maintenance, repair and support of such equipment.

4 JSP 425, the Examination and Testing of Ionising Radiation Monitoring (Including Protection) Instruments, details the minimum requirements for examination and testing of ionising RDME. It also describes the minimum standards to be maintained by Calibration Facilities to ensure that the employers responsibilities under IRR99 Regulation (19) are achieved. 5 Sufficient RDME shall be provided to meet the requirements of the radiation monitoring programme. In addition, permanently installed RDME should be positioned in areas where high radiation dose rates (typically 1 Sv.h-1) may occur, as advised by the Radiation Protection Adviser (RPA). 6 RDME(OP), formally identified as RADIAC equipment is scaled in centi-Gray (cGy) and should not be used for radiation protection purposes, unless advised by the RPA.

STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 7 In addition to the general requirements of the Health and Safety at Work etc Act 1974, the following specific legislation applies: Ionising Radiations Regulations 1999 (IRR 99) (applies directly). Ionising Radiation (Medical Exposure) Regulations 2000. (IRMER2000)

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DUTIES Commanding Officer 8 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and to secure the health, safety and welfare of their staff at work. The CO is required to protect persons not in MOD employment against risks to their health or safety arising from the MOD work activities (eg. the general public). This includes radiation safety. The CO's authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 9 The Radiation Safety Officer (RSO) shall ensure all areas under their supervision have appropriate risk assessments for the RDME (including instrument check sources) they hold. The RSO may be required to liaise with the RPS, IPT, RPA and other stakeholders in obtaining suitable and sufficient risk assessment coverage. (see Ref. Leaflet 2) Radiation Protection Supervisor (RPS) 10 An RPS must be appointed (where necessary) to designate controlled or supervised areas. Where an RPS is appointed, their duties shall include obtaining/preparing sufficient risk assessments/contingency plans for works involving the use of ionising radiation, the RPS may not be expert in such matters and may obtain assistance from the relevant IPT, RSO or RPA. (Ref. Leaflet 2) 11 Newly arising activities involving the use of ionising radiation must be covered by suitable and sufficient Prior Risk Assessment (PRA). A PRA should be in place prior to initiation of work. (Ref. Leaflet 2) Workplace Supervisor (WS) 12 In units where it is unnecessary to appoint an RPS, an WS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety (Ref. Leaflet 16). In addition to those duties, an WS may be required to assist in the preparation of risk assessments and contingency plans.

SELECTION RDME(H&S). 13 The selection of suitable RDME(H&S) should be made on the advice of the RPA.

14 General and specific advice on RDME may be obtained from either the RPA or the equipment sponsor. 15 The approved list of RDME(H&S) is limited to a range of instrumentation Adequate for (MOD) defined radiation and detection monitoring purposes. Utilisation of RDME(H&S) from the approved list provides users with the assurance of through life support for the equipment. 16 Suitable RDME(H&S) is defined by the appropriate RPA and endorsed by the Chief Environment and Safety Officer (CESO) or other suitable person. The approved scales and allowances for RDME(H&S) are detailed in the RDME Approved List of Test Equipment (RDME(H&S)-ALTE) which is maintained on behalf of the MOD Radiation Protection Instruments Committee (RPIC) by the Marine Environment, Survivability and Habitability Integrated Project Team (MESH IPT).

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17 Where a platform, unit or establishment requires change to the type or number of RDME allocated, a request providing reasons for the change in allocation must be provided to the relevant RPA for review and CESO endorsement. Following RPA review, the requirement should be submitted to MESH IPT via the appropriate RPIC representative such that RDME-ALTE amendment action may be initiated. 17.1 For RN units S130 procedures are to be followed for change in RDME scaling.

17.2 For RAF units a TEC application through station TEMC is to be used for change in RDME scaling. 17.3 RDME(OP). 18 The capability for operational use is defined by DEC(CBRN) with the tables of scales and allowances to support operations detailed in JSP336 and specifically for the Royal Navy Surface Fleet in BR 2170(3) and Royal Navy Submarine Fleet in BR2170(4). For Army units form AF8088 procedures are to be followed for change in RDME scaling.

USE 19 RDME used for monitoring operations shall only be operated by personnel who have been trained in their operation and are aware of the capabilities and limitations of the equipment.

PROCUREMENT General Requirements. 20 During the procurement phase, the following requirements shall be incorporated into the contract of purchase by the sponsoring IPT. It is the suppliers responsibility to ensure all of the requirements are met.Type Test data. 20.1 20.2 Before First Use certificate in accordance with JSP425. A calibration protocol in accordance with JSP 425.

21 It is the responsibility of the sponsoring IPT or equipment manager to provide newly procured RDME with the following: 21.1 21.2 21.3 Spares to support repair. Jigs and sources, if special items are required, for testing and operational checks. Test procedures (usually obtained from instrument suppliers).

21.4 Suitable instrument check sources. If an instrument check source is to be supplied a PRA is also to be supplied (Ref. Leaflet 2) and relevant details published in JSP515. 22 RDME is not to be introduced unless details of the equipment's performance, limitations and accuracy relevant to the proposed use of the equipment are provided. RDME(H&S) Equipment Requirements. 23 RDME(H&S), with the exception of site specific special monitoring equipment, is managed by the DE&S, MESH IPT, in consultation with the relevant CESO, RPA and the RPIC.

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24 Where there is a specific requirement for equipment not on the approved list, a request for new equipment is to be submitted to the relevant RPA for consideration and approval. The request is then forwarded to the relevant CESO for endorsement. CESO will arrange procurement with the equipment sponsor normally via the RPIC and MESH IPT. 25 MOD units and establishments with a resident RPA may purchase special/specific to type RDME following RPA approval. In such instances the procuring unit/RPA will become the equipment sponsor and must ensure provision for subsequent support activities is maintained in line with guidance detailed in this leaflet. RDME(OP) Equipment Requirements. 26 New RDME(OP) requirements are managed by the DE&S (CBRN Protection IPT), as directed by DEC(CBRN) capability requirements. 27 Tri-service and land environment specific RDME(OP) such as Tactical Radiation Monitoring Equipment (TRaME) are provided with in service support from the Combat Support Equipment (CSE IPT) within the DE&S. 28 Sea environment specific RDME(OP) such as Ships installed RADIAC System are provided with in service support from MESH IPT.

TESTING 29 RDME testing shall be carried out in accordance with JSP 425 "The Examination and Testing of Ionising Radiation Detection and Monitoring Equipment". 30 Where contracted calibration coverage is not supplied by the supporting IPT, Platforms, units and establishments are responsible for arrangement of annual RDME testing. All testing shall be undertaken by an approved calibration facility, details of which are provided in paragraphs 46 52. 31 Specific arrangements for RAF and Army units and establishments holding RDME(H&S) have been made as follows: 31.1 Annual testing is carried out through Dstl ESD Calibration Facility where a pool of RDME and appropriate spares are held. The work is carried out under the MESH IPT Tri-Service Pool Holding contract with Dstl ESD. 31.2 The Tri-Service Pool Holding contract uses the MOD Form 1773 process for the notification of equipment due calibration. The contractor will raise and issue the MOD Form 1773 for the complete list of RDME held at unit in accordance with their calibration database and will issue the MOD Form 1773 to the unit (or supporting unit) four weeks prior to the month of calibration. 31.3 The unit will receive the form completed including Urgency of Need (UON) and Direct Exchange Return codes. These will have been predetermined by the contractor dependent upon current availability and status of equipment held within the pool and will normally be UON of ROUTINE with a maximum turn around time of 14 days. Units wishing to amend the UON or Direct Exchange Return codes are to notify the Support Authority stating the reasons for change, authorised by the unit Qualified Person. 31.4 Other than the exception stated above then the standard MOD Form 1773 procedure applies. Both Direct Exchange and Loan Cal equipment is to be returned to the Calibration Laboratory as detailed on the MOD Form 1773. 31.5 The maintenance policy for RAF units and establishments RDME(H&S) is contained in AP112G-1300-2R1.

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32 RDME sent to calibration facilities must include all accessories, individual instrument check sources and leads. They must be accompanied by: 32.1 The appropriate instrument log form RN - S/D 1956, RAF/Army RAF Form 4021 R/1.

32.2 Be certified as not being contaminated above levels that would require radiation protection controls to be implemented as agreed with the RPA and calibration facility. 32.3 Where an instrument check source is included as part of the equipment the check source register should be included and the equipment transported in accordance with Leaflet 10 and meet the surface contamination requirements at 32.2 above. 33 Technical queries about RDME should be directed in the first instance to the Equipment Sponsor or the RPA. 34 Testing difficulties arising from the design of RDME are to be referred initially to the equipment sponsor. 34.1 34.2 For RDME(H&S) MESH IPT, MOD Abbey Wood . For RDME(OP) CSE IPT, DE&S Andover.

Test Categories 35 The testing of RDME is broken down into three categories. These categories are fully detailed in JSP 425, but are summarised as follows: Category One (test before first use). 36 This test should be carried out by the instrument manufacturer or an approved calibration facility. The purpose of this test is to compare instrument performance characteristics with type test data. It must be undertaken before the instrument is brought into service or following a repair that may have altered the instrument's response. 37 The test is detailed in the MOD Radiation Calibration Qualified Persons (MRCQP) Calibration Protocol Manual. 38 Category One tests must be carried out by or under the direct supervision of a Qualified Person. The qualification and training requirements for Qualified Persons are given in JSP 425. Category Two (periodic / annual test). 39 This test should be conducted at a minimum annually or periodically as required to confirm that the performance of the instrument has not deteriorated, advice should be sought from the RPA. The test is to be carried out by an approved calibration facility. 40 The test is detailed in the MRCQP Calibration Protocol Manual.

41 Category Two tests must be carried out by or under the direct supervision of a Qualified Person. The qualification and training requirements for Qualified Persons are given in JSP 425. Category Three (test before operational use functional check). 42 For the majority of RDME the test is detailed in the instrument operator's manual, which is usually in the form of a BR for RN, AP for RAF or AESP for the Army. 43 The RPA is to be consulted on the type and frequency of routine checks to be undertaken to meet both local and legislative requirements.

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44 The user should carry out a functional check before operational use. The functional check should as a minimum include the following: 44.1 44.2 44.3 44.4 Battery check Physical condition Calibration in-date Validity of seals

44.5 Response to an instrument check source, if supplied. This check provides confirmation to the user that the instrument responds to radiation to a degree consistent with that obtained during the periodic/annual tests. 44.5.1 The acceptable range of readings for the instrument check source is shown on the instrument calibration certificate. Local procedures should include the requirement to confirm a consistent response to a test source before each use. Demonstration of best practice would include making and retaining a record of such checks for two years. 45 Further advice should be sought from the equipment sponsor or RPA.

Approved MOD / Defence Contractor Radiation Calibration Facilities. 46 For the purposes of this leaflet an Approved MOD / Defence Contractor Calibration Facility will be referred to as an approved calibration facility 47 The minimum facilities, equipment and standards to be achieved by an approved calibration facility are fully defined in JSP 425. 48 The responsibility for ensuring that the approved calibration facility meets the requirements of JSP 425 rests with the MRCQP Committee. The Chairman of the MRCQP Committee, MESH IPT maintains the up to date list of approved calibration facilities. 49 If a non approved calibration facility is to be used then assurance must be provided that the calibration work undertaken is: 49.1 Traceable to National Standards

49.2 Accredited to an appropriate MOD recognised quality management standard, normally ISO 9002 Series Quality Management Standard. 49.3 The facility has been accessed and meets the requirements of BS EN ISO 17025.

49.4 The RDME is calibrated, as a minimum, in accordance with the relevant protocol in the MRCQP Calibration Protocol Manual. 50 MESH IPT are to be informed prior to work being undertaken at non-approved calibration facilities.

51 A calibration facility demonstrating compliance with JSP425 will be nominated as an approved calibration facility. Chairman of the MRCQP Committee maintains the list of approved calibration facilities and this is replicated at Annex A. 52 All approved calibration facilities will be audited by MRCQP against compliance with JSP 425 as a minimum every three years.

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DOCUMENTATION Certificate of Calibration 53 A certificate of calibration for each instrument shall be raised by the approved calibration facility. The certificate layout and contents are detailed in JSP 425 but shall contain as a minimum the following: 53.1 Identification of the equipment e.g. Description, Serial No.

53.2 The calibration accuracy over its range of operation for the types of radiation for which it will be used. 53.3 53.4 54 Date of test. Name and signature of the Qualified Person.

A copy of the current certificate of calibration shall be available to the user.

55 Records of past calibrations are to be maintained by the unit or establishment for the life of the equipment and retained until at least 2 years after last use / disposal. Instrument Log 56 A log containing the particulars of every test and repair for each instrument is to be kept by an appropriate person. 57 Form S/D 1956 is to be used by Navy and Army units and establishments. RAF Form 4201 R/I is to be used by Air Force units and establishments. 58 Equipment managed under the MESH IPT Tri-Service Pool Holding Contract, e.g. RAF and Army units and Establishments, the instrument log will be maintained and retained by, Dstl ESD calibration facility. 59 The instrument logs are to be held for a period of at least 2 years from date of last entry by the unit or establishment.

RECORDS 60 Records of past calibrations are to be maintained by the unit or establishment for the life of the equipment and retained until at least 2 years after last use / disposal. 61 The instrument logs are to be held for a period of at least 2 years from date of last entry by the unit or establishment.

CONTACT DETAILS 62 RDME(H&S), RDME(MED&DENT) Equipment Sponsor MESH IPT, CBRN Section, MOD Abbey Wood, Bristol E-mail - meshcbrnrad@wsa.dlo.mod.uk Tel: (0117) 91 33602, Mil 9352 33602

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63

RDME(OP) Equipment Sponsor CSE IPT, DE&S Andover E-mail - ES(LAND) CSE-CSS2 Tel: (01264) 381867, Mil 94391 7867.

64

MRCQP Chairman MESH IPT, CBRN Section, MOD Abbey Wood, Bristol E-mail - meshcbrnrad@wsa.dlo.mod.uk Tel: (0117) 91 33602, Mil 9352 33602

RELATED LEAFLETS 65 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related leaflets Leaflet Number 2 10 16 21 Leaflet Title

Risk Assessments and Contingency Plans Transport of Radioactive Material Local Orders for Radiation Safety Instrument Check Source

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LEAFLET 8 ANNEX A RADIATION DETECTION AND MONITORING EQUIPMENT Approved MOD / Defence Contractor Radiation Calibration Facilities Secondary Standard Facilities Calibration Facility, Dstl Environmental Sciences Department, Alverstoke Dosimetry and Radiological Metrology Services (Measurement and Calibration) (DRMS(M&C)), AWE Ltd, Aldermaston (formerly DRaStaC) Tertiary Standard Facilities Calibration Facility, Dstl Environmental Sciences Department, Alverstoke Calibration Facility, Fleet Support Ltd, HMNB Portsmouth DML Calibration Facility, Devonport Royal Dockyard BNS Calibration Facility, Rosyth Royal Dockyard Nucleonic Calibration Facility, HM Naval Base Clyde SMITE, BAE Submarines, Barrow-in-Furness Nucleonic Calibration Facility, Vulcan NRTE Calibration Facility, Nuclear Department, HMS Sultan

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LEAFLET 9 STORAGE, ACCOUNTING AND LEAK TESTING OF RADIOACTIVE MATERIAL CONTENTS Para

1 2 3 4 5 6 7 8 9 12 21 22 23 25 26 32 34 37 38 39 40 Table 1 Annex A B C

Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Risk assessment Requirements for radioactive material in storage Requirements for radioactive material stores High activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 Radiation (Emergency Preparedness and Public Information) Regulations 2001 Accounting for radioactive material Accounting for radioactive material on HM ships during refit Radioactive material source lists and musters (sealed sources) List of unsealed radioactive substances Leak tests Incidents Annual Holdings Returns Records Related leaflets Page Related Leaflets...............................................................................................................................7

Example radioactive material source list and muster sheet Radioactive material storage signs List of common radioactive items which require leak testing

SCOPE 1 This leaflet covers the legal and MOD requirements for the safe storage, accounting and leak testing of radioactive material. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements).

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Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR, 2001) (apply directly). High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASS) (parallel arrangements).

DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officers (RSO) role is essentially one of co-ordination and audit, ensuring compliance with the safety management arrangements. In the context of this leaflet, the RSO is to coordinate the annual check of the unit or establishments holdings, audit storage arrangements and investigate any incidents including the loss of radioactive material. Radiation Protection Supervisor (RPS) 5 Where sites and establishments have areas designated as controlled or supervised (see Leaflet 4), the CO must appoint an RPS for each designated area concerned. The prime duty of the RPS is to ensure compliance with the IRR99 in respect of work carried out in the designated area in practice, the RPS will achieve this by ensuring that work is carried out in accordance with the local orders for radiation safety (see Leaflet 16). Workplace Supervisor (WPS) 6 In cases where the storage of radioactive material is carried out but it is unnecessary to appoint an RPS, a WPS is to be appointed with duties to ensure that the storage and accounting of radioactive material is carried out in accordance with the local orders. Employees 7 It is the responsibility of all employees to ensure that they are familiar with the content of local orders and comply with them. Employees must also bring to the attention of the appropriate supervisor or manager any shortcomings they identify in the arrangements for storage and accounting of radioactive materials. RISK ASSESSMENT 8 Where work involves ionising radiation there is a requirement to ensure that the risk assessment considers radiological as well as non-radiological hazards. The requirement for a prior risk assessment, (which must be made before a new activity involving work with ionising radiation begins) complements this risk assessment. The form of these risks assessments and the actions to be taken arising from it are detailed in Leaflet 2. REQUIREMENTS FOR RADIOACTIVE MATERIAL IN STORAGE 9 Radioactive materials when not in use, being moved or transported, must, so far as is reasonably practicable, be kept in a suitable container and in a suitable radioactive store. Any store allocated to radioactive materials shall, as far as possible, be reserved for the materials, containers and handling tools and kept clear of other items, in particular of flammable or explosive materials. Advice on the

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storage of radioactive materials is to be sought from the RPA. Local fire authorities are to be kept informed of the location and radioactive content of all radioactive material storage areas, so that fire plans for buildings can be completed correctly. 10 Items are to be stored in a suitable receptacle to ensure effective restriction of exposure, physical security and prevention of dispersal of radioactive material. Aspects to be considered include shielding to ensure that the dose rate on the external surface of the receptacle is less than 2 mSv h-1, the ability of the receptacle to withstand damage from normal use or foreseeable misuse and fire resistance. If an item containing radioactive material cannot be stored in a suitable receptacle, equivalent protection and containment is to be provided. 11 Radioactive materials and their containers are to be clearly labelled as radioactive, and whenever practicable individually numbered. REQUIREMENTS FOR RADIOACTIVE MATERIAL STORES 12 Dedicated buildings used as permanent radioactive stores are to: Provide sufficient shielding or use controls such that persons outside of the store will not receive a dose exceeding 1 mSv in a year. The risk assessment for the storage of radioactive materials will indicate likely radiation doses to persons external to the store. In practice this will normally be achieved by ensuring that the radiation dose rate at any point on the outside walls of the building is less than 2.5 Sv h-1. For new facilities the dose rate is not to exceed 1 Sv h-1 unless advised otherwise by the Radiation Protection Adviser. Be constructed of fire-resistant materials. Provide protection against the weather. Be provided with adequate ventilation (e.g. an air extraction system exhausting to the open air) to prevent accumulations of gases and vapours or of any accidentally dispersed radioactive substance. This is particularly an issue for the storage of large quantities of GTLDs or items containing Ra-226; in these cases advice of the RPA is to be sought. Provide adequate security.

13 The RPA is to be consulted on the need to designate the store as a controlled or supervised area in accordance with Leaflet 4. 14 Suitable warning notices incorporating the radiation warning trefoil symbol as shown at Annex B, with the name or designation and telephone number of the RPS/WPS and details of the radiation hazard, are to be prominently displayed in appropriate languages at each entrance to a store. Signs stating the contents of a source store and the risks arising from such sources are normally posted at the entrance. Units and establishments are responsible for procuring sufficient stocks of suitable signs, either obtained from commercial sources or manufactured locally. 15 If only a small number of minor sources are held, it is not necessary for a dedicated building to be provided as a store. Such items can be stored in a suitably demarcated lockable metal cabinet within a general store. The cabinet is to be treated as the dedicated source store; thus the storage requirements listed above will also normally apply to the cabinet. Advice is to be sought from the RPA as to the type of cabinet that is appropriate. 16 Very large and bulky items (such as thoriated engines) or items in temporary storage/transit not stored in a dedicated building are to be stored in dedicated areas of storage buildings that are clearly demarcated. All such items are to be kept in their transit boxes where practicable. All relevant storage requirements will apply to the dedicated storage area. Advice is to be sought from the RPA on the storage requirements.

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17 Stores specifically allocated for storing radioactive materials are only to contain radioactive materials, their containers, associated handling tools and shielding materials. No other materials are to be kept within the store. 18 No corrosive, flammable or explosive substances are to be taken into or stored in any building used as a radioactive store. 19 No beverages, foodstuffs, or associated items (e.g. cutlery) are to be taken into or stored in any radioactive store. Radiation sensitive materials, such as radiographic film, are not to be stored in the vicinity of radioactive materials. 20 With the exception of High Activity Sealed Sources (HASS) (see paragraph 21), keeping portable sources in a vehicle overnight is only acceptable if it is not reasonably practicable to provide or make use of a proper store and if the vehicle is locked and kept in a secure place, such as a locked compound. HASS sources must not be kept in a vehicle overnight under any circumstances. HIGH ACTIVITY SEALED RADIOACTIVE SOURCES AND ORPHAN SOURCES REGULATIONS 2005 21 HASS became subject to special permitting, control and transfer procedures from 31 December 2005 for new sources and from 31 December 2007 for those which were placed on the market prior to 31 December 2005. In addition to the MOD accounting arrangements set out in this leaflet, high activity sealed sources are to be accounted for on a HASS Record Form (see Leaflet 3) and are to be identified separately on the Annual Holdings Return as advised by Dstl ESD. RPA advice must be sought before acquiring a high activity sealed source. RADIATION (EMERGENCY PREPAREDNESS AND PUBLIC INFORMATION) REGULATIONS 2001 22 Where a premises holds large quantities of radioactive material, in excess of the values stated in Leaflet 3, Annex F, the radiation employer (e.g. CO, Head of Establishment) of that premises is to make or ensure that a Hazard Identification and Risk Evaluation (HIRE) assessment has been made. The required contents of the HIRE assessment and resultant actions are described in detail in Leaflet 3. ACCOUNTING FOR RADIOACTIVE MATERIAL 23 All radioactive materials including sealed sources, unsealed radioactive substances, articles containing radioactive materials and radioactive waste are to be accounted for. Appropriate records of all radioactive material holdings are to be kept and made available for inspection. 24 Where radioactive materials are fitted to aircraft, a radioactive source list stating the inventory of those items is to be included with the aircraft documentation (MOD Form 701); this is especially important when an aircraft is under maintenance at, or visiting, another unit or establishment. The responsibility for producing and maintaining the source list lies with the parent air station. This source list is to accompany the aircraft documentation and is to be made available to the local RSO. ACCOUNTING FOR RADIOACTIVE MATERIAL ON HM SHIPS DURING REFIT 25 Ships staff are to maintain control of radioactive material during maintenance/repair. Refit authorities and Fleet Maintenance Units with personnel working in areas containing radioactive material are to be supplied with a list of all radioactive items and information on their associated hazards. Local orders must ensure the safety of refit authority personnel during their work in compartments which contain installed sources. All radioactive material is to be mustered and accounted for prior to and on completion of maintenance/repair. The ships going into refit are to return as many radioactive items as practicable to Naval stores or remove them to a suitable lay-apart or other store. RADIOACTIVE MATERIAL SOURCE LISTS AND MUSTERS (SEALED SOURCES) 26 All radioactive items are to be entered onto a radioactive source list kept by the unit or establishment holding the items. An example of a radioactive source list is shown in Annex A.

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However, where all the information required for a radioactive source list is already held or can easily be adapted within other records i.e. Special Stores Register (AFG-8046), and can be readily presented to inspecting officers, then a separate radioactive source list need not be raised. This source list need not be a hard copy document; it can be in an electronic format. If an electronic form is used, a copy of the source list is to be saved periodically either electronically or as a paper copy so that the changes in the source list over time are recorded. An electronic version of the source list is available as a spreadsheet from Dstl ESD. 27 Radioactive source lists are to be kept up to date by an appropriate person on behalf of the CO of the unit or establishment. This is usually the RPS/WPS for each storage area. 28 A review of the total holdings of each nuclide at the establishments is to be undertaken to ensure they do not exceed those detailed on the establishments relevant environment agency notification (if held), or trigger the requirement for a HIRE assessment to be carried out (see Leaflet 3). 29 The location of each source or article containing a radioactive substance must always be known. For static sources, the source list record at Annex A is adequate. For sources which can be used in a variety of locations, a source movement log is to be kept and for sources issued out to individuals, an issue log is to be maintained. 30 Musters are to be conducted at a frequency appropriate to the movement of a source, its security of stowage and its potential for becoming damaged. The frequency of muster is to be decided by the unit or establishment, although advice can be sought from the RPA. The interval between musters must not exceed one month unless otherwise advised by the RPA. A record of the muster talking place is to be retained for at least two years. Typical muster frequencies are listed below: For portable sources such as radiography sources and mobile check sources, at the end of each working day. For installed or static sources, monthly and following maintenance or repair that could have affected the source.

31 An annual check is advisable to ensure that the accounting record is a true record. This can be conveniently linked to the requirement to provide Dstl ESD with an Annual Holdings Return as detailed in Leaflet 3. Any radioactive materials identified at this stage as being no longer required are to be transferred or disposed of through an appropriate transfer/disposal route. A record of the annual audit is to be kept by the unit or establishment. LIST OF UNSEALED RADIOACTIVE SUBSTANCES 32 Records of unsealed radioactive substances, non-radioactive items contaminated with radioactive materials and radioactive waste are to be kept for each unit and establishment in an unsealed radioactive substances list. Records are not, however, required for radioactive substances with a halflife of less of than 3 hours. 33 The list is to contain the following information: 33.1 33.2 33.3 Name and address of authority holding the source. Place where the source is normally kept. Date of receipt and origin of the source.

33.4 Nature of radionuclide and estimated activity, or dose rate at known distance from radioactive material and date of estimation or measurement. 33.5 Nature of container.

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33.6 Details of tests undertaken to demonstrate that the exterior of the container, and surrounding areas are not contaminated. 33.7 33.8 Date and details of removal of part of the source. Date and details of final disposal.

LEAK TESTS 34 It is to be ensured that any article containing or embodying a radioactive substance is tested for leakage, unless it is inappropriate to do so; the RPA will be able to provide advice on leak testing requirements and methods. The purpose of a leak test is to show that the mechanisms for preventing dispersal of radioactive substances are functioning as intended. The risk assessment (see Leaflet 2) is to identify potential ways in which containment could be lost and the likelihood of those scenarios occurring. The test method chosen and the frequency of testing is to be capable of detecting leakage of radioactivity before a radiation risk arises. A list of common sources which require leak testing is detailed in Annex C. The interval between leak tests will not normally exceed two years and in some cases, leakage testing might be required more frequently, for example when a sealed source is going to be retained beyond the recommended working life recommended for the source capsule by the supplier or manufacturer, or when it is used in an aggressive or corrosive environment. A suitable record of the leak test is required is to include the following: 34.1 34.2 34.3 The identification of the source or article which is the subject of the test. The date of the test. The reason for the test.

34.4 The methods of test, including, when the source or article has not been tested directly, a statement of what part of the device was tested and a statement as to whether this is likely to detect any leaking material. The method will include a statement of the pass/fail criteria. 34.5 34.6 34.7 34.8 Numerical results of the test. The result of the test (pass/fail). Any action taken if the source failed the test. The name and signature of the person carrying out the test.

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35 The current Dstl ESD leak test certificate fulfils the requirement of a suitable record of a leak test. The record of the leak test is to accompany the associated radioactive source if this source is transferred to another establishment. A copy is to be kept by the transferring establishment. 36 JSP 800 Vol. 4b Transport of Dangerous Goods by Road, Rail and Sea contains guidance on the transport of smears from units in the UK. Units outside the UK must send smears through established channels and not via the local postal system. INCIDENTS, OCCURRENCES AND ACCIDENTS 37 If a radioactive source is lost or stolen or if any radioactive substances on the source list or inventory cannot be accounted for the RPA and TLB Safety Authority are to be informed initially. In addition MOD, HSE, EA/SEPA/EHS and the police may also need to be informed. Damage to a source or accidental spillages or release of radioactive material may also require notification to the RPA, MOD, HSE and EA/SEPA/EHS. The procedures to be followed after a suspected or real loss or incident are detailed in Leaflet 14. ANNUAL HOLDINGS RETURNS 38 To enable MOD to apply equivalent arrangements to those set out under RSA93, Dstl ESD maintains a database of radioactive material holdings for all units and establishments. In order to ensure that this database is accurately maintained, units and establishments are to complete an Annual Holdings Return. The full detail on the requirements for Annual Holdings Returns is detailed in Leaflet 3. RECORDS 39 Radioactive source lists, records of leak tests and lists of unsealed radioactive substances are to be retained by the unit or establishment indefinitely following disposal of the item. However if the item is transferred to another MOD establishment, the period is 2 years (from the transfer date) for radioactive source lists, records of leak test and lists of unsealed radioactive substances. Source lists from ships that have been decommissioned and establishments that have closed are to be archived in accordance with JSP392 Volume 1, Chapter 11 requirements. RELATED LEAFLETS 40 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 2 Risk assessments Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Restriction of exposure to radiation Leaflet Title

14

Investigation, notification and reporting of unusual radiation events

16

Local orders for radiation safety

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LEAFLET 9 ANNEX A EXAMPLE RADIOACTIVE SOURCE LIST AND MUSTER SHEET Date next leak test due (if required)*

NSN (or other ref.)

Description

Isotope

Activity (Bq)

Serial No/ Quantity

Location

Date received/ removed

Transfer/ disposed to

Custodian

Date

Signed

Date

Signed

Date

Signed

Date

Signed

Date

Signed

Date

Signed

* See Annex C Leaflet 9 Annex A Page 1/2

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LEAFLET 9 ANNEX B RADIOACTIVE MATERIAL STORAGE SIGNS

Figure 1 GTLS Storage Sign

Radioactive Materials (GTLSs) are stored within this Cupboard


Radiation Protection Supervisor Telephone..
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Figure 2 Radioactive material storage area sign

Radioactive Material is stored within this Area


Radiation Protection Supervisor Telephone..

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Figure 3 Radioactive material storage cupboard sign

Radioactive Materials are stored within this Cupboard


Radiation Protection Supervisor Telephone..

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LEAFLET 9 ANNEX C LIST OF COMMON RADIOACTIVE ITEMS WHICH REQUIRE LEAK TESTING

Radioactive source type

Stores or NATO catalogue no.

Type and Original quantity of radioactive material 18.5 MBq Ra-226 37 MBq Co-60 (total)

Leak Test Required

CBRN training source type A CBRN training source type B CBRN training source type C CBRN training source type D CBRN training source type E CBRN training source type G CBRN training source type G Mk III CBRN training source type H CBRN training source type J * Type 1623A NIS 322XA Check source IS 610 Check source Calibrator for PDRM Test Mk 13NJ sample Test Mk 14NJ sample Test Mk 16NJ sample Mk 18NJ jig and source * Test Mk 20NJ source

0552/F12Z 6665-99-911-0015

Yes

0552/F12Z 6665-99-911-0016

Yes

0552/F12Z 6665-99-911-0017

37 MBq Co-60

Yes

0552/F12Z 6665-99-911-0018 0552/F12Z 6665-99-911-0019 0552/F12Z 6665-99-911-0098 6665-99-224-7975 12Z 2247975 0552/F12Z 6665-99-911-0099

185 MBq Co-60 925 MBq Co-60 185 MBq Co-60 740 MBq Cs-137

Yes Yes Yes Yes

3.7 MBq Ra-226 6665-99-911-0097 K107 6665-99-193-3906 12Z 114-8909 6Z/623-2897 K107 6665-99-376-2459 6Z/623-2897 6665-99-628-0572 K104/0552/6665-99-733-5728 K104/0552/6665-99-736-2883 K104/0552/6665-99-795-2016 K104/0552/6665-99-721-2707 K104/6665-99-736-4922

Yes

370 Bq Ra-226 111 kBq Natural Uranium 248 kBq Pu-239/ 43.8 kBq Am-241 24 kBq Am-241 46 kBq Am-241 555 MBq Sr-90 11.1 kBq Sr-90 3.7 kBq Cl-36 555 kBq Sr-90 22 kBq Sr-90 37 kBq Pu-239

Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes

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List of common radioactive items which require leak testing (continued)

Radioactive source type Test Mk 1NXS) Sample Mk 2NXS) Sample Mk 3NXS) Sample Mk 4NXS) Sample Mk 5NXS) Sample Mk 6NXS) Sample Mk 7NXS Calibration plaque Mk 2NCS Calibration jig and source AERE Type 1546A test IM 192 (APD) IM 239 (APD) Source PHR 51 Source CFR 3 Source AMR 2401 * Source AMR 2402 L1A1 (Proban) L3A1 (HED) * L4A1 (BED) * L9A1 (COT) TK30 Source in adjusted assembly Dose meter (PDRM) Test sample Leakmeter Model 61 Chemical agent monitor MCAD COLPRO CAM GID-3 Otto fuel monitor

Stores or NATO catalogue no.

Type and Original quantity of radioactive material Mk 2 -Mk6 Aggregate activity less than 2 kBq Sr90

Leak Test Required No No No No No No No Yes Yes Yes No No Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes See Leaflet 20 See Leaflet 20 See Leaflet 20 See Leaflet 20 See Leaflet 20

These 6 sources are known collectively as Calibration set Mk 1 NCS, K104/6665-99-220-5870

370 Bq Am-241 Not patternised Not patternised 0552/6665-00-691-2840 K101/0552/6665-01-415-5123 6665-99-0612 K107/4940-99-640-5477 NYA K107/4940-99-640-5476 Z5 6665-99-224-8293 Z5 6665-99-224-8294 Z5 6665-99-224-9015 Z5 6665-99-967-0491 NU 6635-99-739-7235 WO8 6635-99-785-5723 Z8 6665-99-119-6940 Z8 6665-99-119-8766 Z8 6665-99-220-9338 6625-99-654-0124 Z8 6665-99-225-3521 6665-99-809-0326 6665-99-609-8640 6665-99-292-4508 Z8 1065-99-765-5786 222 kBq Pu-239 185 MBq Ra226/Be 2.96 MBq Sr-90/Y90 3.7 kBq Tc-99 222 Bq Pm-147 37 kBq/g C-14 74 Bq Am-241 740 Bq Am-241 111.0 MBq Cd-109 1.2 MBq Cf-252 370 MBq Ni-63 370 MBq Ni-63 2.0 GBq Am241/Be 370 MBq Cs-137 1.4 TBq Co-60 12.95 MBq Sr-90 12.95 MBq Sr-90 40.7 MBq H-3 122.1 kBq C-14 370 MBq Ni-63 370 MBq Ni-63 555 MBq Ni-63 555 MBq Ni-63 740 MBq Ni-63 370 MBq Ni-63

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List of common radioactive items which require leak testing (continued)

Radioactive source type Meter survey radiac SIC MK10 NHA Mk 22NRS (SIRS) (Mk 28 NH detector) Mk22 NRS (SIRS) (Mk 29 NH detector) Mk 1 NRS (SIRS) (Mk 3 NH detector) Mk 10 NXS Th232 check source Gamma Alarm Monitor PNI 1248 Test Mk 18 NJ Source *TEST MK 7NXS SAMPLE Test Source Pu-239 Check Source Set 7 Piece Check Source Set 3 Piece Smoke Detectors

Stores or NATO catalogue no.

Type and Original quantity of radioactive material 18.5 kBq Sr-90 370MBq Ni-63 1.1 kBq Sr-90 2.6 MBq Sr-90 18.5 MBq Sr-90 1.11 kBq Th-232 1.1 kBq Sr-90 22.2 kBq Sr-90 50 Bq Am-241 220 Bq Pu-239 Max 3 kBqSr-90 Max 3 kBqCo-60 1 kBq Am-241 1 kBq C-14 1 kBq Sr-90 1 kBq Am-241 Am-241

Leak Test Required Yes Yes (annual) No Yes Yes Yes Yes Yes Yes Yes Yes

Z8 6665-99-911-0123 K103/6665-99-037-0455 K103/ 6665-99-197-1894 K103/ 6665-99-917-1194 K101/0552/6665-99-733-5339 K101/0552/6665-99-733-1142 K101/0552/6665-99-462-3935 K104/6665/01/441/0980 K104/6665-99-538-9196 K104/6665-99-721-2707 K104/6665-99-736-2887 K107/6665-99-664-2456 K104/6665-99-361-2834

K104/6665-99-549-9499 Various

Yes See Leaflet 18

* Sources are fragile and could be damaged by direct leak testing. Leak tests are to therefore only be carried out on the inside of the container in which the source is stored, following the procedure described in local orders or as agreed with the RPA. There is no minimum activity for a source below which a leak test is not required on a sealed source. However, where it is indicated that a source does not require leak testing, this decision has been made on the basis that 100% ingestion of the source would not result in a dose greater than 0.1 mSv and therefore poses a trivial radiological hazard.

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LEAFLET 10 MOVEMENT AND TRANSPORT OF RADIOACTIVE MATERIALS CONTENTS Para 1 3 4 5 6 8 9 10 11 14 16 18 19 20 Table 1 2 SCOPE 1 This leaflet addresses the radiation safety requirements for the movement and transport of radioactive materials. The requirements outlined in this leaflet apply to all types of packages containing radioactive material and to all modes of transport 2 The instructions on how to package and consign radioactive items for transport are given in JSP 800 Vol. 4b Transport of Dangerous Goods by Road, Rail and Sea and JSP 800 Vol. 4a Dangerous Goods by Air Regulations. For the transport of radioactive items other than excepted packages, (described in JSP 800), advice can be sought from the unit or establishments RPA. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health & Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly). Ionising Radiations Regulations 1999 (IRR99) (apply directly). Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Quality assurance programme Radiation protection programme Movement of radioactive material within an establishment Storage in transit Records Related leaflets Related publications Page Related Leaflets...............................................................................................................................4 Related Publications........................................................................................................................4

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DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 5 The Radiation Safety Officer (RSO) is to ensure that: A quality assurance programme for transport operations and a radiation protection programme for radiation safety arrangements are produced for the unit or establishment. The requirements for such programmes are outlined below. All sections that prepare or consign radioactive items for transport have access to the quality assurance programme and radiation protection programme. Quality assurance and radiation protection programmes are subjected to quality audits, those parts of the organisation moving or transporting radioactive materials are subject to compliance audits and systems are in place to follow-up on audit recommendations.

Radiation Protection Supervisor (RPS) 6 Where sites and establishments have an RPS appointed, the RPS is to ensure that all staff involved in the transport of radioactive materials comply with the requirements of the quality assurance programme and radiation protection programme. 7 The RPS is to ensure that the transport operation complies with the requirements of IRR99, in respect of radiation exposures to those handling the package en route and members of the public. Workplace Supervisor (WPS) 8 In cases where a WPS is appointed, the WPS is to ensure that all staff involved in the transport of radioactive materials comply with the requirements of the quality assurance programme and radiation protection programme. Employees 9 It is the responsibility of all employees to ensure that they are familiar with the content of the quality assurance programme and radiation protection programme and comply with them. Employees must also bring to the attention of the appropriate supervisor or manager any shortcomings they identify in the programme. QUALITY ASSURANCE PROGRAMME 10 Each unit or establishment is required to produce a quality assurance programme for the transport of radioactive materials. The programme will demonstrate how the unit or establishment, acting as consignor, carrier or consignee, complies with the regulations governing transport of radioactive material. For example, it could be in the form of a written instruction describing the procedure for transporting radioactive materials and how this procedure complies with the regulatory requirements. The programme must address the design, manufacture, testing, documentation, carriage, use, maintenance and inspection of:

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10.1 10.2 10.3 10.4 10.5

All special form radioactive material. All low dispersible radioactive material. All packages and packaging. All transport and in-transit operations. All special arrangements.

RADIATION PROTECTION PROGRAMME 11 Consignors, carriers and consignees are to establish a radiation protection programme to provide adequate instructions to restrict radiation exposure when transporting radioactive materials. The programme is to address such areas as: 11.1 11.2 The measures taken to ensure radiation exposures remain ALARP. Compliance with the occupational radiation exposure limits that apply.

11.3 Any requirement to segregate radioactive consignments from workers and members of the public; and 11.4 12 13 Emergency arrangements and contingency plans.

The RPA can be contacted for further advice on the radiation protection programme. The radiation protection programme is to be reviewed at least every 3 years.

MOVEMENT OF RADIOACTIVE MATERIAL WITHIN AN ESTABLISHMENT 14 When the movement occurs entirely within an establishment, i.e. not involving transport on public roads, the requirements of Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 are not applicable (even under MOD arrangements). However, the requirements of the Ionising Radiations Regulations 1999 still apply to movement within an establishment and therefore radioactive materials are to be moved: 14.1 In a suitable container to prevent the loss of radioactive material in transit, during loading and unloading. The container is to be labelled or marked to indicate the radioactive contents. Where the use of a container is not practicable (such as for items that are physically too large) the items are to be adequately packaged to prevent the loss of radioactive material in transit and labelled or marked. 14.2 In such a way that the radiation doses to individuals from packaging, loading, movement and unloading are kept as low as reasonably practicable. 14.3 Under written arrangements, when the criteria for controlled areas are exceeded and persons other than classified persons are employed (see Leaflet 5). 14.4 Accompanied by a written statement (e.g. Form 34D, Leaflet 4 Annex A) detailing the nature and quantity of the radioactive substance and the appropriate action to be taken in the event of accident, spillage or dispersal of the material. 14.5 14.6 In accordance with local orders (see Leaflet 16). Movement should normally take place during normal working hours.

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15 The consignor of the item(s) must make the consignee aware that the item(s) to be moved are radioactive and provide the consignee with details of the physical form, the nature of the radioactive material and its activity. The consignee must also have agreed to receive the item(s) prior to their consignment. STORAGE IN TRANSIT 16 Transport packages in transit are to be separated from undeveloped photographic and radiographic film by a distance such that the dose to the film will not exceed 0.1 mSv. They are to be physically separated from other dangerous goods unless they are part of the same equipment. 17 For packages other than excepted packages, there are limits on the quantity of such packages that can be stored together. The storage area is to be clearly demarcated by a physical barrier and appropriate warning signs displayed. Further advice on storage requirements can be sought from the RPA. RECORDS 18 A copy of each completed dangerous goods note as detailed in JSP 800 is to be retained by the establishment for a minimum period of 2 years after the date of consignment. RELATED LEAFLETS 19 Leaflets referred to in this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 4 5 16 Restriction of exposure Written arrangements for unclassified persons entering controlled areas Local orders for radiation safety Leaflet Title

RELATED PUBLICATIONS 20. Other publications referred to in this leaflet are shown in Table 2. Table 2 Related Publications Publication JSP 800 Vol. 4a JSP 800 Vol. 4b Publication Title Dangerous Goods by Air Regulations Transport of Dangerous Goods by Road, Rail or Sea

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LEAFLET 11 REQUIREMENTS FOR THE TRANSFER (INCLUDING RETURN TO STORES), SALE, LOAN AND GIFTING OF RADIOACTIVE MATERIALS AND RADIOACTIVELY CONTAMINATED ITEMS CONTENTS Para 1 4 5 6 7 8 9 10 17 26 27 30 31 32 33 35 Table 1 SCOPE 1 This leaflet covers the radiological safety requirements and arrangements to be followed for the transfer (including transfer within MOD and external to MOD), sale, loan and gifting of radioactive materials and radioactively contaminated items. The accumulation and disposal of radioactive waste is described in Leaflet 12. 2 This leaflet does not cover the requirements for the transfer or sale of contaminated, or potentially contaminated, land which is described in Leaflet 13. 3 This leaflet does not cover the requirements for transport of radioactive or contaminated items. JSP 800 Vol. 4b covers the requirements for transport of excepted packages by land and sea, JSP 800 Vol. 4a covers air transport in all other cases the Dangerous Goods Safety Adviser or RPA is to be consulted. Leaflet 10 gives the radiation protection requirements for movement and transport. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 4 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Return of radioactive items to the stores organisation of transfer to another MOD holder Sale and gifting of radioactive and contaminated items Sale of ships Gifting of radioactive equipment Sale and gifting of high-activity sealed radioactive sources Transfer of high-activity sealed radioactive sources Loan or hire of radioactive items Records Related leaflets Page Related Leaflets...............................................................................................................................7

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High activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASS) (parallel arrangements).

DUTIES Commanding Officer (CO) and Head of Establishment 5 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 6 The Radiation Safety Officer (RSO) is to ensure that the requirements of this leaflet are included in local orders, that appropriate personnel are briefed on the arrangements and that compliance with the arrangements is checked and audited. Radiation Protection Supervisor (RPS) 7 An RPS is to be appointed where areas are designated as controlled or supervised. Where an RPS is appointed they are to ensure that local orders are complied with, including the requirements of this leaflet. Workplace Supervisor (WPS) 8 In units or establishments where it is unnecessary to appoint an RPS, a WPS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety (see Leaflet 16). Employees 9 It is the responsibility of all employees to ensure that they comply with all relevant health and safety instructions including local orders and report any difficulties to the local RPS or WPS. RETURN OF RADIOACTIVE ITEMS TO THE STORES OR TRANSFER TO ANOTHER MOD HOLDER 10 The return of radioactive items to stores or transfer to another MOD holder does not require regulatory approval. This does not, however, relieve the supplier of such items from their statutory obligation to ensure that the recipient is provided with all relevant health and safety information. Specific requirements do apply which are detailed in paragraph 14. 11 Items incorporating radioactive substances that are returned to the stores organisation are not to be designated as radioactive scrap or waste. Such items may include radioactive valves, smoke detectors, equipments containing GTLSs and GTLDs, luminised (tritium or radium) items, sealed or closed sources, and equipments containing radioactive check sources. 12 Redundant or unserviceable items are normally to be returned to the appropriate stores organisation where the item will be assessed and arrangements made for repair or disposal through an approved route. The appropriate stores organisation is to be contacted before despatch to ensure that the items can be accepted and to obtain specific details on conditions of acceptance for items. 13 Contaminated items including those contaminated, or potentially contaminated, as a result of the Naval Nuclear Propulsion Programme (NNPP) are excluded from these arrangements. Unless an established arrangement exists, should any such items be identified, outside the NNPP, advice is to be sought from the RPA on their transfer or disposal. Items already specifically identified as radioactive waste are also excluded from these arrangements.

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14 It is essential that: 14.1 The receiving site (consignee) has a RSA93 Notification/Approval from the relevant environment agency to hold and/or dispose of prescribed radioactive materials, unless the articles are covered by an Exemption Order. Advice on which radioactive items can be accepted must be sought from the consignee in advance. 14.2 The sender (consignor) of the radioactive items informs the consignee of the intention to forward radioactive materials, describes them appropriately and obtains the agreement of the consignee that the radioactive items will be accepted. A valid consignors certificate for radioactive material must also accompany each consignment. The items must NOT be described as radioactive waste. 14.3 The appropriate transport requirements are followed in accordance with JSP 800 Vol. 4a or Vol. 4b and Leaflet 10. Where a carrier is used, the carrier of the radioactive items must be informed of the radioactive content of the items, be given adequate instruction by the consignor and appropriate documentation. The driver must also possess the appropriate ADR licence. 15 Items which fall into the following categories are not to be accepted by the consignee and are to be returned to the consignor where practicable unless an alternative means to rectify the situation can be immediately identified and agreed: 15.1 Radioactive items that originate from the NNPP (contaminated, activated/irradiated or containing radioactive sources) unless the consignee has specific approvals in place to receive such items and has agreed to each consignment in advance. 15.2 15.3 Items which are consigned without prior arrangements made with the consignee. Items which will breach the sites approved limits from the relevant environment agency.

15.4 Items which on receipt are proven by the consignee not to be properly described in the consignors certificate. 16 High-activity sealed radioactive sources (see Leaflet 3) are subject to additional requirements as outlined later. SALE AND GIFTING OF RADIOACTIVE AND CONTAMINATED ITEMS 17 The Disposal Services Agency (DSA) is responsible for the disposal by sale of all MOD surplus equipment. All surplus items identified as containing radioactive components or material should be notified to the Disposal Services Agency (DSA) by the organisation (unit, stores or equipment manager as appropriate) proposing them for sale. This organisation is to supply DSA with the following details of the hazards associated with these items: Description of items. Details of the components containing radioactive material and their location. Details of radionuclides and estimates of activity. Details of contamination levels (advice is to be obtained from an RPA if contaminated items are to be sold). Details of any requirement for the eventual recipient to hold an appropriate environment agency registration or to provide a notification to HSE. Details of any exemptions to registration together with any limiting conditions under which the exemptions would apply.

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Description of the hazards associated with the items. Any other risks involved. Any other risks that may be deemed relevant.

18 It is vital that the unit declaring the disposal provides the information above to DSA, taking advice from the RPA if necessary. 19 Although the disposal of items by sale does not require regulatory approval, DSA, before agreeing to the sale, must obtain confirmation that a buyer has any necessary RSA 93 registrations in place or that an exemption applies. DSA must also check that the prospective buyer has carried out any necessary IRR 99 HSE notifications (or, in the latter case, will undertake the notification 28 days before receipt). Where items are to be sold to overseas purchasers, advice is always to be sought from the TLB Safety Authority (e.g. CESO for the TLB area) and the RPA as to specific requirements of the recipient State, as to any restrictions or requirements on the shipment of items and as to the appropriate level of information and cooperation required by UK statute. 20 MOD policy (see Volume 1 Chapter 4) prohibits the sale of items containing radium-226 to members of the general public hence such items must not be offered for sale to the public, nor are they to be offered to potential resale or collectors outlets. 21 Once DSA has received comprehensive information from the declaring unit, DSA will be in a position to decide if the items are suitable for sale and radioactive components/material are to be left in position, DSA is to issue all prospective buyers of the items with details of the radioactive hazards associated with them. The agreement to sell radioactive items must clearly identify the point at which title (and associated liability) for the material transfers this may, for example for a contractor collecting the equipment, be at the point at which the contractors vehicle leaves the MOD site. 22 Regardless of the obligations on DSA, detailed above, the unit transferring or despatching the items, whether part of the stores organisation or otherwise, also has responsibilities and must comply with its environment agency terms and conditions relating to the sale or supply of the radioactive material. In particular, before consigning the items, the despatching unit must be satisfied in the following respects: 22.1 That the recipient holds an RSA 93 registration appropriate for the items being consigned DSA should confirm that this is the case. 22.2 That the recipient has been provided with any necessary safety information relating to the items including the description of the radioactive material DSA should confirm that this is the case. 22.3 That the recipient has agreed to receive the consignment DSA should normally confirm that this is the case. 22.4 That the item(s) are marked and labelled to show that they are radioactive material.

23 If items or equipment cannot be sold for the purpose they were originally designed, the radioactive component/material is to be removed (see also the next paragraph) and returned to the stores organisation and the remaining items monitored for contamination. If the remaining items are uncontaminated, radiation warning signs are to be removed prior to disposal. 24 Removal of radioactive components from equipment is likely to be a specialised activity requiring specialised skills and equipment. RPA advice is to be sought as to the requirements for this work to be carried out in a designated area and as to the training and supervision needed for the work. Components falling into this category are: 24.1 Components containing radioactive sources, such as smoke-detection systems, radiationmonitoring equipment and some targets and drogues.

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24.2 Luminised equipments and components, such as control dials, luminised markers and some gauges. 24.3 24.4 Components containing GTLSs. Aircraft counter-balance weights containing depleted uranium.

25 Further Information on the disposal of items by sale is detailed in Pamphlet 9 of JSP 336 Defence Supply Chain Manual. Sale of Ships 26 Disposal of any HM ships placed on the Commercial List (also known as the Disposal List) except those handed over to other Governments from the active fleet is to follow the procedures given in the Disposal Reserve Ship Manual Vol 1. Copies of this manual are available from Disposal and Reserve Ships Organisation, Portsmouth (DARSO). It is MOD policy that all ships are monitored for radioactive items prior to disposal. Records are to be retained by DARSO. Gifting of Radioactive Equipment 27 Surplus radioactive items may only be gifted with the approval of the equipment manager - MOD does not gift to private museums, UK citizens, companies or charities. 28 In addition to meeting the financial policy on gifting (see JSP 462 Financial Policy Manual), surplus radioactive items may only be gifted or donated if the recipient organisation holds the appropriate RSA93 registrations or notifications. In supplying the item(s), the final MOD holder must comply with the appropriate environment agency terms and conditions and follow the same procedures detailed above for the sale of items. In particular, arrangements regarding transfer of title must be clearly stated and agreed. 29 Further details on gifts of radioactive equipment to museums are covered in Leaflet 31. Sale and gifting of high-activity sealed radioactive sources 30 There are a number of additional requirements to be followed for the transfer of high-activity sealed radioactive sources (see below). TRANSFER OF HIGH-ACTIVITY SEALED RADIOACTIVE SOURCES 31 Strict terms and conditions are applied to holders of high-activity sealed radioactive sources (HASS) (see Leaflets 3 and 9). These terms and conditions, which must be complied with, include requirements for transfer of HASS as follows: 31.1 Before a HASS may be transferred (regardless of whether this is a sale, lease or transfer within or external to MOD), the holder must first ascertain that the recipient holds the appropriate HASS authorisation or notification from the relevant environment agency or, in the case of transfer to a nuclear site that the recipient holds the appropriate authorisation from the nuclear regulator. Written confirmation that this is the case must be obtained. 31.2 The transfer of title and liability for safe management and disposal of the source when it becomes disused must be established and agreed in writing prior to transfer of the source. 31.3 The source must be supplied to the recipient accompanied by written information and photographs, its identification number, how it is marked, details of the radioactive content and, where appropriate, the identification number of the source container. 31.4 Containers must be marked with the container identification number, the source identification number, the name and activity of each radionuclide contained in the source at the date of receipt and the word radioactive and the ionising radiation symbol.

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31.5 Holders must amend the HASS record in the specified format (see record form at Leaflet 3) to show the date of transfer, the name of the recipient, the address of the recipient, the type of recipient (e.g. manufacturer, supplier, next user, short or long-term storage, disposal site etc) and the recipients permission number. 31.6 Within 14 days following the transfer, the holder must send a copy of the record showing the transfer details to the appropriate environment agency. If the transfer is to a nuclear site, then the holder must also send to the appropriate environment agency a copy of the acknowledgement of receipt of the HASS. 31.7 Transport of the source must be carried out in accordance with the appropriate transport regulations and radiation protection requirements (see Leaflet 10). Where a carrier is used to transfer the source, the carrier is not considered to be a holder and therefore the record is to show details of transfer to the new holder and not the carrier. LOAN OR HIRE OF RADIOACTIVE ITEMS 32 When radioactive items are loaned or hired, the supplying MOD custodian must comply with the previous requirements and procedures for sale, donation or transfer of equipment as appropriate. In addition, the MOD custodian must retain the relevant notifications/approvals to hold the radioactive material and retain the appropriate facilities, safety and environmental management arrangements and qualified staff to ensure safe and effective storage and control of the item(s) on their return. RECORDS 33 Radioactive source lists, records of leak tests and registers of unsealed radioactive substances are to be retained by the ship, unit or establishment indefinitely following the disposal, gifting or transfer to DSA of the item. However if the item is transferred to another MOD establishment, the period is 2 years (from the transfer date) for radioactive source lists, records of leak test and registers of unsealed radioactive substances. Source lists and source registers from ships that have been decommissioned and establishments that have closed should be archived in accordance with MOD policy described in Chapter 11. Records of items on loan must be kept throughout the period of loan by both those receiving and despatching loaned items. 34 Where clearance certificates are issued with items or materials, they should include the following features: a. Unique identification (as far as practicable) of the item or material cleared; b. Identification of the documentation which supports the certificate; c. Identification of the legislation with which it is compliant d. A statement of caveats where applicable (e.g. radioactivity not detectable by the measurement systems used; presence of other toxic substances etc); e. A statement of recommendations by and signature of a nominated suitably qualified and experienced person (SQEP) concerning compliance with legislation and future use or disposal; f. Authorisation by and signature of the owner of the item or material; g. A date of issue and period of validity of the certificate; h. A statement of responsibilities for keeping the documentation and certificate i. A signed confirmation of release and date; j. The statement For all regulatory and control purposes, this material is not radioactive.

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RELATED LEAFLETS 35 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 3 Leaflet Title Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Storage and accounting for radioactive materials Radiation protection aspects of transport and movement of radioactive materials Accumulation and disposal of radioactive waste Radioactively contaminated land Radiation safety arrangements for museums Dangerous goods by air regulations

9 10 12 13 31 JSP 800 Vol. 4a JSP 336 JSP 800 Vol. 4b JSP 462

Defence supply chain manual Transport of dangerous goods by road, rail or sea

Financial policy manual

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LEAFLET 12 ACCUMULATION AND DISPOSAL OF RADIOACTIVE WASTE CONTENTS Para 1 2 8 9 10 11 12 13 14 15 18 22 25 27 32 36 39 Scope Introduction Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Radiation dose limits for the public from radioactive waste Excluded or exempt radioactive material Identification of clean or exempt radioactive waste Application for agreement to dispose of radioactive waste above exemption levels Accumulation of radioactive waste Disposal arrangements Disposal of radioactive special/hazardous wastes Recording of disposals Disposal of waste overseas

Table 1 Annex: A B SCOPE Current exemption orders of relevance to MOD radioactive sources Radioactive waste disposal forms

Page Legal and MOD mandatory requirements .......................................................................................6

1 This leaflet covers the requirements for accumulation and disposal of radioactive waste. The transfer, sale, re-use or recycling of items containing radioactive material are addressed in Leaflet 11. INTRODUCTION 2 The disposal of radioactive material in the UK is controlled by the Radioactive Substances Act 1993 (RSA 93) and associated Exemption Orders (EOs) and Agreements (those made under the Radioactive Substances Act 1960 (RSA 60) and agreements remain in force until they are replaced by new EOs made under RSA 93 or new agreements). RSA 93 does not apply to MOD, but the Secretary of State for Defence has stated that standards and arrangements will be introduced which will be, so far as is reasonably practicable, at least as good as those required by legislation. Government Policy on radioactive waste management is given in the Review of Radioactive Waste Management Policy: Final Conclusions (Cm2919, July 1995). The MOD policy for the management of Defence related radioactive wastes is given at JSP392 Volume 1 Chapter 5. 3 Before any radioactive material can be declared as waste or accumulated an Approval must be obtained from the appropriate regulatory authority unless RSA93 specifically excludes that type of radioactive material or it is the subject of an Exemption Order.

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4 A suitably qualified and experienced person or organisation must be consulted at the earliest opportunity to advise on regulatory issues associated with declaration, accumulation or disposal of radioactive waste. This person or organisation will often also be the appointed radiation protection adviser. 5 Most units or establishments will not accumulate or dispose of radioactive waste, but will return items via the appropriate stores organisation as redundant items. It will normally be the duty of the stores organisation to declare the items as waste, if they cannot be utilised elsewhere. 6 Disposal of radioactive material that is not waste, for example by sale, loan or transfer, is addressed in Leaflet 11. 7 Radiation protection relating to transport of radioactive material is addressed in Leaflet 10. Transport operations must be undertaken in accordance with JSP800 Vol. 4b; Transport of Dangerous Goods by Road, Rail and Sea or JSP800 Vol. 4a Transport of Dangerous Goods by Air . STATUTORY REQUIREMENTS 8 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety Regulations 1999, the following specific legislation may apply: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) and associated Exemption Orders (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly). High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASS2005) (parallel arrangements).

DUTIES Commanding Officer (CO) and Head of Establishment 9 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 10 If appointed and where authority has been delegated the Radiation Safety Officer (RSO) will normally discharge the duties of the Commanding Officer with respect to seeking Approvals from the appropriate regulator. Radiation Protection Supervisor (RPS) 11 A Radiation Protection Supervisor must be appointed where it is necessary to designate areas as controlled or supervised (see Leaflet 4). Where an RPS is so appointed they are to ensure that the work is carried out in accordance with local procedures or system of work which should address the requirements of this leaflet.

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Workplace Supervisor (WPS) 12 In units where it is unnecessary to appoint an RPS, a WPS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety. In addition to those duties, a WPS may be required to assist the RSO in the preparation of documentation requesting the Approval to accumulate or dispose of radioactive waste for submission to the regulatory authority with assistance of the RPA. Employees 13 It is the responsibility of all employees to ensure that changes to holdings of or work with radioactive material or radiation generators are notified to the RPS or other appropriate person and that all relevant local instructions are complied with. RADIATION DOSE LIMITS FOR THE PUBLIC FROM RADIOACTIVE WASTE 14 In addition to the requirement to keep any radiation exposure as low as reasonably practicable (ALARP) under IRR99 the process of seeking Approval from the EA or other regulator will require an assessment to be made, as part of the planning process for radiation protection, to determine whether the following maximum doses could be received by individuals as a result of the planned activity: 14.1 0.3 mSv per year from any source from which radioactive discharges are first made on or after 13th May 2000. 14.2 0.5 mSv per year from the discharges from any single site.

EXCLUDED OR EXEMPT RADIOACTIVE MATERIAL 15 Small quantities of certain radioactive material are deemed either excluded or exempt from certain requirements of RSA93 if an Exemption Order exists for that specific material. A list of Exemption Orders is given at Annex A. Typically, Exemption Orders set out conditions which, when complied with, allow the disposal of limited quantities of radioactive waste without the need to obtain Approval from the appropriate environment regulator. 16 Disposal of radioactive material under the relevant Exemption Order may only take place, following consultation with the RPA, provided that: 16.1 16.2 16.3 The item contains only exempt radioactive material. The disposal is not routine. All conditions in the relevant Exemption Order are complied with.

16.4 Suitable records are kept (including description of the item, isotope, activity, date of receipt, method of disposal, and date of disposal) and the disposal is noted on the Annual Holdings Return. 17 Large quantities of very low level radioactive waste or exempt wastes such as thoriated engine casings and spoil from the remediation of sites should be disposed of through the Disposal Services Agency, MODs central contract for the disposal of hazardous and special wastes. The appointed RPA will advise on whether this route or direct disposal via a waste contractor is most appropriate. Further details can be obtained from DSA, Zone C, 2nd Floor, St Georges Court, 2-12 Bloomsbury Way, London, WC1A 2SH Tel 0207 3053096. Records as detailed in Paragraph 16.4 are still required to be kept if this disposal option is used.

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IDENTIFICATION OF CLEAN OR EXEMPT RADIOACTIVE WASTE 18 There are many instances, such as in the decommissioning of facilities, where items (e.g. tools, bricks etc) or materials (e.g. soil) may be found to be contaminated or potentially contaminated to low levels with radioactive material. In these situations it is important to correctly quantify the degree of contamination to enable appropriate disposal routes to be identified and applied. 19 To support this, the MOD has contributed to the Code of Practice (COP) Clearance & Exemption Principles, Processes and Practices for use by the Nuclear Industry Issue 1. This document sets out industry good practice for identifying and sentencing exempt radioactive material. A copy of the code of practice is included on the CD with this JSP 392. Alternatively, it is available at http://www.ukaea.org.uk/news/clearance_and_exemption.htm. 20 The COP interprets current legislation and provides, through the use of flow charts, clear guidance for commonly found material types. Those seeking to manage the waste disposal process, working with their RPA, should incorporate the requirements of the COP into local procedures and practices for the disposal, re-use or recycling of exempt radioactive material (see Leaflet 11). 21 Following local procedures that incorporate the principles of the COP will generally be sufficient to enable individual units and establishments to demonstrate that material is being appropriately sentenced in compliance with legislative and MOD requirements. APPLICATION FOR AGREEMENT TO DISPOSE OF RADIOACTIVE WASTE ABOVE EXEMPTION LEVELS 22 No radioactive waste disposals other than those covered by an appropriate Exemption Order are to be made by MOD establishments or equipment managers without first obtaining an Approval from the Regulatory Authority (Environment Agency, Scottish Environment Protection Agency or the Environment and Heritage Service in Northern Ireland). Advice on the arrangements for disposal of radioactive material through an approved route should be sought from the RPA or other suitably qualified person. 23 Equipment managers, units and establishments without local RPAs, who require to dispose of radioactive waste, must seek assistance from Dstl RPA Body as soon as possible. The Regulatory Authorities require payment for issuing and maintaining Approval documents. Dstl RPA Body will arrange any necessary payment and should therefore be advised when an Approval is required to ensure that the appropriate financial provision can be made. Dstl RPA Body will then conduct the negotiation with the appropriate Regulatory Authority on behalf of the equipment manager, unit or establishment and arrange any necessary payment. A suitable Approval is then issued by the Regulatory Authority through Dstl RPA Body. MOD establishments with their own resident RPA may apply directly to the Regulatory Authority concerned, but must keep Dstl ESD informed by letter, as detailed in Leaflet 3 to ensure that funding arrangements are put in place. 24 Approval documents provided by the Regulatory Authority via Dstl ESD are to be held by the unit or establishment, and a copy of these documents is to be displayed on the unit or establishment main notice board, for example the SHEF notice board of the facility holding the Notification or Approval. MOD (Army) establishments are to send an additional copy to CESO (Army). ACCUMULATION OF RADIOACTIVE WASTE 25 Radioactive waste is considered to be accumulated if it is stored at a site for more than 3 months. At the end of this 3-month period, radioactive waste must be disposed of, either in accordance with a current Approval for disposal or an exemption order. Where disposal within this timescale would not be practicable an Approval for the accumulation of waste over a longer period must be obtained from the appropriate regulatory authority. Agreement to accumulate waste is required from the appropriate TLB Safety Authority who will then instruct Dstl ESD to obtain an Approval from the regulatory authority.

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26 Radioactive waste is to be disposed of in accordance with the terms of any Approvals and exemptions. Where it is necessary to accumulate waste, the waste should be stored in accordance with the requirements of Leaflet 9, and comply with the requirements of any conditions set out in the Approval. DISPOSAL ARRANGEMENTS 27 Unless an exemption order applies, accumulation, discharge or disposal of radioactive waste can only take place after an Approval has been received. The disposal must take place in accordance with the conditions of the Approval. 28 If the radioactive material is a sealed source then it may, subject to compliance with certain conditions, be disposed of under the terms of the Waste Closed Sources Exemption Order without the need for an Approval. For this exemption order to apply the source must be disposed of via a person or organisation who is authorised under RSA93 to dispose of similar material, or via a person or organisation who produces radioactive material of the same type as is contained within the source. This could be the original source manufacturer or other user who has the appropriate Approvals in place. Records must be retained that detail: 28.1 28.2 28.3 The date of disposal of the waste source. The name and total activity of each of the radionuclides contained; and The name and address of the person to whom the source was sent or of who removed it.

29 Paragraph 28 contains summary details of the requirements only. Additional advice should be sought from the appointed RPA or suitably qualified person before applying this exemption order. 30 Once a unit or establishment has no further requirement to dispose of radioactive waste, they are to inform the TLB Authority and Dstl ESD, who will initiate proceedings to cancel the Approval. 31 It should be noted that High Activity Sealed Sources (HASS) should not normally be disposed of, but will generally be transferred to an organisation approved to accept such sources, for example a manufacturer, see Leaflet 3. DISPOSAL OF RADIOACTIVE SPECIAL/HAZARDOUS WASTES 32 In some circumstances, hazardous waste may become contaminated with radioactive material. Where this applies, and such substances are therefore declared as radioactive waste, the advice of the RPA is to be sought as special disposal and recording procedures may need to be followed. Where an equipment manager, unit or establishment is uncertain whether or not a substance is a listed substance advice should be sought from the relevant RPA. The disposal of certain radioactively contaminated hazardous wastes may also be available through the contract detailed in Paragraph 17. 33 Hazardous waste is waste which exhibits one or more of the properties that are hazardous to health or the environment. These hazardous properties are listed in the European Commission Hazardous Waste Directive (91/689/EC) as the Hazardous Waste List and incorporated into the revised European Waste Catalogue (EWC) as a six digit code denoted with an asterisk 34 In addition to radioactivity properties of waste that render them hazardous include: Explosive; oxidising; highly flammable and flammable; irritant; harmful; toxic; carcinogenic; corrosive; infectious; teratogenic; mutagenic; substances and preparations which emit toxic or very toxic gases in contact with water, air or an acid; substances and preparations capable by any means, after disposal, of yielding another substance e.g. leachate, which possess any of the characteristics listed above; and ecotoxic.

35 Hazardous or special waste is subject to separate regulation and guidance should be sought from the appropriate local Environment Officer or SHEF representative.

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RECORDING OF DISPOSALS 36 A record of all disposals of radioactive waste is to be kept by the equipment manager, unit or establishment disposing of the waste. Records are required for some disposals under an exemption order. Advice should be sought from the RPA or suitably qualified person. Records of disposals are to be kept indefinitely or for such time as specified in the disposal Approval document. Suitable forms are provided at Annex B and should be used for recording solid and liquid waste disposals, respectively. Details of gaseous or airborne particulate waste disposals should be recorded on an appropriate form containing the following information: 36.1 36.2 36.3 Details of discharge. Radionuclide, its chemical form and total activity. Date, time and duration of release.

37 A statement of all radioactive waste disposals made in that calendar year is to be forwarded to Dstl ESD by all Naval (including ships and submarines), RAF, Army and Defence Agency units and establishments at the end of each calendar year. This should reach Dstl by 31 March of the year following that being reported on. To assist in this procedure, Dstl will distribute blank copies of the reporting form during January of each year, included as a section of the Annual Holdings Return. Additional forms can be provided on request. 38 It should be noted that radioactive items returned to stores or permanently transferred to another establishment are not classed as waste and should not be included on the Disposals page of the Annual Holdings Return. DISPOSAL OF WASTE OVERSEAS 39 Establishments situated overseas are to dispose of radioactive waste in accordance with local national regulations. Where regulations on the disposal of radioactive waste are believed not to exist, advice should be sought from Dstl RPA Body, or the relevant service authority. LEGAL AND MOD MANDATORY REQUIREMENTS Table 1 Legal and MOD mandatory requirements Requirement HSE Notification Risk assessment Accounting Approval to accumulate or dispose** Re-use, recycling Local orders Designated areas Transport *JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environmental Protection Agency (SEPA) for Scotland and Environmental and Heritage Service for Northern Ireland (EHSNI). See also JSP800 Vol. 4b Transport of Dangerous Goods by Road, Rail and Sea Applicable Comments Keep a copy indefinitely. Review as appropriate. HSE will not provide acknowledgement of this Equipment specific risk assessments or prior risk assessments may be required Storage and retention of disposal records Copy information to Dstl RPA Body Good practice Should address disposal requirements for redundant equipment or waste items Related leaflet* 3 2 9 3 11 16 4 10

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LEAFLET 12 ANNEX A CURRENT EXEMPTION ORDERS OF RELEVANT TO MOD RADIOACTIVE SOURCES

1 The following exemption orders remain current. application of these exemption orders. Title

Advice should be sought from the RPA on

Statutory Instrument No. 953 1991 No. 477 1967 No. 1797

The Radioactive Substances (Smoke Detectors) Exemption Order (as amended 1991) 1980 The Radioactive Substances (Electronic Valves) Exemption Order 1967

The Radioactive Substances (Luminous Articles) Exemption Order 1985

1985 No. 1048

The Radioactive Substance (Testing Instruments) Exemption Order 2006

2006 No. 1500

The Radioactive Substances (Waste Closed Sources) Exemption Order 1963 The Radioactive Substance (Prepared Uranium and Thorium Compounds) Exemption Order 1962 The Radioactive Substance (Hospitals) Exemption Order 1990 The Radioactive Substance (Gaseous Tritium Light Devices) Exemption Order 1985 The Radioactive Substance (Substances of Low Activity) Exemption Order (as amended 1992) 1986 The Radioactive Substances (Uranium and Thorium) Exemption Order 1962 The Radioactive Substances (Phosphatic Substances, Rare Earths, etc) Exemption Order 1962 The Radioactive Substances (Schools etc) Exemption Order 1963

1963 No. 1831

1962 No. 2711

1990 No. 2512

1985 No. 1047 No. 1002 1992 No. 647 1962 No. 2710

1962 No. 2648

1963 No. 1832

The Radioactive Substances (Exhibitions) Exemption Order 1962 NOTE

1962 No. 2648

The above Exemption Orders apply to England and Wales. The corresponding Exemption Orders for Scotland and Northern Ireland have identical or similar wording, but carry different Statutory Instrument number.

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LEAFLET 12 ANNEX B RADIOACTIVE WASTE DISPOSAL FORMS CONTENTS Table B1 B2 Radioactive waste disposal form (solid) .......................................................................................1 Radioactive waste disposal form (liquid) ..................................................................................... 2

Table B1 Radioactive Waste Disposal Radioactive Waste Disposal Surface dose rate Sv h-1 Ship or establishment ___________________

Package no and date

Description & nuclide

Surface contamination Bq cm-2

Place and method of disposal

Remarks (estimated total activity if known)

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Table B2 Radioactive waste disposal form (liquid)

RADIOACTIVE WASTE DISPOSAL FORM (LIQUID) Ship or establishment Unit reference no and date Surface dose rate Sv h-1 Surface contamination Bq ml-1 Specific activity Bq ml-1 Place and method of disposal

Description & nuclide

Volume ml

Total activity Bq

Remarks

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LEAFLET 13 ASSESSMENT AND MANAGEMENT OF RADIOACTIVELY CONTAMINATED LAND CONTENTS Para ASSESSMENT AND MANAGEMENT OF RADIOACTIVELY CONTAMINATED LAND Scope Statutory Requirements and Parallel Arrangements Guidance Advice Duties Commanding Officer Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Employees Risk Assessment Requirements for Assessment and Management/Remediation Work on Sites/Establishments Incidents Annual Drigg Allocation Monitoring Records Related Leaflets Page Related Leaflets...............................................................................................................................5 ASSESSMENT AND MANAGEMENT OF RADIOACTIVELY CONTAMINATED LAND SCOPE 1 This leaflet is aimed principally at providing duty holders with guidance on the assessment and management of radioactively contaminated land on MOD sites and establishments and to sign post relevant documents and sources of specialist advice. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 The scope of the Contaminated Land Regime as enacted under Part 2A of the Environmental Protection Act 1990 in England, Wales and Scotland has been extended to cover radioactively contaminated land. 3 This extends the Contaminated Land Regime now applies to radioactively and chemically contaminated land on non nuclear defence sites. Details about the Regime and overall legal position are presented in Volume 2, leaflet 2 of JSP 419: Sustainable Development and Environment Manual as well as Defence Estates Practitioner Guide 01/07 Contaminated Land Management: land Quality Assessment (LQA) Management Guidance. 4 MOD nuclear sites will be regulated separately owing to the fact that MOD is bound by the liability provisions arising from the Paris Convention as transposed under section 7 of the Nuclear Installations Act 1965. 5 In addition to Part 2A the following specific legislation applies directly to radioactively contaminated land: Management of Health and Safety at Work Regulations 1999 (applies directly).

1 2 6 8 10 11 12 14 15 16 19 20 21 23 Table

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Ionising Radiations Regulations 1999 (IRR99) (applies directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements).

GUIDANCE 6 General guidance on MOD policy and approach to the assessment and management of contaminated land is provided by: 6.1 Leaflet 2 - Volume 2 of JSP 418 MOD Sustainability and Environment Manual

6.2 DE PG 01/07 Contaminated Land Management Quality Asessment (LQA) Management Guide 7 Specific guidance on the assessment (site characterisation) and management of radioactively contaminated land on nuclear and defence sites is provided by the Safegrounds Project initiative which is supported by MOD and has produced various guides which can be downloaded for free from the Safegrounds web site at: www.safegrounds.com. The web site also contains the current HSE and Environment Agency Guidance. Further information and guidance is also available in Chapter 29 of JSP 392, Instructions for Radiation Protection. ADVICE 8 Specific RPA advice is available from Dstl ESD.

9 Specific advice and support on contaminated land issues is available from Defence Estates Construction Support Team based at: St George's House, Kingston Road, Sutton Coldfield, West Midlands B75 7RL. DUTIES Commanding Officer 10 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and to secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment against risks to their health or safety arising from the MOD work activities (egg. the general public). This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 11 The Radiation Safety Officers (RSO) role is essentially one of co-ordination and audit, ensuring compliance with the safety management arrangements. In the context of this leaflet, the RSO or nominated competent person is to co-ordinate the assessment and management of radioactively contaminated land. Radiation Protection Supervisor (RPS) 12 Where sites and establishments have areas, including areas of radioactively contaminated land, designated as controlled or supervised (see Leaflet 4), radiation employers must appoint an RPS for each designated area concerned. The prime duty of the RPS is to ensure compliance with the IRR99 in respect of work carried out in the designated area be it survey work or remediation in practice, the RPS will achieve this by ensuring that work is carried out in accordance with the local orders for radiation safety (see Leaflet 16). Please note that survey and site investigation work to define the nature and extent of radioactively contaminated land do not routinely require designation as controlled or supervised areas. However, intrusive investigations into areas of known activity will require careful planning and control by the RPS.

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13 The RPS is to also ensure the adequate control of the radioactive material/contaminated land through compliance with the requirements of the RSA93 and associated exemption orders. This is particularly important during remediation of radioactively contaminated land on non nuclear defence sites where the RPS will need to arrange for the accumulation and disposal of the radioactive material. Employees 14 It is the responsibility of all employees to ensure that they are familiar with the content of local orders including those relating to radioactively contaminated land and comply with them. Employees must also bring to the attention of the appropriate supervisor or manager any shortcomings they identify in the arrangements for the assessment and management of radioactively contaminated land including the arrangements for the accumulation and disposal of the radioactive materials. RISK ASSESSMENT 15 Where work involves ionising radiation there is a requirement to ensure that the risk assessment considers radiological as well as non-radiological hazards. The requirement for a prior risk assessment, (which must be made before a new activity involving work with ionising radiation begins) complements this risk assessment. The form of these risks assessments and the actions to be taken arising from it are detailed in Leaflet 2. REQUIREMENTS FOR ASSESSMENT AND MANAGEMENT/REMEDIATION WORK ON SITES/ESTABLISHMENTS 16 Preliminaries: 17 Prior 28 days notification to HSE where radioactively contaminated land is known or suspected Plan work and prepare method statements identifying hold points and dose rates within which the work can be done Undertake risk assessment Formulate contingency plan to address incidents and accidents Provide dosimetry to enable exposure to be monitored Seek advice from RPA and Defence Estates as required

Site Surveys/Investigations: Surveys/investigations do not routinely require designation of controlled or supervised areas or require classified workers Undertake surveys on a grid Intrusive investigations into areas of known activity are to be carefully planned and controlled Personnel should wear appropriate PPE and dosimetry, monitor clothing and footwear regularly, do not eat, drink or smoke during work, cover open wounds with waterproof plasters prior to work and remove PPE and wash prior to leaving site. Sufficiently detailed records are to be kept. Advice on record retention sis currently being developed by the CIRIA Safegrounds initiative and should be available from their website later this year. Do not remove radioactive artefacts as samples but take soil/material adjacent to the artefact for analysis

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Record dose rates at measured distance from the artefact (1m, 0.5m etc) Samples suspected to contain radioactive material should only be dispatched to an appropriate laboratory following agreement and arrangements for disposal have been made. Every effort should be made to ensure that samples fulfil the requirements for and are dispatched as 'excepted packages' in accordance with the Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007. Further details are available from Leaflet 10 and JSP 800 Vol. 4b. Seek advice from RPA and Defence Estates as required

18

Management/Remediation: Ensure adequate controls and containment Ensure use of a competent contractor. Advice and assistance can be obtained from Defence Estates. Ensure adequate waste control and minimisation Ensure adequate environmental monitoring Ensure site end points/clearance criteria provide required protection of human health and the environment and are consistent with best practice. Advice and assistance is available from Dstl ESD, Alverstoke and the Defence Estates Construction Support Team. Arrange disposal (for Low Level Waste (LLW) consignment to Drigg involving Thorium and Radium waste streams, Defence Estates must be informed at the earliest opportunity as they are responsible for securing the necessary Drigg allocation) Maintain adequate records to document work and provide an audit trail Seek advice from RPA and Defence Estates as required.

INCIDENTS 19 Accidental releases of radioactive material may require notification to the RPA, MOD, HSE and EA/SEPA/EHS. The procedures to be followed after an incident are detailed in Leaflet 14. ANNUAL DRIGG ALLOCATION MONITORING 20 To enable MOD to continue to secure and effectively manage the required annual Drigg allocation for LLW comprising radium and thorium waste streams copies of all British Nuclear Group (BNG) forms (D1 to D6 as appropriate) must be sent promptly to Defence Estates at the address shown previously. In addition Defence Estates must be provided with regular updates of the volume and activity of LLW being consigned to Drigg. Defence Estates is required to inform the BNG immediately of any allocation surplus so that it can be re-allocated to other BNG customers. RECORDS 21 When undertaking surveys/investigations and implementing management measures including remediation, the following records should be kept: 21.1 21.2 instruments used; background measurements etc

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21.3 21.4 21.5 22

details of the location and size of areas of radioactivity and nature of materials photographs details of environmental monitoring, remediation and validation work undertaken

Further guidance on record keeping is part of the Safegrounds Initiative (www.safegrounds.com).

RELATED LEAFLETS 23 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 2 Leaflet Title

Risk Assessments and contingency planning Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Restriction of exposure to radiation

14

Investigation, notification and reporting of unusual radiation events

16

Local orders for radiation safety

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LEAFLET 14 INVESTIGATION, NOTIFICATION AND REPORTING OF UNUSUAL RADIATION EVENTS CONTENTS Para 1 2 3 4 5 6 7 8 Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Unusual radiation events Notifiable to MOD and to external authorities Notifiable to MOD but not to external authorities Initial alerting report for unusual radiation events Investigation, notification and reporting requirements for unusual radiation events Radiation overexposure Occurrence of release of radioactive substances into the atmosphere Occurrence of spillage of radioactive substances Occurrence of loss or theft of a radioactive source or radioactive substance Malfunction of equipment used for medical or dental exposure Failure of industrial radiography or irradiation equipment Unusual radiation incidents (not notifiable to authorities external to MOD) Nature of an immediate investigation Nature of a detailed or follow-up investigation Radiation protection advice Radiation medicine advice Accident and incident reporting system Records Related leaflets Page Related Leaflets...............................................................................................................................8

10 11 12 13 14 15 16 18 19 21 24 25 26 27 28 Table 1 Annex A B C D E F G H I

Signal addressees for notification of unusual radiation events Investigation, notification and reporting of radiation overexposure Investigation, notification and reporting of the occurrence of release of radioactive substances to atmosphere Investigation, notification and reporting of the occurrence of spillage of radioactive substances Investigation, notification and reporting of the occurrence of loss or theft of radioactive substances Quantities of radionuclides for external notification of radiation occurrences Investigation, notification and reporting of malfunction of equipment used for medical exposure Investigation, notification and reporting of failure of industrial radiography or irradiation equipment to de-energise or return to its safe position after the intended exposure period Investigation, notification and reporting of unusual radiation incidents (including near misses)

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SCOPE 1 Unusual radiation events such as radiation accidents, incidents and occurrences may occur from time to time. Depending on the precise nature of the event, MOD policy requires the event to be investigated, notified and reported to a number of MOD addressees. In addition, there are statutory obligations to notify and report to external regulatory bodies and to carry out investigations into some of these events. This leaflet details the criteria and procedures for investigation, notification and reporting of these unusual events. The criteria considered are radiological criteria only and the scope of this leaflet does not extend to other non-radiological reporting requirements (e.g. for fire, explosion, injury). STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure that: 4.1 Requirements for investigation, notification and reporting of unusual radiation events are promulgated in local orders (Leaflet 16). 4.2 Investigation, notification and reporting is carried out in accordance with this leaflet, consulting the RPA as directed by the CO. Radiation Protection Supervisor (RPS) 5 The RPS should normally carry out the investigation and prepare the report as directed by the RSO. Workplace Supervisor (WPS) 6 In units where it is unnecessary to appoint an RPS, a WPS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety (see Leaflet 16). Employees 7 It is the responsibility of all employees to ensure that they immediately report any unusual or unexpected radiation event or exposure, affecting themselves or others, to the local RPS or WPS. Near misses must also be reported (i.e. an unusual event which could have given rise to an exposure but, by chance, did not). Ionising Radiations Regulations 1999 (IRR99) (apply directly). Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements).

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UNUSUAL RADIATION EVENTS 8 A radiation accident is defined in IRR 99 as an accident that requires immediate action to prevent or reduce the exposure to ionising radiation of employees or any other persons. Radiation accidents and other incidents and occurrences could lead to exposure of personnel and/or the release or loss of radioactive material. Decisions on whether such events require to be investigated, notified and reported depend on both the type of event and radiological criteria such as dose level or activity level involved in a release or loss immediate RPA advice is to be sought in cases of doubt. The different types of event which require investigation and reporting are as follows: Notifiable to MOD and to external authorities: 8.1 Overexposure i.e. any exposure of a person to ionising radiation to the extent that the dose received by that person causes a dose limit (see Leaflet 4) relevant to that person to be exceeded. 8.2 Release of radioactive material into the atmosphere as a gas, aerosol or dust where such release is not in accordance with a notification or approval from the appropriate environment agency (see Leaflet 3) or within the terms of the conditions of an exemption order. This category could include a release from a fire or explosion. 8.3 Spillage of radioactive substances, or radioactive substances otherwise released, in such a manner as to give rise to contamination (i.e. in excess of the relevant level at Annex F). 8.4 8.5 Loss or theft of a radioactive substance. Malfunction of equipment used for medical or dental exposure.

8.6 Failure of industrial radiography or irradiation equipment to de-energise or return to its safe position after the intended exposure period. Notifiable to MOD but not to external authorities: 8.7 Unusual radiation incident. This category covers the events which do not meet the reporting criteria for any of the above externally reportable categories but which still need to be reported to MOD authorities. Examples of an unusual radiation incident are unexpected radiation exposure below the level of an overexposure, a release of material below external reporting levels, ingestion of radioactive material, contaminated wound, fixed skin contamination or a near miss (i.e. an unusual event which could have given rise to an exposure, release or loss but, by chance, did not). 9 The sections which follow set out the criteria for each type of unusual radiation event and instructions as to the investigation, notification and reporting procedures to be followed. Further guidance is provided at the Annexes to this leaflet. INITIAL ALERTING REPORT FOR UNUSUAL RADIATION EVENTS 10 Any unusual radiation event coming into any of the categories described below, involving possible loss or release of radioactive material or unplanned excess radiation exposure is to be subject to an immediate alerting report to the appointed RPA for the unit or establishment, the appropriate TLB safety authority (e.g. the Chief Environment Safety Officer (CESO) for the TLB area), Occupational Health and Safety and Radiation Protection team at DS&C (OHS & RP) and the relevant units chain of command. The initial report is to be made by signal or telephone (confirmed by signal) unless otherwise specified by the authorities concerned. Signal indicator code (SIC) SQY (radiation safety) is to be used. Signal addressees are listed at Annex A. Requirements for investigation, reporting and notification are given below supported by detailed information at the Annexes to this leaflet.

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INVESTIGATION, NOTIFICATION AND REPORTING REQUIREMENTS FOR UNUSUAL RADIATION EVENTS Radiation overexposure 11 An overexposure is an exposure of a person to ionising radiation to the extent that the dose received by that person causes a dose limit relevant to that person to be exceeded (see Leaflet 4). Where the CO suspects or has been informed that any person is likely to have received an overexposure as a result of work carried out at the unit, the CO shall carry out an immediate investigation. In practice, this means that the unit or establishment RPS/WPS/RSO should be detailed to carry out the investigation taking advice from the RPA as necessary. Unless this immediate investigation shows beyond reasonable doubt that no overexposure could have occurred, the CO must carry out statutory notification and follow-up investigation procedures. Detailed information on the procedures to be followed is at Annex B. Occurrence of release of radioactive substances into the atmosphere 12 A unit or establishment RPS/WPS/RSO is to institute an immediate investigation into any release or suspected release of radioactive substances to atmosphere except those carried out in accordance with a relevant environment agency notification or approval. Where this investigation confirms the release, then the appropriate personnel at the unit or establishment, TLB safety authority and appointed RPA are to be immediately informed. Under certain circumstances, notification of authorities external to MOD is required. Copies of the investigation report are to be rendered to internal MOD authorities as directed by the TLB safety authority. Detailed information on the procedure to be followed is at Annex C. Occurrence of spillage of radioactive substances 13 In this context, the term spillage is to be taken to include other types of release such as leakage or seepage of materials leading to the spread of radioactive contamination. A unit or establishment RPS/WPS/RSO is to institute an immediate investigation into the spillage or suspected spillage of radioactive substances except those occurring in accordance with a relevant environment agency approval. Where this investigation confirms the spillage then the appropriate personnel at the unit or establishment, TLB safety authority and appointed RPA are to be informed immediately. Under certain circumstances, notification of authorities external to MOD is required. Copies of the investigation report are to be rendered to internal MOD authorities as directed by the TLB safety authority. Detailed information on the procedure to be followed is at Annex D. Occurrence of loss or theft of a radioactive source or radioactive substance 14 A unit or establishment RPS/WPS/RSO is to institute an immediate investigation into the loss of the radioactive source or radioactive material. Where this investigation confirms the loss then the appropriate personnel at the unit or establishment, TLB safety authority and appointed RPA are to be immediately informed. Under certain circumstances, notification of authorities external to MOD is required. Copies of the investigation report are to be rendered to internal MOD authorities as directed by the TLB safety authority. Detailed information on the procedure to be followed is at Annex E. Malfunction of equipment used for medical or dental exposure 15 Where the CO suspects or has been informed that an incident may have occurred in which a person while undergoing a medical exposure was, as the result of a malfunction of, or defect in, radiation equipment under the control of that CO, exposed to ionising radiation to an extent much greater than intended, the CO shall carry out an immediate investigation. In practice, this means that the CO of the unit or establishment must detail the RPS/RSO to carry out the investigation taking advice from the RPA as necessary. Unless this immediate investigation shows that no incident has taken place, the CO must carry out statutory notification and follow-up investigation procedures. Detailed information on the procedures to be followed is at Annex G.

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Failure of industrial radiography or irradiation equipment 16 The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR 95) requires certain incidents involving industrial (site) radiography or irradiation equipment to be reported to the Health and Safety Executive. The incidents involved are: The malfunction of a radiation generator or its ancillary equipment used in fixed or mobile industrial radiography that results in the equipment failing to de-energise at the end of the exposure. The malfunction of equipment used in fixed or mobile industrial radiography that results in a radioactive source failing to return to its safe position at the end of the exposure.

17 An investigation is to be conducted by the RPS/RSO taking advice from the RPA as required and a report rendered. Detailed information on the procedures to be followed is at Annex H. Unusual radiation incidents (not notifiable to authorities external to MOD) 18 The following unusual radiation incidents are to be investigated by the RPS/WPS/RSO with advice from the RPA as necessary and notified and reported to the appropriate MOD authorities. Detailed information on the procedures to be followed is at Annex I. 18.1 Accident or occurrence likely to result in a person receiving an effective dose (i.e. whole body dose) exceeding 6 mSv or an equivalent dose (i.e. dose to eye, skin, hands, forearms, feet or ankles) exceeding three-tenths of the relevant dose limit. This unusual radiation incident also carries statutory dosimetry assessment and record keeping requirements (see Leaflet 6). Note that if the dose received constitutes a radiation overexposure, it is to be investigated, notified and reported in accordance with paragraph 11. 18.2 Effective dose (i.e whole body dose), accumulated from routine external and internal radiation exposure, exceeding the formal investigation level (see Leaflet 4). Note that if the dose received constitutes a radiation overexposure, it is to be investigated, notified and reported in accordance with paragraph 11. 18.3 Any intake of radioactive material by ingestion.

18.4 Any fixed skin contamination greater than 3 Bq cm-2 for -emitters and 30 Bq cm-2 for and -emitters remaining after 24 hours. 18.5 Any contaminated wound.

18.6 Any release of radioactive material to atmosphere or spillage of radioactive material which is below the levels prescribed for notification of external authorities (e.g. HSE, environment agencies). Note that releases or spillage at levels above those prescribed are to be investigated and reported in accordance with paragraphs 12 and 13 respectively and their supporting annexes. 18.7 Any near miss i.e. an unusual event with the potential to cause unplanned radiation exposure, or a release or spill of radioactive material to the environment or the loss of radioactive substances but where these events did not, by chance, actually occur. Note that specific types of malfunction of equipment associated with industrial radiography require to be investigated and reported in accordance with paragraphs 16 and 17. 18.8 An incident likely to generate press or media interest.

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NATURE OF AN IMMEDIATE INVESTIGATION 19 An immediate investigation into any unusual radiation event is to be conducted by the RSO/RPS/WPS of the unit or establishment on behalf of the CO, unless alternative arrangements are made. The main purpose of the immediate investigation is to rule out suspected accidents, incidents or occurrences which it can be readily shown did not take place. Also, the immediate investigation is to collect temporal details and information which may be lost due to the passage of time. In cases where a exposure cannot be excluded, reviews intended to refine the initial estimate or assessment of dose received are not part of the immediate investigation. Such are to be carried out, if appropriate during the detailed investigation which follows. 20 Once the immediate investigation has been completed, the need, or otherwise, for a report to MOD authorities and, in some cases, external authorities will be evident. The RPA is to be consulted regarding the aspects which are to be covered in a detailed or follow-up investigation (see below). NATURE OF A DETAILED OR FOLLOW-UP INVESTIGATION 21 Detailed investigations into unusual radiation events are to be conducted by the RSO/RPS/WPS of the unit or establishment on behalf of the CO, unless alternative arrangements are made such as the setting up of a Board of Inquiry. The RPA is to be consulted. 22 The unusual radiation event is to be thoroughly investigated to determine the extent of the radiation hazard, level of radiation exposures and the causes of the event including the less obvious contributory causes, and to recommend safeguards to prevent its reoccurrence. 23 Reports of investigations into unusual radiation events are to contain all the relevant facts, including the following details where applicable: 23.1 23.2 23.3 Time and location. Names of persons involved, work routine and duties being performed at the time. Description of any equipment involved.

23.4 Summary of relevant local orders, work instructions, safety documents, equipment manuals and maintenance programmes covering the work undertaken at the time or the equipment involved. 23.5 Full description detailing the sequence of events including adherence to local orders, work instructions, safety documents, equipment manuals and maintenance programmes. 23.6 Results of any radiation or contamination survey for the areas concerned during the period under investigation. 23.7 Results of any special surveys or measurements taken (e.g. during a reconstruction advised by the RPA). 23.8 In the case of an exposure (or overexposure) recorded on a dosemeter, consideration as to whether the dosemeter could have been left in a radiation area (i.e. exposed whilst not being worn) or worn whilst the employee underwent a medical exposure. 23.9 Where relevant, estimated quantities of radionuclides involved, estimates of quantities released and spread of contamination both airborne and surface. 23.10 Estimated (or measured) external dose, level of bodily surface contamination or intake of radionuclide(s), together with details of results of measurements and laboratory analyses to include employees and any other persons involved. 23.11 Immediate action taken to lessen the consequences.

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23.12

Medical action taken, including suspension from radiation work.

23.13 Training, instruction or information received and general competence for the work undertaken. 23.14 23.15 23.16 Direct and/or indirect cause. Views of relevant safety representatives or safety committee. Recommendations for future preventive measures.

RADIATION PROTECTION ADVICE 24 Radiation protection advice for units and establishments is to be obtained from the appointed RPA. For those units and establishments for which Dstl ESD is appointed as the radiation protection adviser, radiation protection advice is available 24 hours by telephoning: During working hours 02392 768130 During silent hours 02392 768020 and asking for the duty health physicist.

RADIATION MEDICINE ADVICE 25 Radiation medicine advice is to be obtained from the Radiation Medicine Section at the Institute of Naval Medicine, Alverstoke, Gosport, Hants, PO12 2DL, the tri-service focal point for such advice, or by telephoning: During working hours 023 9276 8085 or 8026 During silent hours 023 9276 8020 and asking for the Duty Radiation Medicine Specialist. Also, fax on 023 9250 4823 e-mail smorm@inm.mod.uk e-mail aoumd@inm.mod.uk ACCIDENT AND INCIDENT REPORTING SYSTEM 26 In addition to the investigation, notification and reporting procedures described above, all unusual radiation events are to be reported using points of contact. They can be found at: http://defenceintranet.diiweb.r.mil.uk/DefenceIntranet/PeopleServices/HealthWellBeingAndSickness/Rep ortingWorkRelatedAccidents/ For those not having access to the intranet they should contact the Chief Environment and Safety Officer within their TLB. When JSP 375 is revised and published (post 2007) this should contain the latest information and should be used. RECORDS 27 Records of investigations into unusual radiation events are to be retained by the establishment for at least 50 years and in the case of radiation exposures retained until the person involved would have reached the age of 75 years if this is later. Where an investigation showed that no unusual radiation event had actually occurred, the retention period is a minimum of 2 years, after which period, an assessment on the relevance of retaining the document is to be made in accordance with MOD policy at Volume 1 Chapter 11.

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RELATED LEAFLETS 28 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 3 Leaflet Title

Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Restriction of exposure to radiation Dosimetry and personal dose records Local orders for radiation safety

4 6 16

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LEAFLET 14 ANNEX A

SIGNAL ADDRESSEES FOR NOTIFICATION OF UNUSUAL RADIATION EVENTS

Addressee CINCFLEET for CESO(RN) FLEET HQ for RADPOL(SM) HQ LAND for CESO(A) HQPTC RAF High Wycombe for CESO(RAF) DRPS ALVERSTOKE for Dstl MODUK DE&S for DNSR MODUK for DSC ADNAR MODUK DE&S for CESO(DE&S) MODUK DE&S for CDM MODUK for DSC HPAD INM ALVERSTOKE RN units only RN units only Army units only RAF units only

Comments

For units using Dstl ESD as RPA For events involving nuclear material or events on nuclear sites For events involving nuclear material or events on nuclear sites All All All (information only) All - for cases involving suspected or confirmed overexposure or contamination of personnel and where radiation medicine advice may be required.

Signal Indicator Code (SIC) SQY (Radiation Safety) is to be used.

Suggested Signal Formats:

SIGNAL ONE. SIC: H9D/SQY SUBJECT : RADIOLOGICAL INCIDENT REF : 1. 2. 3. 4. 5. 6. JSP 392, Leaflet 14 Name of ship / Establishment. Date and time of incident. Nature of incident and brief description of circumstances. Location of incident. No of personnel exposed to external ionising radiation No of personnel exposed to internal ionising radiation

SIGNAL TWO. SIC: H9H/SQY

SUBJECT : LOSS OF RADIOACTIVE SOURCE REF : 1. 2. 3. 4. 5. 6. JSP 392, Leaflet 14 Name of Ship / Establishment. Date and time loss discovered / occurred. Type of source and/or radioactive material. Radioactive nuclide(s) and nominal activity. Serial number. Brief outline of circumstances of loss

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LEAFLET 14 ANNEX B INVESTIGATION, NOTIFICATION AND REPORTING OF RADIATION OVEREXPOSURE

1 Following any suspected or actual overexposure carry out an immediate investigation as detailed in this leaflet. 2 Unless the immediate investigation shows beyond reasonable doubt that no overexposure has occurred, immediately notify the following: 2.1 2.2 2.3 Appropriate personnel at the unit or establishment. The Appointed Doctor and INM Alverstoke (by priority signal (see Annex A)). The TLB safety authority and units line authority by priority signal.

2.4 Dstl ESD Alverstoke (for Approved Dosimetry Service (ADS) and RPA Body) or external ADS and RPA (if Dstl ESD not used for either or both). 2.5 3 DS&C (OHS and RP) (for information only).

Notify as soon as practicable: 3.1 3.2 3.3 NOTE Notification of external body (3.3) is only to be undertaken when MOD authorities (2.1-2.5) have been notified. Notification of the external body will not apply where an overexposure has occurred to a member of a visiting force. External notification will apply for the UK armed forces, MOD civilians and other persons. In the case of an employee of another employer, notify that other employer. Notify the person affected. Local office of the Health and Safety Executive.

4 Carry out a follow-up investigation of the circumstances of the overexposure and the assessment of the relevant dose to determine, so far as is reasonably practicable, the measures required, if any, to be taken to prevent a recurrence of such overexposure. Notify the results and forward the report of the further investigation to the authorities and individuals listed above. 5 Where the investigation shows that the exposure is below the overexposure level, then the internal MOD procedure for reporting unusual radiation incidents at Annex I is to be followed as the exposure will still be reportable internally within MOD. 6 All overexposures are to also be reported. Accident and incident reporting is to be undertaken using points of contact. They can be found at http://defenceintranet.diiweb.r.mil.uk/DefenceIntranet/PeopleServices/HealthWellBeingAndSickness/Rep ortingWorkRelatedAccidents/ For those not having access to the intranet they should contact the Chief Environment and Safety Officer within their TLB. When JSP 375 is revised and published (post 2007) this should contain the latest information and should be used. Unusual radiation exposures below the overexposure level may still need to be reported this way (see Leaflet 14 paragraph 18).

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7 Records of the immediate investigation are to be retained by the establishment for at least 2 years. The follow-up investigation report is to be retained at least until the person affected would have attained the age of 75 years but in any event for at least 50 years. 8 Where the person who received the overexposure is an employee who has a dose record, the CO must arrange for the assessment of dose to be entered into that dose record (see Leaflet 6).

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LEAFLET 14 ANNEX C INVESTIGATION, NOTIFICATION AND REPORTING OF THE OCCURRENCES OF RELEASE OF RADIOACTIVE SUBSTANCES TO ATMOSPHERE

1 Following any release or suspected release of radioactive substances to atmosphere, other than in accordance with a relevant environment agency discharge approval, carry out an immediate investigation as detailed at Leaflet 14. 2 If the release exceeds the quantity specified in Annex F, immediately notify the following: 2.1 Appropriate personnel at the unit or establishment.

2.2 The TLB safety authority and units line authority by priority signal. (Signal addressees are given at Annex A). 2.3 2.4 2.5 Dstl ESD and RPA (if RPA not the Dstl ESD RPA Body). DS&C (OHS and RP) (for information only). Local office of the Health and Safety Executive.

2.6 Environment agencies, as appropriate, where there is a risk of environmental contamination (see also paragraph 5 below). NOTE Notification of external bodies (2.5-2.6) is only to be undertaken when MOD authorities (2.1-2.4) have been notified. Notification of external bodies will not apply to HM Ships, except when undergoing refit. 3 The authorities notified above are to be provided initially with the following information: Type of radioactive source or material. Radionuclides and nominal activity. Brief outline of circumstances of release.

4 Further details of the release, equipment and areas affected and personnel contaminated externally or internally may be required by MOD authorities to enable advice/reassurance to be provided. 5 Where the quantity is found not to exceed the relevant level in Annex F, the advice of the RPA is to be sought as to whether a report to the appropriate environment agency is still required in accordance with the terms and conditions which relate to the radioactive material which has been released. If a report to the appropriate environment agency is not required, then the internal MOD procedure for reporting unusual radiation incidents at Annex I is to be followed. 6 All releases are also to be reported via the Accident and Incident Reporting System as described in JSP 375. 7 Records of investigation reports are to be retained by the establishment for at least 50 years.

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LEAFLET 14 ANNEX D INVESTIGATION, NOTIFICATION AND REPORTING OF THE OCCURRENCE OF SPILLAGE OF RADIOACTIVE SUBSTANCES

1 Following any spillage or suspected spillage of radioactive substances, other than in a fume cupboard or total enclosure or in a manner specified in a relevant environment agency approval to dispose of radioactive waste, carry out an immediate investigation as detailed at Leaflet 14. 2 If the spillage exceeds the quantity specified in Annex F, immediately notify the following: 2.1 Appropriate personnel at the unit or establishment.

2.2 The TLB safety authority and units line authority by priority signal. (Signal addressees are given at Annex A). 2.3 2.4 2.5 Dstl ESD and RPA (if RPA not the Dstl ESD RPA Body). DS&C (OHS and RP) (for information only). Local office of the Health and Safety Executive.

2.6 Environment agencies, as appropriate, where there is a risk of environmental contamination (see also paragraph 5 below). NOTE Notification of external bodies (2.5-2.6) is only to be undertaken when MOD authorities (2.1-2.4) have been notified. Notification of external bodies will not apply to HM Ships, except when undergoing refit. 3 The authorities notified above are to be provided initially with the following information: Type of radioactive source or material. Radionuclides and nominal activity. Brief outline of circumstances of spillage. 4 Further details of the spillage, equipment and areas affected and personnel contaminated externally or internally may be required by MOD authorities to enable advice/reassurance to be provided. 5 Where the quantity is found not to exceed the relevant level in Annex F, the advice of the RPA is to be sought as to whether a report to the appropriate environment agency is still required in accordance with the terms and conditions which relate to the radioactive material which has been spilled. If a report to the appropriate environment agency is not required, then the internal MOD procedure for reporting unusual radiation incidents at Annex I is to be followed. 6 All spillages are also to be reported via the Accident and Incident Reporting System as described by JSP 375. 7 Records of investigation reports are to be retained by the establishment for at least 50 years.

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LEAFLET 14 ANNEX E INVESTIGATION, NOTIFICATION AND REPORTING OF THE OCCURRENCE OF LOSS OR THEFT OR RADIOACTIVE SUBSTANCES

1 Following any loss or theft of a radioactive substance, carry out an immediate investigation as detailed at Leaflet 14. 2 If the loss exceeds the quantity specified in Annex F, immediately notify the following: 2.1 Appropriate personnel at the unit or establishment.

2.2 The TLB safety authority and units line authority by priority signal. (Signal addressees are given at Annex A). 2.3 2.4 2.5 2.6 2.7 NOTE Notification of bodies (2.5-2.7) is only to be undertaken when MOD authorities (2.1-2.4) have been notified. 3 The authorities notified above are to be provided initially with the following information: Type of radioactive source or material. Radionuclides and nominal activity. Serial number. Brief outline of circumstances of loss. Dstl ESD and RPA (if RPA not the Dstl ESD RPA Body). DS&C (OHS and RP)) (for information only). Local of the Health and Safety Executive (within 24 hours from discovery of loss). Environment agencies (see also paragraph 4 below). MOD Police (where applicable) and local Police.

4 Where the quantity is found not to exceed the relevant level in Annex F, the advice of the RPA is to be sought as to whether a report to the appropriate environment agency is still required in accordance with the terms and conditions which relate to the radioactive material which has been lost or stolen. If a report to the appropriate environment agency is not required, then the internal MOD procedure for reporting unusual radiation incidents at Annex I is to be followed. 5 All losses or thefts are also to be reported via the Accident and Incident Reporting System as described by JSP 375. 6 Records of investigation reports are to be retained by the establishment for at least 50 years.

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LEAFLET 14 ANNEX F QUANTITIES OF RADIONUCLIDES FOR EXTERNAL NOTIFICATION OF RADIATION OCCURRENCES

Radionuclide Hydrogen-3 (Tritium) elemental Hydrogen-3 (Tritium) tritiated compounds Chlorine-36 Cobalt-57 Cobalt-60 Nickel-63 Krypton-85 Strontium-90 Yttrium-90 Technetium-99m Iodine-123 Iodine-131 Iodine-133 Caesium-137 Promethium-147 Iridium-192 Polonium-210 Radium-226 Thorium-232 Thorium (natural) Uranium-238 Uranium (natural) Americium-241 NOTE

Lost or stolen (Bq) 1 x 1010 1 x 1010 1 x 107 1 x 107 1 x 106 1 x 109 1 x 105 1 x 105 1 x 106 1 x 108 1 x 108 1 x 107 1 x 107 1 x 105 1 x 108 1 x 105 1 x 105 1 x 105 1 x 105 1 x 104 1 x 105 1 x 104 1 x 105

Spillage or unauthorised release to atmosphere (Bq) 1 x 1013 1 x 1012 1 x 1010 1 x 1011 1 x 1010 1 x 1011 1 x 1012 1 x 109 1 x 1011 1 x 1013 1 x 1012 1 x 1010 1 x 1011 1 x 1010 1 x 1010 1 x 1010 1 x 107 1 x 107 1 x 106 1 x 106 1 x 107 1 x 106 1 x 106

For radionuclides not given in the table, notifiable quantities are given in Schedule 8 of the Ionising Radiation Regulations 1999, or advice is to be sought from the RPA .

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LEAFLET 14 ANNEX G INVESTIGATION, NOTIFICATION AND REPORTING OF MALFUNCTION OF EQUIPMENT USED FOR MEDICAL EXPOSURE

1 Following any suspected or actual malfunction or defect resulting in a dose to the person undergoing the medical or dental exposure much greater than expected carry out an immediate investigation as detailed at Leaflet 14. 2 Unless the immediate investigation shows beyond reasonable doubt that no incident has occurred, immediately notify the following: 2.1 2.2 2.3 2.4 2.5 2.6 NOTE Notification of external body (2.6) is only to be undertaken when MOD authorities (2.1-2.5) have been notified. 3 Carry out a detailed follow-up investigation of the circumstances of the exposure and an assessment of the relevant dose. Determine, so far as is reasonably practicable, the measures required, if any, to be taken to prevent a recurrence. Notify the results of the further investigation to the authorities listed above. 4 All incidents in this category are also to be reported via the Accident and Incident Reporting System as described by JSP 375. 5 Records of the immediate investigation are to be retained by the establishment for at least 2 years. The follow-up investigation report is to be retained for at least 50 years. Appropriate personnel at the unit or establishment. INM Alverstoke f.a.o. Radiation Medicine Specialist (by priority signal (see Annex A)). The TLB safety authority and units line authority by priority signal. Dstl ESD Alverstoke and RPA (if RPA not the Dstl ESD RPA Body). DS&C (OHS and RP) (for information only). Local office of the Health and Safety Executive.

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LEAFLET 14 ANNEX H INVESTIGATION, NOTIFICATION AND REPORTING OF FAILURE OF INDUSTRIAL RADIOGRAPHY OR IRRADIATION EQUIPMENT TO DE-ENERGISE OR RETURN TO ITS SAFE POSITION AFTER THE INTENDED EXPOSURE PERIOD

Following a malfunction as described in Leaflet 14, immediately notify the following: 1.1 1.2 1.3 1.4 1.5 NOTE Notification of external body (1.5) is only to be undertaken when MOD authorities (1.1-1.4) have been notified provided that this does not cause the reporting period specified by RIDDOR to be exceeded. Appropriate personnel at the unit or establishment. The TLB safety authority and units line authority by priority signal. Dstl ESD and RPA (if RPA not the Dstl ESD RPA Body). DS&C (OHS and RP) (for information only). Local office of the Health and Safety Executive.

2 Carry out an investigation of the circumstances of the malfunction or defect. Determine, so far as is reasonably practicable, the measures required, if any, to be taken to prevent a reoccurrence of this failure. Report the results of the investigation to the MOD authorities listed above. Note that if this failure involves a radiation exposure the Approved Dosimetry Service (ADS) must also be provided with a copy of the report (usually the Dstl ESD ADS). 3 All incidents in this category are also to be reported via the Accident and Incident Reporting System as described by JSP 375. 4 Records of the investigation are to be retained by the establishment for at least 50 years and in the case of a radiation exposure until the person to whom the report relates would have reached the age of 75 years (if later).

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LEAFLET 14 ANNEX I INVESTIGATION, NOTIFICATION AND REPORTING OF UNUSUAL RADIATION INCIDENTS (INCLUDING NEAR MISSES)

1 Following any unusual radiation incident, it is to be established whether the incident constitutes an overexposure, release or spillage in excess of Annex F levels, loss or theft, malfunction of equipment used for medical or dental exposure or failure of industrial radiography or irradiation equipment if the incident fits any of the aforementioned categories then the procedures appropriate to that category are to be followed. 2 Carry out preliminary investigation and notify: 2.1 2.2 2.3 2.4 Appropriate personnel at the unit or establishment. The TLB safety authority and units line authority. Dstl ESD and RPA (if RPA not the Dstl ESD RPA Body). DS&C (OHS and RP) (for information only).

3 Unless otherwise directed, carry out a follow-up investigation in accordance with the procedure at Leaflet 14, taking RPA advice as necessary. 4 Render the follow-up investigation report to the line authority and TLB safety authority, copy to Dstl ESD. 5 Unless otherwise directed, all incidents in this category are also to be reported via the Accident and Incident Reporting System as described in JSP 375. 6 Records of the investigation are to be retained by the establishment for at least 50 years.

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LEAFLET 15 TRAINING REQUIREMENTS AND COURSES CONTENTS Para

1 2 3 4 5 6 7 8 9 15 21 27 28 32 35 36 Table 1 Annex A

Scope Statutory requirements and parallel arrangements Duties Commanding Officers (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Line managers Employees Type of Training Radiation Safety Officers (RSOs) Radiation Protection Supervisors (RPSs) Workplace Supervisors (WPSs) Employees working with radiation Others Courses available Records Related leaflets Page Related Leaflets...............................................................................................................................5

Core of Competence for Radiation Safety Training

SCOPE 1 This leaflet covers the training requirements for the statutory and MOD policy radiation safety appointments. Training required under the Ionising Radiations (Medical Exposure) Regulations 2000 is covered in Leaflets 25 and 26. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements).

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DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to co-ordinate the radiation safety training (including basic, on the job and continuation training) for personnel at the unit or establishment. Radiation Protection Supervisor (RPS) 5 An RPS must be appointed where it is necessary to designate a controlled or supervised area. Where an RPS is appointed, their duties are to include ensuring that all workers under their control have been suitably instructed in the hazards and radiation protection procedures and are aware of the relevant safety orders and instructions. Workplace Supervisor (WPS) 6 In units where it is unnecessary to appoint an RPS, a WPS may need to be appointed with duties to ensure that work is carried out in accordance with local orders for radiation safety (see Leaflet 16). In addition, the WPS is to ensure that all persons carrying out work with the radiation in their area have been suitably instructed in the hazards and radiation protection procedures and are aware of the relevant safety orders and instructions. Line managers 7 Line managers have a duty to follow the management arrangements that the CO has put in place to ensure that when an individual takes over RSO/RPS/WPS duties from another individual then they are to receive appropriate training or information to ensure that they can carry out their new role. Employees 8 It is the responsibility of employees to ensure that they understand the radiation hazards and are aware of the relevant safety orders and instructions in their working area. TYPE OF TRAINING Radiation Safety Officers (RSOs) 9 The Radiation Safety Officer is appointed by the CO as part of the local safety organisation and will normally discharge the radiation protection duties of the Commanding Officer. 10 Radiation Safety Officers are to ensure that they are familiar with the specific radiation hazards of their unit or establishment and that adequate radiation protection arrangements are made to minimise the radiation hazard. 11 Training for the RSO is to be conducted by a combination of a short generic training package and local specific training. Advice on both the generic package and local component of training necessary is to be sought from the RPA.

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12 The modules detailed in Annex A comprise a basic level of knowledge for radiation safety training. The degree of detail that each module is to provide will depend on the range of tasks to be supervised and the individuals previous level of relevant knowledge. 13 Where such an appointment has been terminated, a previously trained and appointed RSO may be reinstated without further training provided that: 13.1 The process over which supervision is exercised is unchanged since the last appointment. 13.2 A period of not greater than 2 years has elapsed since termination of the appointment. 14 RSOs are also to receive refresher training at intervals not exceeding 5 years after the completion of an RSO course. Radiation Protection Supervisors (RPSs) 15 Radiation Protection Supervisors (RPSs) are appointed to carry out the duties as detailed in Leaflet 39 in respect of controlled or supervised areas. 16 Training for the RPS is to be conducted by a combination of a short generic training package and local specific training. Advice on both the generic package and local component of training necessary is to be sought from the RPA. 17 The modules detailed in Annex A comprise a basic level of knowledge for radiation safety training. The degree of detail that each module is to provide will depend on the range of tasks to be supervised and the individuals previous level of relevant knowledge. 18 Completion of an appropriate training course does not automatically qualify an individual to be appointed as an RPS. The CO or delegated authority is to satisfy themselves that the people they appoint to act as RPSs: 18.1 Have received appropriate information and instruction. 18.2 Know and understand the local orders and contingency plans relevant to the work with ionising radiation. 18.3 Possess sufficient authority to allow them to supervise all the radiation protection aspects of the work in areas subject to local orders. 18.4 Know what to do in an emergency; and 18.5 Know where to seek more information or advice. 19 Where an RPS appointment has been terminated, a previously trained and appointed RPS may be reinstated without further training provided that: 19.1 The process over which supervision is exercised is unchanged since the last appointment. 19.2 A period of not greater than 2 years has elapsed since termination of the appointment. 20 RPSs are also to receive refresher training at intervals not exceeding 5 years after the completion of an RPS course.

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Workplace Supervisors (WPSs) 21 For certain types of work involving minor quantities of radioactive material, the generation of X-rays or work in radon affected areas, it is unnecessary to designate a controlled or supervised area and hence an RPS need not be appointed. However, it is still necessary to have workplace supervision to ensure that work is carried out in accordance with local orders for radiation safety. Under these circumstances, it is MOD policy that an individual is trained and appointed as a Workplace Supervisor to carry out the duties as detailed in Leaflet 39. 22 Training for the WPS is less onerous than that for an RPS and is to be conducted by attendance on a short generic training package or local specific training. Advice on the appropriateness and necessary components of local training is to be sought from the RPA. 23 The training requirements for each WPS is to be specified in local orders.

24 The modules detailed in Annex A comprise a basic level of knowledge for radiation safety training. The degree of detail that each module is to provide will depend on the range of tasks to be supervised and the individuals previous level of relevant knowledge. 25 Where a WPS appointment has been terminated, a previously trained and appointed WPS may be reinstated without further training provided that: 25.1 The process over which supervision is exercised is unchanged since the last appointment. 25.2 A period of not greater than 2 years has elapsed since termination of the appointment. 26 WPSs are also to receive appropriate refresher training at appropriate intervals but not exceeding every 5 years after the completion of a WPS course or local training. Employees working with radiation 27 All employees on a site where controlled or supervised areas are designated are to be given information or instruction to avoid being unnecessarily exposed i.e. recognition and understanding of warning signs. Others 28 There are specific training requirements for duty holders under the Ionising Radiation (Medical Exposure) Regulations 2000 (see Leaflet 25 and Leaflet 26) 29 Some managers on a site where work with ionising radiation is carried out may not be directly involved in the work, however, they are to receive training to help them develop and sustain a commitment to restricting radiation exposure. 30 Female employees are to be informed of the possible risk from exposure to ionising radiation to the foetus and to a nursing infant and of the importance of informing the CO in writing as soon as possible after becoming aware of their pregnancy or if they are breast feeding. 31 Visitors (those not involved with work in the area) who are to enter designated areas are to be briefed on radiation protection requirements before entry to those areas (see Leaflet 5). COURSES AVAILABLE 32 Courses are held at HMS Sultan, these are detailed in the appropriate DIN GEN.

33 The RPA is to be consulted prior to booking attendance on any radiation course to ensure that it is the most appropriate course available.

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34 If no course seems appropriate, specific courses may be run for certain users at their own premises. Consult the RPA for further details. RECORDS 35 Records of appointments and attendance at training courses or local training are to be retained for a minimum of 2 years from termination of appointment to enable the CO to identify who needs further/refresher training. Personnel files are to be annotated with the dates of commencement and termination of the appointment and training. RELATED LEAFLETS 36 Leaflets referred to within this Leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 3 5 25 26 39 Leaflet Title Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Written arrangements for unclassified persons entering controlled areas Dental X-ray machines Medical diagnostic X-ray machines Radiation safety duties of MOD employees

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LEAFLET 15 ANNEX A CORE COMPETENCIES FOR RADIATION SAFETY TRAINING

1 The nature of ionising radiation and its interaction with tissue confined to those types of ionising radiation which may be encountered, but including: 1.1 1.2 and 1.3 2 The nature of any harmful effects. The principle of restricting exposure to ionising radiation so far as reasonably practicable;

The concepts of internal and external radiation exposure.

The quantities used for (as appropriate to the circumstances): 2.1 2.2 2.3 Measuring ionising radiation, including the units of measurement. Activity of radioactive substances; and Contamination.

NOTE A detailed understanding of all dose quantities may not be needed, provided there is an understanding of what is meant by the general term dose of ionising radiation.
3 Relevant measurement techniques (i.e. those that will be met in the course of normal work), for example:

3.1 3.2 3.3 3.4 3.5 3.6 3.7 4

Film badge. Thermo-luminescent dosemeter (TLD). Electronic dosemeter. Other personal dosemeter. Bioassay. Air sampling; and Workplace portable monitors for radiation and contamination.

Basic legal requirements: 4.1 4.2 4.3 4.4 4.5 The lonising Radiations Regulations 1999 (IRR99) and Approved Code of Practice (L121). Local orders, their purpose and how to use them to secure compliance with IRR99. Risk assessments. Provisions specific to women and young people. Designation of people and areas; and

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4.6 Appreciation of relevant general health and safety legislation, such as the Management of Health and Safety at Work Regulations 1999. 5 The basic principles of practical radiation protection: 5.1 5.2 5.3 5.4 5.5 5.6 6 Time. Distance. Shielding. Containment; and Good housekeeping, and How those principles are carried through in the particular work situation.

In-house knowledge, as appropriate: 6.1 6.2 6.3 6.4 6.5 6.6 6.7 The COs safety policy and organisation. The specific functions the RPS would be expected to undertake. Relevant dose limits. Operational levels set by the CO for the particular workplace. Content of the local orders established by the CO. Contingency plans; and Where help and advice can be obtained.

7 Practical procedures to be followed in the event of an accident, incident, emergency or other unwanted occurrence, including procedures for reporting adverse incidents.

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LEAFLET 16 LOCAL ORDERS FOR RADIATION SAFETY CONTENTS Para

1 2 3 4 5 6 7 8 11 12 14 15 16 17 Table 1 Annex A

Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation safety officer (RSO) Radiation protection supervisor (RPS) Workplace supervisor (WPS) Employees Content of local orders for radiation safety Additional requirements of local rules (applies to designated areas) Contingency plans Review of local orders Standard local orders Records Related leaflets Page Related Leaflets...............................................................................................................................1

Provision of local rules

SCOPE 1 All COs must provide employees with comprehensive information and instruction on the risks to their health and safety and the appropriate precautions and preventative and protective measures to be taken to ensure that exposure to ionising radiation is minimised so far as is reasonably practicable. The risks and measures will, in the first instance, be identified in the risk assessment (see Leaflet 2). There is an additional statutory requirement for the CO in respect of designated areas (i.e. controlled and supervised areas as described in Leaflet 4) they must make and set down in writing local rules appropriate to the radiation risk and the nature of the operations undertaken in that area. Local orders for radiation safety must therefore meet the general requirement to provide information and instruction and also, in the case of designated areas, meet the statutory requirements for local rules. This leaflet details the necessary content of local orders (which can include local instructions, local memoranda, notices, signs etc) which will satisfy all of these requirements. Local orders for radiation safety can be standalone or can be part of general safety orders. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly).

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DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements can be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure that: Local orders are kept up to date taking into account the findings of the risk assessment, changes to the assessment, recommendations from audits, regulatory inspections and RPA visits as they arise. Local orders are brought to the attention of all staff as appropriate and all sections have access to the parts of local orders relevant to them. Staff are provided with appropriate local training so that they understand and can comply with the local orders. Local orders are subjected to quality audits, sections are subject to compliance audits and systems are in place to follow-up on audit recommendations.

Radiation Protection Supervisor (RPS) 5 Where sites and establishments have controlled areas and, where appropriate having regard to the nature of the work carried out there, supervised areas, the CO must set down in writing local rules. Whenever local rules are required, an RPS must be appointed for each designated area concerned. In this case, local orders must also incorporate the essential requirements of local rules as required by IRR99 (see Annex A). The prime duty of the RPS is to ensure compliance with the IRR99 in respect of work carried out in the designated area in practice, the RPS will achieve this by ensuring that work is carried out in accordance with the local orders for radiation safety. Workplace Supervisor (WPS) 6 In cases where work with ionising radiation is carried out but where the risk assessment shows that designated areas are not required, a WPS is to be appointed with duties to ensure that the work with ionising radiation is carried out in accordance with the local orders for radiation safety. Employees 7 It is the responsibility of all employees to ensure that they are familiar with the content of local orders and comply with them. Employees must also bring to the attention of the appropriate supervisor or manager any shortcomings they identify in local orders. CONTENT OF LOCAL ORDERS FOR RADIATION SAFETY 8 Local orders for radiation safety can be stand-alone documents or can be combined with general safety orders. Where sites have designated areas, the local orders must also satisfy the statutory requirement for local rules (detailed guidance is at Annex A). The local orders for radiation safety for several different areas are to be combined in one document or issued as separate documents to each area. The orders are to include or be supplemented by separate instructions, memoranda, notices and signs. However issued, the orders are to contain:

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8.1 Radiation safety management organisation, including appointments and responsibilities of managers, supervisors and employees (See Volume 1 Chapter 8). 8.2 8.3 Names and contact details of local supervisors. Location and description of work with ionising radiations covered by the orders.

8.4 Summary or reference to work instructions and procedures to be followed for work with ionising radiations. 8.5 Summary or reference to general precautions and principles of protection to be followed to restrict exposure to ionising radiation so far as is reasonably practicable (See Leaflet 4). 8.6 Physical surveillance arrangements including arrangements and programmes for radiation and/or contamination monitoring (See Leaflet 8). 8.7 Personnel surveillance arrangements including any medical or radiation dosimetry requirements (See Leaflet 6). 8.8 The CO must set a dose investigation level. Where the effective dose to an employee exceeds this level, an investigation is to be carried out. The purpose of this investigation is to trigger a review of working conditions to make sure that exposure is being restricted as far as is reasonably practicable. Although the maximum level set by IRR99 is 15 mSv, MOD requires that the level be no higher than 6 mSv. The report of this investigation is to be retained for at least 5 years. 8.9 Reference to maintenance and testing arrangements for equipment associated with radiation safety, including radiological monitoring equipment, personal protective equipment (PPE) (including respiratory protective equipment (RPE)), safety and hygiene features, warning devices, storage areas, work surfaces and work areas. 8.10 Where the risk assessment (See Leaflet 2) has identified reasonably foreseeable radiation accidents, contingency plans and emergency procedures designed to restrict exposure to ionising radiation must be drawn up these can be contained within the orders or, if separate documents, referred to. Requirements for training and exercising the contingency plans must be specified. 8.11 Procedures (or references) for procurement, receipt or despatch of radioactive materials, equipment containing radioactive materials or equipment capable of generating radiation including internal/external notification or approval requirements (see Leaflets 1 and 3). 8.12 Procedures (or references) for storage and accounting for radioactive sources and materials (See Leaflet 9). 8.13 Procedures (or references) for investigating and reporting of accidents, incidents or occurrences involving radiation or radioactive material (See Leaflet 14). 8.14 Training requirements and arrangements for employees and supervisors to include both external and local training (See Volume 1 Chapter 9). 8.15 Record keeping requirements. Local orders are to include details of records to be kept, who is to keep them and for how long. Such records can include monitoring instrument log cards, monitoring survey records, radiation dose records, health records, source accounting records, radioactive waste records, incident reports, records of maintenance and examination of PPE and engineering controls. Detailed instructions regarding maintenance of the above records are provided in the appropriate Leaflets overall record keeping policy is at Volume 1 Chapter 11. 9 Copies of relevant local orders (or parts thereof) are to be posted close to the areas to which they apply. Personnel are to be made aware of the content of local orders. The CO or their nominated representative is required to take all reasonable steps to ensure that local orders are observed.

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10 Further instruction and guidance on the content of local orders for specific uses can be found in the relevant leaflet. ADDITIONAL REQUIREMENTS OF LOCAL RULES (APPLIES TO DESIGNATED AREAS) 11 IRR99 requires, for the purposes of enabling work with ionising radiation to be carried out, that every CO shall, in respect of any controlled area, or where appropriate, any supervised area make and set down in writing such local rules as are appropriate to the radiation risk and nature of the operations to be undertaken in that area. Although many of the requirements for local rules are encompassed in the general requirements for local orders stated above, there are a number of additional considerations which must be addressed. Detailed guidance for local rules is provided at Annex A. CONTINGENCY PLANS 12 An essential component of local orders and local rules is the identification or summary of any contingency arrangements indicating the reasonably foreseeable accidents or occurrences to which they relate. Contingency plans can be contained within local orders or referred out to the appropriate documents which are to be made available to any person who might be affected by the accidents or occurrences. Such persons are also to be provided with training and instructions appropriate to the actions that they are to take. General instructions on contingency plans are given in Leaflet 40. 13 Further instruction and guidance on the content of specific contingency plans can be found in the relevant leaflet. REVIEW OF LOCAL ORDERS 14 Local orders shall be reviewed by a unit or establishment whenever the risk assessment or review of the risk assessment (see Leaflet 2) indicates that a change to local orders is required, or whenever there have been other significant changes e.g. changes to the methods of work or practices carried out in relation to the work with ionising radiations. STANDARD LOCAL ORDERS 15 Dstl ESD has produced a number of specimen sets of local orders (which also incorporate the requirements of local rules) for many units and establishments. They can be obtained from the RPA in electronic format and subsequently tailored to meet the requirements of the individual unit or establishment. RECORDS 16 Reference copies of local orders are to be retained for a minimum period of 2 years after they are superseded. At the end of this period, an assessment on the relevance of retaining the document is to be made in accordance with MOD policy at Volume 1 Chapter 11.

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RELATED LEAFLETS 17 Leaflets referred to within this leaflet are shown in Table 1. Table 1 Related Leaflets Leaflet Number 1 2 3 Leaflet Title

Procurement of sources of ionising radiation Risk assessments Notification, approval and assessment of the introduction and use of radioactive substances and other sources of ionising radiation Restriction of exposure to radiation Dosimetry and personal dose records Radiation detection and monitoring equipment Storage and accounting for radioactive materials Accumulation and disposal of radioactive waste Investigation, notification and reporting of unusual radiation events Gaseous tritium light sources and devices Instruments containing Nickel-63 Contingency plans

4 6 8 9 12 14 19 20 40

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LEAFLET 16 ANNEX A PROVISION OF LOCAL RULES CONTENTS Para

1 3 4 5 6

Introduction Local rules Essential contents of local rules Optional content of local rules Making local rules effective

INTRODUCTION 1 For the purposes of enabling work with ionising ionising radiation to be carried on in accordance with IRR 99, the Regulations require that every radiation employer (e.g. CO, Head of Establishment) shall, in respect of for any controlled area, or where appropriate any supervised area provide a written set of local rules as are appropriate to the radiation risk and the nature of operations undertaken in that area. 2 It is also a requirement of the Regulations that an RPA is consulted regarding the implementation of requirements as to controlled and supervised areas, and therefore regarding the content of local rules which describe measures to be taken in such designated areas. LOCAL RULES 3 Local rules will vary between units and establishments, both in detail and in format, depending on the complexity of the work and the radiation risk involved, but in general they must detail, as necessary, the information shown below. Note that these requirements of local rules are in addition to the MOD requirements for local orders specified in Leaflet 16. Essential contents of local rules 4 The Health and Safety Executive (HSE) have identified a number of areas that must be addressed in local rules these are as follows: 4.1 Investigation level. The dose level at which the CO will carry out an investigation shall be specified in the local rules. The purpose of this investigation is to trigger a review of working conditions to make sure that exposure is being restricted as far as is reasonably practicable (see Leaflet 4). It is MOD policy that the investigation level shall not exceed 6 mSv. 4.2 Contingency plans and emergency procedures. The rules shall also contain or refer to detailed contingency plans and emergency procedures, indicating the reasonably foreseeable accidents to which they relate. Examples of such procedures are: dealing with a broken radioactive electronic valve or gaseous tritium light sources (GTLS); recovery of a jammed radiography source, searching for and reporting a lost source; dealing with the non-termination of an X-ray exposure and first aid treatment. Reference shall also be made to first aid and emergency medical arrangements. 4.3 Name(s) of the appointed radiation protection supervisors.

4.4 Location and description of areas covered. Each area covered shall be identified and described together with its designation (controlled/supervised). The designation of supervised and controlled areas is described in Leaflet 4.

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4.5 Summary of Work Instructions. The written local rules shall identify the key working instructions intended to restrict any exposure in that controlled or supervised area. The summary shall cover instructions for restriction of access, storage, handling etc of radioactive substances, dose reduction methods, the use of PPE, RPE and safety equipment, written arrangements for unclassified persons entering a controlled area, permits to work and systems of work. Where detailed written working instructions are contained within operations manuals etc it is sufficient for the local rules to refer to the relevant sections of these documents. Optional content of local rules 5 The HSE have identified a number of other areas which have to be addressed to comply with IRR 99. These areas can be covered in separate documents, included in or referred to in local rules. They are thus termed an optional content of local rules and are as follows: 5.1 Management and supervision of the work. The RPS and other employees must be made aware of management and supervision arrangements including arrangements for monitoring and auditing compliance with the Regulations. Provided this information is included in general safety instructions, it would not need to be reproduced in local rules. 5.2 Testing and maintenance. A summary of the arrangements for testing and maintaining engineering controls and design features, safety features and warning devices 5.3 Radiation and contamination monitoring. Local rules are to detail (or refer to) standard operating procedures for workplace radiation and contamination monitoring, together with appropriate frequencies where applicable. Examples are: monitoring for contamination of areas where luminised equipment is routinely handled; monitoring of benches where tracer isotopes are prepared; monitoring gamma dose rates at the boundaries of source stores; monitoring of X-ray security equipment. 5.4 Examination and testing of radiation monitoring equipment. All instruments that are to be used for radiological measurements are required to function correctly. To this end local rules are to include (or refer to) the procedures for regular functional checks of each instrument and arrangements for annual calibration in accordance with Leaflet 8. Consultation with the RPA on calibration and checking of instruments is a statutory requirement. 5.5 Personal dosimetry. With certain exceptions, all persons entering a controlled area are to wear radiation dosemeters issued by the Approved Dosimetry Service (normally Dstl ESD). Local rules are to express the dosimetry requirement for each work area or task. The arrangements for Outside Workers are to be included (see Leaflets 4 and 6). 5.6 Arrangements for pregnant and breast-feeding staff. A reference is to be made to the requirement for a female member of staff to notify her CO that she is pregnant or breast feeding. Local rules shall also refer to the arrangements to be put in place such that, once the CO has been notified of pregnancy, the conditions of exposure are set such that the dose to the foetus is unlikely to exceed 1 mSv during the remainder of the pregnancy. Reference shall also be made to any arrangements necessary to prevent bodily contamination to an employee who is breastfeeding. 5.7 Medical surveillance. Local rules are to include instructions or reference to requirements for any medical examinations or health reviews, which can be necessary statutorily (See Leaflet 6). 5.8 Risk assessments. A summary of the significant findings of the risk assessment are to be included or a reference as to where it can be found (See Leaflet 2). 5.9 ALARP reviews. Local rules are to include the programme for reviewing whether doses are being kept as low as reasonably practicable and whether local rules remain effective. 5.10 Investigations and reporting. Local rules are to include the requirements for and the procedures for initiating investigations and reporting the outcome (see Leaflet 14).

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Training. Local rules shall detail the procedures for ensuring that employees have received sufficient information, instruction and training. 5.11 RPA consultation. Local rules are to include the requirement and procedures for contact and consultation with the appointed RPA. MAKING LOCAL RULES EFFECTIVE 6 When producing local rules a balance will need to be struck between the provision of necessary details and the inclusion of excessive information to the extent that the people to whom they relate can be discouraged from reading them fully. 7 Local rules are likely to be effective if they: 7.1 Are brief, concentrating on areas with the greatest risks.

7.2 Focus on work instructions to be followed to keep radiation doses As Low As Reasonably Practicable (ALARP). 7.3 7.4 Contain clear instructions which reflect actual work practice. Are reviewed periodically to ensure that they remain relevant.

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Leaflet 16 Annex A Page 4/4

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LEAFLET 17 RADIOACTIVE ELECTRONIC VALVES CONTENTS Para 1 3 4 5 6 7 8 9 10 11 13 14 15 18 Table 1 2 3 4 5 Fig 1 2 3 Annex A B C Class 1 radioactive electronic valve example of a summary radiation risk assessment Class 2 radioactive electronic valve example of a summary radiation risk assessment Hazard grade radioactive electronic valve example of a summary radiation risk assessment Theta marking for Class 1 radioactive valves. Marking for Class 2 radioactive valves. Marking for hazard grade radioactive valves Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) and Head of Establishment Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Classification of radioactive electronic valves Markings on radioactive electronic valves Markings on containers and equipment housing radioactive electronic valves Risk assessments for radioactive electronic valves Handling of radioactive electronic valves Breakage of radioactive electronic valves Legal and MOD mandatory requirements Page Maximum radionuclide content of Class 1 and Class 2 valves .......................................................3 Markings on radioactive valve containers .......................................................................................4 Markings on equipments containing radioactive valves ..................................................................4 Hazards associated with radioactive electronic valves ...................................................................5 Legal and MOD mandatory requirements for radioactive electronic valves....................................6

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SCOPE 1 A large number of radioactive electronic valves are used across a wide range of MOD activities particularly in radar and telecommunications equipment. Items such as electronic switches, spark gaps, protection cells, pre TR cells, surge protectors and high energy ignition switches may all contain radioactive material either in gaseous or solid form. Such valves are classified either as Class 1, Class 2 or Hazard Grade valves depending on the quantities of radioactive material they contain. 2 This leaflet describes the radiological requirements for keeping, using and disposing of such equipment. Summaries of the radiation risk and regulatory requirements for examples of electronic valves are provided at the annexes to this leaflet. Summary risk assessments for a comprehensive range of electronic valves are available from the RPA who may also be consulted for further advice regarding the hazards and requirements for these items. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Radioactive Substances (Electronic Valves) Exemption Order 1967 (parallel arrangements).

Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 5 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping, using and disposing of electronic valves containing radioactive material as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

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Radiation Protection Supervisor (RPS) 6 Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Further information on the requirements for appointment of an RPS is given in Table 5. Workplace Supervisor (WPS) (Radioactive Materials) 7 In units holding radioactive electronic valves but where it is unnecessary to appoint an RPS, a WPS (Radioactive Materials) is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Employees 8 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that these items are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager. CLASSIFICATION OF RADIOACTIVE ELECTRONIC VALVES 9 The Hazardous Stores Information System (HSIS) contains details of radioactive electronic valves. The Class or Grade of a valve can also be identified from markings on the valve and it is therefore important to be aware of the markings which are associated with each Class of valve. Table 1 shows the maximum activity content of specified radionuclides for Class 1 and Class 2 valves. Valves that exceed the maximum quantity for Class 2 are designated as hazard grade valves. Classification for valves containing more than one radionuclide is determined by the pro rata contribution of each nuclide. Valves containing nuclides other than those specified in Table 1 are designated as hazard grade valves. Further advice may be sought from the RPA. Table 1 Maximum radionuclide content of Class 1 and Class 2 valves Radionuclide Cobalt-60 (Co-60) Nickel-63 (Ni-63) Caesium-137 (Cs-137) Thorium (any isotope of) (Th-..) Thallium-204 (Tl-204) Radium-226 (Ra-226) Uranium (any isotope of) (U-..) Carbon-14 (C-14) Chlorine-36 (Cl-36) Promethium-147 (Pm-147) Gaseous radionuclides: Krypton-85 (Kr-85) Tritium* (H-3) Class 1 3.7kBq 3.7kBq 3.7kBq 3.7kBq 3.7kBq 3.7kBq 3.7kBq 37kBq 37kBq 185kBq Class 2 37 kBq 37 kBq 37 kBq 37 kBq 37 kBq 37 kBq 37 kBq 370 kBq 370 kBq 1110 kBq

370kBq 5550kBq

3700 kBq

*Any valve containing more than 5550kBq of tritium is classified as hazard grade. Any valve containing Americium-241 is classified as hazard grade and is subject to 24 monthly leak test.

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MARKINGS ON RADIOACTIVE ELECTRONIC VALVES 10 The approved markings found on radioactive electronic valves are shown in Figs 1, 2 and 3. CLASS 2 CAUTION

Figure 1 Theta marking for Class 1 radioactive valves. Colour of marking black. (See Note.) Figure 2 Marking for Class 2 radioactive valves. Colour of symbol: black on yellow background. NOTE 11

55 MBq H-3 Figure 3 Marking for hazard grade radioactive valves. Colour of symbol: black on yellow background.

Class 1 radioactive valves manufactured after April 1995 are marked as in Fig 2, with the legend CLASS 1. Colour as in Fig 2. MARKINGS ON CONTAINERS AND EQUIPMENT HOUSING RADIOACTIVE ELECTRONIC VALVES Containers holding radioactive electronic valves are identified by the markings shown in Table 2. Table 2 Markings on radioactive valve containers Class 1 Envelope, carton and crate markings. or trefoil Class 2 Class 2 and trefoil sign and marked radioactive electronic valve. Hazard Grade Trefoil in black on yellow background and marked Radioactive: handle only as instructed.

12 Equipment containing radioactive electronic valves is to have markings containing the information given in Table 3. Table 3 Markings on equipments containing radioactive valves Class 1 or Class 2 Equipment containing radioactive valves The words Class 1 or 2 as appropriate Trefoil symbol CV number(s)* Hazard Grade Trefoil symbol. The words Hazard Grade. CV number(s)

*CV number = Valve Classification Number

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HAZARDS Table 4 Hazards associated with radioactive electronic valves Radiation type Emitted Comments Alpha radiation is emitted within valves containing nuclides of radium, thorium and uranium. The alpha radiation does not penetrate beyond the casing of the valve. Alpha radiation poses a potential internal hazard only in the event of breakage of the valve. Low energy beta radiation is emitted within valves containing H3, C-14, Ni-63, Pm-147 but the energy of the beta is insufficient to penetrate beyond the valve casing. Higher energy beta radiation, which may penetrate for a short distance beyond the valve casing, is emitted from valves containing Cl-36, Co-60, Kr-85, Tl-204, Ra-226, Thorium and Uranium. Beta radiation poses a potential hazard in the event of breakage of a valve due to the possibility of inhalation of gas (H-3 or Kr-85), inhalation of dusts or via contamination of the skin. Low levels of Bremsstrahlung radiation (X-rays) are emitted from valves containing beta emitters. Gamma radiation is emitted by valves containing Co-60, Ra-226, Thorium and Uranium. Valves containing Kr-85, Pm-147 also emit low levels of gamma radiation. External radiation dose rates depend on the activity of the gamma emitter contained within the valve but the levels are likely to be measurable only within about 30 cm of the valve. (see examples of summary risk assessments at annexes to this leaflet). Parasitic X-rays are a by-product arising from many types of high voltage equipment (>5 kV) (see Leaflet 23). They may be emitted from electronic valves within high voltage equipment and/or other parts of the equipment when it is operating.

Alpha

Direct Beta

Bremsstrahlung

Gamma

X-rays Neutrons

RISK ASSESSMENTS FOR RADIOACTIVE ELECTRONIC VALVES 13 The number of radioactive electronic valves in service within MOD is too large to list in this publication. Similarly, it is not possible to include risk data for all valves. However, summary risk assessments for an example of each of a Class 1, 2 and hazard grade valve are reproduced at Annexes A to C of this leaflet. These summary risk assessments may be used to scope the hazard and control requirements for a wider range of valves and may be used, where appropriate, as input to the risk assessments and local orders required in accordance with Leaflets 2 and 16 respectively. Advice on further detail and assessments for radioactive electronic valves may be sought from the RPA. HANDLING OF RADIOACTIVE ELECTRONIC VALVES 14 No protective clothing is required for the routine handling of radioactive electronic valves. However, the valves are not to be carried on the person. BREAKAGE OF RADIOACTIVE ELECTRONIC VALVES 15 Radioactive valves are not to be broken deliberately.

16 A broken radioactive valve is potentially hazardous because loose radioactive material can enter the body by a variety of means including inhalation of gaseous material (if present), inhalation of radioactive dust and absorption through cuts or scratches in the skin.

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17 Because a large number of radioactive valves contain gaseous tritium (H-3), it is important that the room or compartment where the breakage has occurred is vacated for 1 hour to ventilate before dealing with the broken fragments wearing gloves and safety goggles. If it is certain that the valve does not contain tritium or krypton-85 (Kr-85), then a delay before dealing with the fragments is not necessary. Detailed guidance on the procedure for dealing with and disposing of a broken valve is in Leaflet 40. LEGAL AND MOD MANDATORY REQUIREMENTS 18 Table 5 below summarises the legal and MOD mandatory requirements for radioactive electronic valves. Class 1, Class 2 and hazard grade valves are all considered. In cases of doubt, the RPA is to be consulted for advice. Table 5 Legal and MOD mandatory requirements for radioactive electronic valves Requirement HSE authorisation Applicable Comments In general, work carried out involving radioactive valves is to be notified to HSE in accordance with Leaflet 3. Where only small numbers of valves are held, notification may not be necessary (see Leaflet 3). Holdings of any number of Class 1 valves are exempt from notification to the relevant environment agency. Up to 10 Class 2 valves may be held without notification of the relevant environment agency, provided, when not in use, valves are stored in an appropriately marked container. Where Class 2 valves are incorporated in equipment, there is no limit on the numbers which may be held without notification. Holdings of hazard grade valves must be included in notifications to the appropriate relevant environment agency in accordance with Leaflet 3. See examples at Annexes to this leaflet. Further specific risk assessments or prior risk assessments may be required (see Leaflet 2). Observe manufacturers instruction and guidance. Also, see Leaflet 4. Not required except when dealing with a breakage See Leaflet 40 breakage/fire Related leaflet* -

HSE notification

EA/SEPA notification** (Class 1 Valves only)

EA/SEPA notification (Class 2 Valves only)

(but see comment

EA/SEPA notification** (hazard grade valves only) Risk assessment Restriction of exposure PPE Maintenance of radiation engineering controls Contingency plans

2 4 40

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Table 5 Legal and MOD mandatory requirements for radioactive electronic valves (continued) Requirement Applicable Comments The presence of radioactive electronic valves in equipment does not usually, on its own, lead to a requirement for area designation designation may, however, be necessary for other reasons (e.g. parasitic X-rays). Stores holding quantities of electronic valves may require designation if they meet the criteria detailed in Leaflet 4. Note: small stores which people cannot enter (e.g. drawers or cupboards) do not require designation but must be appropriately marked. Monitoring of installed electronic valves is not required but where stores are designated areas, then monitoring will be required in accordance with Leaflets 4 and 8. Information and Instruction only. See Leaflet 16 for guidance. RPS not required except for storage areas required to be designated as controlled or supervised. Where an RPS is not required, a WPS (Radioactive Materials) needs to be appointed in accordance with Leaflet 39. In a segregated secure store/container/cupboard marked with radiation trefoil warning sign and stored in accordance with Leaflet 9. Valves are not to be removed from their cartons until required. Recorded on a source list (retained for 2 years) and mustered in accordance with Leaflet 9. Recorded on Dstl Annual Holdings Return, copy retained for 1 year. Leak testing is not normally appropriate for valves containing gaseous radioactive material. For valves containing solid or liquid radioactive material, the risk assessment is to identify whether or not leak testing is appropriate; the RPA should be consulted. Personal dosimetry will only need to be worn if there is a requirement for a designated area. All losses and certain other incidents require to be reported to MOD authorities. Reporting to external regulatory authorities may also be required. See Leaflet 14 for details. Items and bulk quantities may generally be transported as excepted packages subject to the item and package limits for other form (rather than special form items) as detailed in JSP 800 Vol. 4b (road, rail, sea) or JSP 800 Vol. 4a (air). All radioactive electronic valves and equipment, stores and containers holding such valves are to be marked appropriately in accordance with this leaflet. Related leaflet*

Designated areas

(but see comment)

Monitoring Training for users Local orders

(but see comment)

4, 8 15 16

Appointed person

39

Storage

Accounting

Leak testing

Personal dosimetry

(but see comment)

Reporting procedures

14

Transport

JSP 800 Vol. 4a & Vol. 4b

Marking

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Table 5 Legal and MOD mandatory requirements for radioactive electronic valves (continued) Requirement Sale/transfer Applicable Comments See Leaflet 11 Many valves have an intrinsic value even when they become defective. Thus, they are normally to be returned through stores or otherwise returned as advised by the IPT. Where a valve is considered disposable as waste, advice is to be sought from the RPA on an appropriate disposal route radioactive valves are not to be disposed of as refuse unless specifically advised by the RPA. Leaflet 12 also refers. Keep records of disposal for 2 years. Related leaflet* 11

Disposal of redundant items

12

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 17 ANNEX A CLASS 1 RADIOACTIVE ELECTRONIC VALVE EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

Tuned T 1007 Radar (Waveguide Fit)

Description Valve BS810 Tuned Junction Box Valve marking Tuned T . The radioactive valve BS810 is found within a junction box (NSN 5840-99-543-3741/5985-99-531-8473) of the Kelvin Hughes 1007 Radar waveguide See BR 8549 for maintenance and fitting. Use Supplier NSN / Part No IPT Radionuclide Ionising radiation Half life Original activity Classification External radiation hazard Navigational and Helicopter operation frequency adjustment. E2V Technologies, 106 Waterhouse Lane, Chelmsford, Essex CM1 2QU 5960-99-000-1923/BS810 FWS. Tritium (H-3). Beta (low energy (19 kEV)). 12.3 years. 5.43 MBq. Class 1 valve under the Radioactive Substances (Electronic Valves) Exemption Order 1967 SI 1797 which relates to RSA 93. H-3 does not present an external radiation hazard since the beta radiation is of low energy and will not penetrate even a thin layer of material. Very small amounts of tritium leak from these valves over a prolonged period of time but this does not present a significant health risk. The escape of tritium from a broken valve could result in a minor health risk if breakage occurs in a confined space. Tritium may be present both as an elemental gas (behaving, chemically, in the same way as hydrogen gas) and also in the form of tritiated water vapour. The latter (behaving, chemically, in the same way as water vapour) presents the greater hazard due to its ability to enter the body both by inhalation and by rapid absorption through the skin. In the case of breakage, evacuation affords the best protection against internal hazards since the filters in respiratory protection will not absorb tritium nor prevent absorption through the skin. Total dose to an individual, following breakage of a single valve of this type in a confined space is likely to be less than 0.2 Sv.

Internal radiation hazard

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Local orders Control measures during use Inspection Leak testing

Tuned T 1007 Radar (Waveguide Fit) (continued) Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Item not to be carried on the person. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Although exempt from formal RSA 93 notification to the environment agencies, this item is to be included in the Annual Holdings Return to Dstl Leaflet 3 refers. If uninstalled, this item is to be stored in a dedicated area for radioactive materials see Leaflet 9. The equipment is to display the recognised radioactive valve warning label on it. The storage/installed area is also to have a sign showing radioactive material within. i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS (Radioactive Materials) and stating the nature of the radiological hazard Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item is damaged. If a breakage occurs the area is to be evacuated and ventilated. Tritium gas will disperse relatively quickly, however some may remain bonded to the component. Once a suitable amount of ventilation time (one hour) has passed, the broken item can be cleaned up using a breakage kit, see Leaflet 40. RPA advice is to be sought regarding disposal of the fragments. Reporting of loss and certain other incidents is to be carried out in accordance with procedures described in Leaflet 14. This item may be transported within an excepted package provided the total package activity does not exceed 8000GBq. Units and Establishments are to return this item, unbroken, through the Stores Organisation. Broken items are to be disposed of in accordance with Leaflet 40.

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans breakage/loss/incident

Transport Disposal

Leaflet 17 Annex A Page 2

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LEAFLET 17 ANNEX B CLASS 2 RADIOACTIVE ELECTRONIC VALVE EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

Goalkeeper Spark Gap TG-375-20 5/24KV CLASS 2 One Spark Gap found in High Voltage Circuit. Description BR 8423(7) Vol 2 Fig 04-033 Items BV1 Spark Gap diagram Use Supplier NSN / Part number IPT Radionuclide Ionising radiation Half life Original activity Classification External radiation hazard Spark gap. Clare High Energy Devices, Maryland Heights, MO 63043, USA. 5920-01-223-0747 Goalkeeper. Caesium137 ( 1.17 MeV, 510 keV, 662 keV). Beta and Gamma. 30 years. 37 kBq. Hermetically sealed Class 2 valve under the Radioactive Substances (Electronic Valves) Exemption Order 1967 SI 1797 which relates to RSA93. Caesium-137 sealed sources emit gamma radiation. The dose rate arising from 37 kBq of Cs-137 is <0.5 Svh-1 at 10 cm and <0.1Svh-1 at 30 cm. An internal hazard can only occur if the valve is broken. The likelihood of damage to this component when installed to such a degree that caesium escapes is low. A more severe accident, for example, crushing, could possibly result in a small fractional release. Should this happen then a committed effective dose of <0.01Sv could be received, which is insignificant. Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing required. This item is not to be carried on the person and handling of the item is to be kept to a minimum. Annually as well as during routine maintenance. Check is to be made for signs of damage. Leak testing is not required for this component. / 3522 500 41574 ( TG-375 -20 5/24KV ). Valve marking

Internal radiation hazard

Local orders Control measures during Use Inspection Leak testing

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Radiation Safety Handbook

Goalkeeper Spark Gap TG-375-20 5/24KV (continued) This item is to be accounted for on a Radioactive Source List (Leaflet 9 refers) under the supervision of an RPS or WPS (Radioactive Materials). Accounting All radioactive material is to be mustered at least monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. This Class 2 item is exempt from notification to the environment agencies under RSA 93 providing either it is installed in equipment or Radioactive Substances no more than 10 Class 2 valves are stored (Leaflet 9 refers). The item Act 1993 is, however, to be included in the Annual Holdings Return to Dstl ESD (Leaflet 3 refers). If uninstalled, this item is to be stored in a dedicated area for radioactive materials (see Leaflet 9). The equipment is to have the recognised radioactive trefoil and marking on it. The storage/installed area is also to have a sign showing radioactive Storage and labelling material within. i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS (Radioactive Materials) and stating the nature of the radiological hazard: Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged. If a breakage occurs the area is to be cordoned off. The broken item can be cleaned up using a breakage kit (Leaflet 40 refers). Contingency plans Reporting of loss and certain other incidents are to be carried out in breakage/loss/incident accordance with the procedures described in Leaflet 14. These items may be transported as excepted packages providing the Transport total package activity does not exceed 600 GBq. Units and Establishments are to return this item, unbroken, through the Disposal Stores Organisation. Broken items are to be disposed of in accordance with Leaflet 40.

Leaflet 17 Annex B Page 2

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LEAFLET 17 ANNEX C HAZARD GRADE RADIOACTIVE ELECTRONIC VALVE EXAMLE OF A SUMMARY RADIATION RISK ASSESSMENT

SCOT 1A/1D/2D TR Cell CAUTION

Description BS4415 Antenna

55 MBq H-3 Valve Markings

Use Supplier NSN IPT Radionuclide Ionising radiation Half life Original activity Classification External radiation hazard

The BS4415 valve is a sealed volume of 9.1 cc constructed of steel and glass. There is only one radioactive valve in each cell. (NSN 0601-99-805-3998). Protection from high voltage power surges Two cells are installed in Scot 1A/1D/2D. E2v Technologies,106 Waterhouse Lane, Chelmsford, Essex CM1 2QU. 5999-99-798-9212. FWS. Tritium (H-3). Beta (low energy (19 keV)). 12.3 years. 55 MBq. Classified as a Hazard Grade valve which does not qualify for exemption under the electronic valves exemption order. Therefore the RSA93 requirements apply. H-3 does not present an external radiation hazard since the beta is of low energy and will not penetrate even a thin layer of material. Very small amounts of tritium leak from these valves over a prolonged period of time but this does not present a health risk. The escape of tritium from a broken valve could result in a minor health risk if breakage occurs in a confined space. Tritium may be present both as an elemental gas (behaving, chemically, in the same way as hydrogen gas) and also in the form of tritiated water vapour. The latter (behaving, chemically, in the same way as water vapour) presents the greater hazard due to its ability to enter the body both by inhalation and by rapid absorption through the skin. In the case of breakage, evacuation affords the best protection against internal hazards since the filters in respiratory protection will not absorb tritium nor prevent absorption through the skin. Total dose to an individual, following breakage of a single valve of this type in a confined space is likely to be less than 2 Sv.

Internal radiation hazard

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Leaflet 17 Annex C Page 1

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Radiation Safety Handbook

Local orders Control measures during use Inspection Leak testing

SCOT 1A/1D/2D TR Cell (continued) Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Item not to be carried on the person. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List (see Leaflet 9) under the care of an appointed RPS or WPS (Radioactive Materials). All radioactive material is to be mustered at least monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. This item is not exempt and must be included in the RSA 93 notification to the appropriate environment agency (Leaflet 3 refers). It is also to be included in the Annual Holdings Return to Dstl ESD (Leaflet 3 refers). If uninstalled this item is to be stored in a dedicated area for radioactive materials (see Leaflet 9). The equipment is to have the recognised radioactive trefoil on it. The storage/installed area is also to have a sign showing radioactive material within. i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS (Radioactive Materials) and stating the nature of the radiological hazard Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged. If a breakage occurs the area is to be evacuated and ventilated. Tritium gas will disperse relatively quickly, however tritium may remain bonded to the component. Once a suitable amount of ventilation time (1 hour) has passed, the broken item can be cleaned up using a breakage kit (see Leaflet 40). RPA advice is to be sought regarding disposal of the fragments. Reporting of loss and certain other incidents is to be carried out in accordance with procedures described in Leaflet 14. This item may be transported in an excepted package provided the total package activity does not exceed 8000 GBq. Units and Establishments are to return this item, unbroken, through the Stores Organisation.

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans breakage/loss/incident

Transport Disposal

Leaflet 17 Annex C Page 2

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LEAFLET 18 SMOKE DETECTORS CONTAINING AMERICIUM-241 CONTENTS Para 1 4 5 6 7 8 9 10 11 13 Table 1 2 3 Annex A B Summary radiation risk assessment for lower activity smoke detector Summary radiation risk assessment for higher activity smoke detector Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Risk assessments for smoke detectors Handling of smoke detector heads Legal and MOD mandatory requirements Page Hazard associated with Am-241 smoke detectors ..........................................................................3 List of common smoke detectors used in MOD ..............................................................................4 Legal and MOD mandatory requirements for smoke detectors containing Am-241 .......................5

SCOPE 1 This leaflet applies only to smoke detector heads incorporating radioactive sources containing Americium-241 (Am-241). The following information describes the requirements for keeping, using and disposing of such equipment. Summaries of the radiation risks and regulatory requirements for two examples of smoke detector heads containing Am-241 are included in the annexes to this leaflet. The examples chosen are representative of a lower activity and a higher activity Am-241 smoke detector. 2 Summary risk assessments for a comprehensive range of smoke detectors are available from the RPA who is also to be consulted regarding the hazards and requirements for detectors not covered by the scope of this leaflet. 3 It should be noted that, where reasonably practicable and where suitable alternatives exist, nonradioactive detectors should be used in preference to those containing radioactive material. Smoke detectors containing Ra-226 are not to be used.

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Radiation Safety Handbook

STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 4 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR9) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Radioactive Substances (Smoke Detectors) Exemption Order 1980 as amended by the Radioactive Substances (Smoke Detectors) Exemption (Amendment) Order 1991 (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 5 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 6 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards of their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping, using and disposing of smoke detectors containing radioactive material as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 7 Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. The requirements for appointment of an RPS are covered in Table 3. Workplace Supervisor (WPS) (Radioactive Materials) 8 In units holding smoke detectors but where it is unnecessary to appoint an RPS, a WPS (Radioactive Materials) is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet.

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Employees 9 It is the responsibility of all employees to ensure that they are familiar with the relevant requirements of local orders to ensure that these items are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager. HAZARDS Table 1 Hazard associated with Am-241 smoke detectors Radiation type Emitted Comments Alpha radiation emitted from the foil source will not penetrate beyond the casing of the smoke detector head. Alpha radiation poses a potential internal hazard only in the event of breakage of the detector head and the sealed Am-241 source. Direct Bremsstrahlung Gamma radiation and low energy X-rays are emitted by the source and will penetrate through the smoke detector head. External radiation dose rates depend on the activity of Am-241 but will only be significant within about 30 cm of the detector heads (see summary risk assessments at annexes to this leaflet).

Alpha

Beta

Gamma

X-rays Neutrons RISK ASSESSMENTS FOR SMOKE DETECTORS 10 Table 2 gives brief details of a number of smoke detectors in service in MOD. The list is not intended to be exhaustive. Summary risk assessments for a lower activity smoke detector (up to 40 kBq Am-241) and a higher activity (2.2 MBq Am-241) are provided at Annexes A and B respectively. These summary risk assessments may be used to scope the hazard and control requirements for all the detectors listed in Table 2 and may be used as input to the risk assessments and local orders required in accordance with Leaflets 2 and 16 respectively. Advice on further detail and assessments for detectors not listed may be sought from the RPA.

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Table 2 List of common smoke detectors used in MOD Supplier Tyco (Thorn)(Minerva) Tyco (Thorn)(Minerva) Tyco (Thorn)(Minerva) Tyco (Thorn)(Minerva) Ginge-Kerr Hochiki Apollo Tyco (Thorn)(Minerva) Tyco (Thorn)(Minerva)Miner va Tyco (Thorn)(Minerva) Minerva Minerva Minerva CAM Kiddie Fireseer Hochiki Tann Synchrome Hochiki Apollo Name MF 301EX MF 301 F712 EX F712 M System Sensor 1551 Model AIE Series 60 MF 501 EX MF 501 MF 901 F31 F35 F36 Mk IV K93222 PID-B SmokeTec PID-SIC-E 53541-111 NSN 051-6941 313-3953 012-010 768-1561 465-2258 NPI-0536 301-4061 125-4400 930-5380 151-1011 519-3461 542-2133 519-3462 NPI-0014 NPI-0427 NPI-0044 NPI-0041 NPI-0025 NPI-0369 Am-241 Activity 33.3 kBq 33.3 kBq 29.6 kBq 29.6 kBq 37 kBq 33.3 kBq 33 kBq 33.3 kBq 40 kBq 33.3 kBq 3 sources total 2.2 MBq 3 sources total 2.2 MBq 3 sources total 2.2 MBq 259 kBq 370 kBq 166 kBq 111 kBq 166 kBq 266 kBq Summary risk assessment Annex A Annex A Annex A Annex A Annex A Annex A Annex A Annex A Annex A Annex A Annex B Annex B Annex B Annex B Annex B Annex B Annex B Annex B Annex B

HANDLING OF SMOKE DETECTOR HEADS 11 Latex or surgical gloves are to be worn by personnel routinely handling higher activity smoke detector heads or large quantities of low activity smoke detector heads. 12 Smoke detector heads are not to be dismantled, repaired or tampered with in any way except by authorised persons working to approved procedures and with the advice of the RPA. LEGAL AND MOD MANDATORY REQUIREMENTS 13 Table 3 below summarises the legal and MOD mandatory requirements for smoke detectors containing Am-241. Two categories are considered - where a smoke detector does not fall into either of the two categories or where it contains radionuclides other than Am-241, the RPA is to be consulted for advice. The two separate categories of smoke detector considered in Table 2 are: Those containing up to 40 kBq of Am-241 (i.e. 40 kBq). Those containing more than 40 kBq of Am-241 but up to 2.2 MBq (i.e. > 40 kBq 2.2 MBq).

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Table 3 Legal and MOD mandatory requirements for smoke detectors containing Am-241 Requirement HSE authorisation (both categories) HSE notification ( 40 kBq) HSE notification (>40 kBq 2.2 MBq) EA notification** ( 40 kBq) EA notification** (> 40 kBq 2.2 MBq) Risk assessment (both categories) Restriction of exposure (both categories) PPE (both categories) Maintenance of radiation engineering controls (both categories) Contingency plans (both categories)
(but see comment) (but see comment) (but see comment) (but see comment)

Applicable

Comments

Related leaflet*

Only if more than 500 uninstalled smoke detectors are stored in any building must HSE must be notified in accordance with Leaflet 3. Notification not necessary where these smoke detectors are installed but HSE must be notified where 1 or more of these detectors are stored. Only if more than 500 uninstalled smoke detectors are stored in any building must EA be notified in accordance with Leaflet 3. Notification not necessary where these smoke detectors are installed but notification is required where 1 or more of these detectors are stored. See Annexes, further specific risk assessments or prior risk assessments may be required. See Leaflet 4. Latex or surgical gloves are to be worn if handling large quantities of these detectors.

3 2 4 4

See Leaflet 40. Areas housing solely installed smoke detectors do not require designation but stores holding quantities of smoke detectors may require designation if they meet the criteria detailed in Leaflet 4. Note: small stores which people cannot enter (e.g. drawers or cupboards) do not require designation but must be marked. Monitoring of installed detectors is not required but where stores are designated areas, then monitoring will be required in accordance with Leaflets 4 and 8. Information and Instruction only. See Leaflet 16 for guidance. RPS not required except for storage areas required to be designated as controlled or supervised areas. Where an RPS is not required, a WPS needs to be appointed in accordance with Leaflet 39. In a segregated secure store/container/cupboard marked with radiation trefoil warning sign and stored in accordance with Leaflet 9.

40

Designated areas (both categories)

(but see comment)

Monitoring (both categories) Training for users (both categories) Local orders (both categories) Appointed person (both categories)

(but see comment)

4, 8

15 16

39

Storage (both categories)

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Table 3 Legal and MOD mandatory requirements for smoke detectors containing Am-241 (continued) Related leaflet*

Requirement

Applicable

Comments Mustered annually, recorded on a source list and retained for 2 years. Where detectors require leak testing (see below), test certificates are to be retained in accordance with Leaflet 9. Recorded on Dstl Annual Holdings Return, copy retained for 1 year. Smoke detectors containing up to 40 kBq of Am-241 do not require to be leak tested. Where experience shows that a particular type of detector is prone to leakage, appropriate testing will be recommended by the RPA. Leak testing is currently required for F31, F35 and F36. Smoke detectors F31, F35 and F36 require to be leak tested at intervals no greater than 24 months. Contact the RPA for details of leak testing, if unsure. Details of the leak test undertaken and the results obtained are to be retained for 2 years. Personal dosimetry will only need to be worn if there is a requirement for a designated area. All losses to be reported in accordance with Leaflet 14. Items transported as Exempt Packages in accordance with JSP 800 Vol. 4b (road, rail, sea) or JSP 800 Vol. 4a (air) maximum number in a package is 500. Items transported as Excepted Packages in accordance with JSP 800 Vol. 4b. Overall package limit is an activity of 1 GBq. All smoke detectors are to be marked externally with a radiation trefoil or the word radioactive and details of the radionuclide and activity they contain. See Leaflet 11 Preferred route is to return to the manufacturer via stores as appropriate. In some cases it may be permissible to dispose of small numbers of detectors as refuse RPA to be consulted for advice Leaflet 12 also refers. Keep records of disposal for 2 years. Preferred route is return to manufacturer via stores as above. Disposal as refuse is not permitted. Advice on other options for disposal is to be sought from the RPA Leaflet 12 also refers.

Accounting (both categories)

Leak testing ( 40 kBq) Leak testing (> 40 kBq 2.2 MBq)


(but see comment)

Leak testing (Type F31, F35 and F36 only)

Personal dosimetry (both categories) Reporting procedures (both categories) Transport ( 40 kBq)

(but see comment)

6 14 JSP 800 Vol. 4a & 4b JSP 800 Vol. 4b

Transport (> 40 kBq 2.2 MBq) Marking (both categories) Sale/transfer Disposal of redundant items ( 40 kBq)

4 11

12

Disposal of redundant items (> 40 kBq 2.2 MBq)

12

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 18 ANNEX A SUMMARY RADIATION RISK ASSESSMENT FOR LOWER ACTIVITY SMOKE DETECTOR

Example - Smoke Detector Containing up to 40 kBq Americium-241 Within the smoke detector there is a chamber. Across this chamber a low-level electrical voltage is applied to collect ions produced as a result of the alpha particles emitted from the Am241. When smoke enters the space between the electrodes of the chamber, the current drops in the smoke detector, setting off an audible alarm.

Example shown is the Tyco (Thorn) MF 501 Example shown contains 33.3 kBq of Am-241

External view

Internal view

Use Radionuclide Ionising radiation Half life

Early detection of smoke. Americium 241 (Am-241) Alpha/Gamma ( 5.44 MeV, 5.46 MeV 59.5 keV, 26.3 keV, 13.9 keV) 433 years. Smoke detectors containing up to 40 kBq of Americium-241 fall under the Radioactive Substances (Smoke Detectors) Exemption Order 1980 and are also the subject of an HSE Type Approval. This confers exemptions on notification of environment agencies and HSE for up to 500 of these items. Exemptions may only apply if specified conditions for use, storage and disposal are met (see below) the RPA is to be contacted if further information is required. Am-241 emits low energy gamma radiation. The hourly dose rate from external radiation from this type of detector is extremely low (<0.01 Sv h-1 at 30 cm) and is not considered significant. Am-241 emits alpha particles which are completely absorbed before they escape the smoke detector head. Hence for an intact unit, there is no internal hazard. The likelihood of accidental damage to this component to such a degree that Am-241 escapes is low. A more severe accident, for example, crushing or fire, could possibly result in the release of some particulate Am-241. In this case, a body intake by ingestion and inhalation could give rise to an internal dose of no more than about 10 Sv. (DRPS Report 167/2004 dated 02/07/04). Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety. Leaflet 16 gives guidance on the content of local orders. Latex or surgical gloves are to be worn for personnel routinely handling large quantities of smoke detector heads (SDH). It is recommended that hands be washed after handling SDHs. Annually as well as during routine maintenance. Check is to be made for signs of damage. No routine leak test is required.

Classification

External radiation hazard

Internal radiation hazard

Local orders Control measures during use Inspection Leak test

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Example - Smoke Detector Containing up to 40 kBq Americium-241 This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. Uninstalled SDHs must be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Although exempt from formal RSA 93 notification to the environment agencies, this item is to be included in the Annual Holdings Return to Dstl Leaflet 9 refers. If uninstalled, this item is to be stored in a dedicated area for radioactive materials see Leaflet 9. The equipment is to have the recognised radioactive trefoil on it. The storage/installed area is also to have a sign showing radioactive material within i.e. a trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard in appropriate languages: Smoke detectors contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged. If a breakage occurs the immediate area is to be cordoned off. The broken source fragments item can be cleaned up using a breakage kit Leaflet 40 refers. Broken fragments are disposed of as directed by the RPA. Personnel exposed to leaking Am-241 are to report to the RPS or WPS. The loss of any smoke detectors is to be reported in accordance with procedures described in Leaflet 14. These items can be transported as an exempt package, provided the total package does not exceed 500 of these items. Units and establishments are to return this item, unbroken to the Stores Organisation.

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans breakage/loss

Transport Disposal

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LEAFLET 18 ANNEX B SUMMARY RADIATION RISK ASSESSMENT FOR HIGHER ACTIVITY SMOKE DETECTOR

Example Smoke Detector Containing 2.2 MBq Americium-241 Within the smoke detector there is a chamber. Across this chamber a lowlevel electrical voltage is applied to collect ions produced as a result of the alpha particles emitted from the Am-241. When smoke enters the space between the electrodes of the chamber, the current drops in the smoke detector, setting off an audible alarm. These detectors are mostly found in high voltage cabinets or weapon magazines.

Example shown is the Minerva F36 Example shown contains 2.2 MBq of Am-241

Marking

Use Radionuclide Ionising radiation Half life

Early detection of smoke. Americium 241 (Am-241). Alpha/Gamma ( 5.44 MeV, 5.46 MeV 59.5 keV, 26.3 keV, 13.9 keV). 433 years. Smoke detectors of this type (containing more than 40 kBq but less than 4 MBq of Am-241) fall under the Radioactive Substances (Smoke Detectors) Exemption Order 1980 and are also the subject of an HSE Type Approval but only when the detectors are installed. This confers exemptions on notification of environment agencies and HSE for these items when installed. Exemptions may only apply if specified conditions for use and disposal are met (see below). Units or establishments storing these items are not exempt from the notification procedures detailed in Leaflet 3. Your RPA should be contacted if further information is required. Am-241 emits low energy gamma radiation. External radiation from a 2.2 MBq smoke detector is measurable in close proximity to the detector head (~0.3 Sv h-1 at 30 cm). Am-241 emits alpha particles which are completely absorbed before they escape the smoke detector head. Hence for an intact unit, there is no internal hazard. The likelihood of accidental damage to this component to such a degree that Am-241 escapes is low. A more severe accident, for example, crushing or fire, could possibly result in the release of some particulate Am-241. In this case, a bodily intake by ingestion and inhalation could give rise to an internal dose of about 400 Sv. (DRPS Report 6/2004 dated 02/03/04). Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety. Leaflet 16 gives guidance on the content of local orders. Latex or surgical gloves are to be worn for personnel routinely handling this type of smoke detector heads (SDH). It is recommended that hands be washed after handling SDHs. Annually as well as during routine maintenance. Check is to be made for signs of damage.

Classification

External radiation hazard

Internal radiation hazard

Local orders Control measures during use Inspection

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Example Smoke Detector Containing 2.2 MBq Americium-241 Only required where advised by RPA. Tests have shown that leakage has been observed in some unit types in which case, leakage tests are advised for units of the same type. Currently, on this basis, the F31, F35 and F36 require a leak test to be carried out every 24 months once they are unpacked and put into service. These items are to be accounted for on a Radioactive Source List - Leaflet 9 refers. Uninstalled SDHs must be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Although installed items of this type are exempt from notification to the environment agencies, this item is to be included in the Annual Holdings Return to Dstl Leaflet 9 refers. If uninstalled, this item is to be stored in a dedicated area for radioactive materials in accordance with Leaflet 9. The equipment is to have the recognised radioactive trefoil on it. The storage/installed area is also to have a sign showing radioactive material within. i.e. a trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard in appropriate languages: Smoke detectors contain radioactive material. Low external radiation hazard from intact item. Radioactive contamination hazard if item damaged. Note, storage areas may require to be designated as controlled or supervised areas in accordance with RPA advice (see Leaflet 4). If a breakage occurs the area is to be cordoned off. Wearing a FFP3 rated mask, the broken source fragments item can be cleaned up using a breakage kit Leaflet 40 refers. Broken fragments are disposed of as directed by the RPA. Personnel exposed to leaking Am-241 are to report to the RPS or WPS. The loss of any smoke detectors is to be reported in accordance with procedures in Leaflet 14. These items can be transported as an excepted package, provided the total package does not exceed an activity of 1GBq and the surface dose rate does not exceed 5 Sv h-1. Units and establishments are to return this item, unbroken to the Stores Organisation.

Leak tests

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans breakage/loss

Transport Disposal

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LEAFLET 19 GASEOUS TRITIUM LIGHT SOURCES (GTLSs) AND GASEOUS TRITIUM LIGHT DEVICES (GTLDs) CONTENTS Para 1 4 5 6 7 8 9 10 11 16 18 20 21 22 25 Table 1 2 Figure 1 2 Annex A B C D SA80 blade sight assembly example of a summary radiation risk assessment SUSAT sight light assembly example of a summary radiation risk assessment DAS control panel example of a summary radiation risk assessment Specific guidance for GTLD repair workshops Scope What is a GTLS? Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Classification of GTLSs or GTLDs Markings of GTLSs or GTLDs Tritium monitoring and detection Risk assessments for GTLSs and GTLDs Handling of GTLSs and GTLDs Breakage of GTLSs and GTLDs Legal and MOD mandatory requirements Page Hazards associated with GTLSs and GTLDs..................................................................................4 Legal and MOD mandatory requirements for GTLSs and GTLDs ..................................................5 Page Tritium marking................................................................................................................................4 Standard radiation trefoil. Colour of symbol: black on yellow or white background.......................4

SCOPE 1 A gaseous tritium light source (GTLS) is a sealed glass container filled with radioactive tritium gas. GTLSs may be referred to as betalights, trilux or nuclear lamps and are used to provide illumination. 2 A gaseous tritium light device (GTLD) is an equipment containing one or more GTLS. There are many types of GTLDs in service use, including prismatic compasses, defile markers and SUSAT weapon sights. 3 This leaflet describes the radiological requirements for keeping, using and disposing of such equipments. Summaries of the radiation risk and regulatory requirements for examples of GTLSs and GTLDs are provided at the Annexes to this leaflet. Summary risk assessments for a comprehensive range of GTLSs and GTLDs are available from the RPA who may also be consulted for further advice regarding the hazards and requirements for these items.

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WHAT IS A GTLS? 4 A GTLS is a glass capsule coated internally with a phosphor and filled with tritium gas, a radioactive isotope of hydrogen. Low energy beta particles, which are emitted during the radioactive decay of tritium, react with the phosphor to produce a continuous emission of light. If a capsule is broken, the escape of tritium could result in a health risk, particularly if the breakage occurs in a confined space. When a GTLS is broken, provided that the area is reasonably well ventilated, the tritium gas will disperse relatively quickly, however some activity will remain bonded to the phosphor and shards. The sources also contain small quantities of tritiated water, which also tend to remain associated with the phosphor and fragments of glass for a considerable time following breakage. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 5 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Radioactive Substances (Gaseous Tritium Light Devices) Exemption Order 1985 (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 6 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 7 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping, using and disposing of GTLSs or GTLDs containing radioactive material as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit. Radiation Protection Supervisor (RPS)

Radiation Protection Supervisor (RPS) 8 Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Further information on the requirements for appointment of an RPS is given in Table 2. Leaflet 19 Page 2 Jan 2007

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Workplace Supervisor (WPS) (Radioactive Materials) 9 In units holding GTLSs or GTLDs but where it is unnecessary to appoint an RPS, a WPS (Radioactive Materials) is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Employees 10 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that these items are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager. CLASSIFICATION OF GTLSs OR GTLDs 11 In accordance with the Radioactive Substances (Gaseous Tritium Light Devices) Exemption Order 1985, certain GTLSs or GTLDs may be classified as Class A, Class B or Class C articles. The classification dictates the conditions under which holdings of such articles, and the arrangements for accumulation and disposal of such articles as waste, are exempt from specific requirements of the RSA93. 12 A GTLS or GTLD, the activity of which does not exceed 20 GBq, is a Class A article.

13 A GTLS or GTLD is a class B article where each GTLS comprising the article has an activity not exceeding 80 GBq and the total activity of the article does not exceed 1 TBq. 14 A GTLS or GTLD is a Class C article when installed, or awaiting installation, in: A vessel or aircraft; or A vehicle or equipment used or intended for use by the armed forces of the Crown.

15 The majority of GTLSs and GTLDs held at MOD establishments are Class A articles, exempt from registration from Section 1 of the Radioactive Substances Act 1993 provided the total activity of all such articles on the premises does not exceed 5 TBq. Where an establishment holds GTLSs and GTLDs which are not Class A articles, RPA advice is to be sought regarding the classification adopted and the requirements for registration under RSA93. Additionally, RPA advice is to be sought prior to disposal of any GTLS or GTLD, whether of Class A, B or C.

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MARKINGS OF GTLSs OR GTLDs 16 The following markings may be found on GTLSs or GTLDs.

T
Figure 1 Tritium marking. Figure 2 Standard radiation trefoil radioactive valves. Colour of symbol: black on yellow or white background.

17 Where possible GTLSs and GTLDs in storage are to be kept in their original containers or packaging and are to be marked with the following information: NATO stock number. Number of GTLSs/GTLDs in package Total activity of GTLSs/GTLDs in package. The word radioactive and the trefoil symbol.

HAZARDS Table 1 Hazards associated with GTLSs and GTLDs Radiation type Alpha Low energy beta radiation is emitted from GTLSs and GTLDs, but the energy of the beta is insufficient to penetrate beyond the casing. Tritium can present a hazard internal to the body if taken in by ingestion, inhalation, absorption through the skin or through cuts in the skin. Of the two forms of tritium, tritiated water presents the far greater health hazard due to its more significant ability to enter the body both by inhalation and by rapid absorption through the skin. Low levels of Bremsstrahlung radiation (X-rays) are emitted from valves containing beta emitters. Emitted Comments

Direct Beta

Bremsstrahlung Gamma X-rays Neutrons

TRITIUM MONITORING AND DETECTION 18 Monitoring the radiation dose rate from a GTLS or GTLD is very difficult due to the very low energy beta radiation emitted and will therefore record a level significantly less than 1 Sv h-1. Similarly, it is very difficult to detect tritium contamination without the use of specialised monitoring instrumentation. Tritium surveys are therefore generally carried out by indirect means involving the taking and analysis of smears of the surfaces to be monitored.

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19 It is also difficult to monitor for tritium in the air and thus assess the internal hazard following a release of tritium into the atmosphere. Therefore, for workers who have potentially been exposed to tritium, it may be necessary to carry out tritium-in-urine monitoring to assess the amount of tritium taken into the body and the resulting radiation dose. RISK ASSESSMENTS FOR GTLSs AND GTLDs 20 The number of GTLSs and GTLDs in service within MOD is too large to list in this publication. Similarly, it is not possible to include risk data for all items. However, summary risk assessments for an example are reproduced at Annexes A to C of this leaflet. These summary risk assessments may be used to scope the hazard and control requirements for a wider range of GTLSs and GTLDs and may be used, where appropriate, as input to the risk assessments and local orders required in accordance with Leaflets 2 and 16 respectively. Specific risk assessments would be required where large quantities (> 5000 GBq) of GTLSs and GTLDs are stored. Advice on further detail and assessments may be sought from the RPA. HANDLING OF GTLSs AND GTLDs 21 No protective clothing is required for the routine handling of GTLSs and GTLDs. Specific advice for those involved in repairing GTLSs or GTLDs is given in Annex D. BREAKAGE OF GTLSs AND GTLDs 22 All reasonable practical steps are to be taken to prevent any GTLS or GTLD being damaged, lost or stolen. Wherever there are reasonable grounds for believing that such an item is damaged, lost or stolen the incident is to be reported in accordance with the procedures detailed in Leaflet 14 and further actions, as detailed below, should be followed. 23 A broken GTLS or GTLD is potentially hazardous because loose radioactive material can enter the body by a variety of means including inhalation of gaseous material (if present), inhalation of radioactive dust and absorption through cuts or scratches in the skin. 24 Because GTLSs and GTLDs contain gaseous tritium (H-3), it is important that the room or compartment where the breakage has occurred is vacated for 1 hour to ventilate before dealing with the broken fragments wearing suitable personal protective equipment. Detailed guidance on the procedure for dealing with a broken GTLS or GTLD can be found in Leaflet 40. LEGAL AND MOD MANDATORY REQUIREMENTS 25 Table 2 below summarises the legal and MOD mandatory requirements for GTLSs and GTLDs. In cases of doubt, the RPA is to be consulted for advice. Table 2 Legal and MOD mandatory requirements for GTLSs and GTLDs Requirement HSE authorisation HSE notification The HSE is to be notified in accordance with Leaflet 3, if there are any GTLSs or GTLDs on the site having a cumulative activity of greater than 1GBq. Holdings of any number of Class C articles are exempt from notification to the Environment Agency under the Radioactive Substances (Gaseous Tritium Light Devices) Exemption Order 1985. 3 Applicable Comments Related leaflet*

EA notification**

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Requirement

Applicable

Comments See summaries at annexes to this leaflet. Further specific risk assessments or prior risk assessments may be required, especially where large quantities (> 5000 GBq) are stored. (see Leaflet 2). Observe manufacturers instruction and guidance. Also, see Leaflet 4. Not required except when dealing with a breakage (see Leaflet 40). For very large quantities (> 5000 GBq) of GTLSs or GTLDs it may be appropriate to ventilate the storage areas, depending on the outcome of the risk assessment. These ventilation systems are to be maintained on a regular basis in accordance with manufacturers instructions. See Leaflet 40 breakage and fire The presence of GTLSs and GTLDs in equipment does not usually, lead to a requirement for area designation. Stores holding quantities of electronic GTLSs or GTLDs may require designation if they meet the criteria detailed in Leaflet 4. Note: small stores which people cannot enter (e.g. drawers or cupboards) do not require designation but must be appropriately marked. Indirect monitoring may be required in areas where maintenance or repair on GTLSs or GTLDs is carried out. Information and instruction only. See Leaflet 16 for guidance. RPS not required except for storage areas required to be designated as controlled or supervised. Where an RPS is not required, a WPS needs to be appointed in accordance with Leaflet 15. In a segregated secure store/container/cupboard marked with radiation trefoil warning sign and stored in accordance with Leaflet 9. May require ventilation for large quantities (> 5000 GBq) depending on outcome of risk assessment. GTLSs and GTLDs are not to be removed from their cartons until required. Recorded on a source list (retained for 2 years) and mustered in accordance with Leaflet 9. Recorded on Dstl Annual Holdings Return, copy retained for 1 year. Leak testing is not appropriate for GTLSs or GTLDs.

Related leaflet*

Risk assessment

Restriction of exposure PPE

Maintenance of radiation engineering controls Contingency plans

(but see comment)

40

Designated areas

(but see comment)

Monitoring Training for users Local orders

(but see comment)

15 16

Appointed person

15

Storage

Accounting

Leak testing Personal dosimetry

Leaflet 19 Page 6

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JSP 392

Table 2 Legal and MOD mandatory requirements for GTLSs and GTLDs (continued) Requirement Applicable Comments All losses and certain other incidents require to be reported to MOD authorities. Reporting to external regulatory authorities may also be required. See Leaflet 14 for details. Items and bulk quantities may generally be transported as Excepted Packages provided that the activity per GTLS does not exceed 800 GBq and the total activity per package does not exceed 8000 GBq as detailed in JSP 800 Vol. 4b (road, rail, sea) or JSP 800 Vol. 4a (air). All GTLSs, GTLDs, equipment stores and containers are to be marked appropriately in accordance with this leaflet. See Leaflet 11 Unbroken GTLSs and GTLDs should be returned via stores. Broken GTLSs should be placed in a suitable container (e.g. a paint tin) following the approved cleanup procedure. In the UK the disposal of the tin, GTLS fragments, cloths, gloves etc, is into a normal refuse route, provided the activity of the item is not greater than 20 GBq and not more than 1 item is disposed of in any 0.1m3 of nonradioactive waste. The disposal container should have all markings that indicate the presence of radioactive material removed. Disposal must not be to a tip on the establishment site. Overseas, broken GTLSs are to be returned via stores. Where surplus MOD stocks are sold at auction, it is particularly important that sales items are checked for the presence of radioactive materials, including GTLSs. Further advice may be sought from the RPA as necessary. Records following a stores return are to be kept for 2 years and following a disposal indefinitely. Leaflets 11 and 12 also refer. *JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI). Related leaflet*

Reporting procedures

14

Transport

JSP 800 Vol. 4a & 4b

Marking Sale/transfer

11

Disposal of redundant items

12

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LEAFLET 19 ANNEX A

SA80 BLADE SIGHT ASSEMBLY EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT SA80 Blade Sight Assembly B4 The GTLS aperture is about the size of a pinhead seen at the rear of the blade near the top. The whole sight containing the Blade 1005-99967-0508 is 1005-99-9670506 * Note Cadet version 100599-967-0507 does not contain GTLS.

Description

Beta light

Equipment carries no manufacturer T or trefoil warning symbol Use Supplier NSN IPT Details Radionuclide Ionising Radiation Half Life Original Activity

Sight illumination (Gaseous Tritium Light Source). British Aerospace. 1005-99-967-0508. Combat Support. Tritium (H-3) Beta (0.019 MeV). 12.3 years. 259 MBq. This component is Class C under the GTLD Exemption Order 1985 SI 1047 Installed/awaiting installation in armed forces vessels, aircraft, vehicles or equipment. This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. Your RPA is to be contacted if further information is required. Tritium is a form of Hydrogen and in GTLSs and GTLDs in the form of gas. If destroyed in a fire, the tritium is rapidly converted to tritiated water. The escape of tritium could result in a health risk particularly in a confined space. Of the two forms of tritium, tritiated water presents the greater hazard due to its ability to enter the body both by inhalation and rapid absorption through the skin. Radiation levels on contact <0.1 Sv h-1. All components with tritium in them leak. The degree of risk from tritium leaking out of this component is negligible. The likelihood of accidental damage to this component to such a degree that tritium escapes is low. A more severe accident, for example, crushing, could possibly result in the release of tritium. Internal dose will be dependent on the duration of exposure and concentration of tritium. An adult in a 30m3 room breathing an atmosphere with 259 MBq of tritium dispersed in it for an hour could receive an internal dose of around 7 Sv. (DRPS Report 289/2004 dated 10/12/04).

Classification

Hazard

Risk Assessment

Jan 2007

Leaflet 19 Annex A Page 1

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Radiation Safety Handbook

Local orders Control measures during use Inspection Leak Testing

Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Although exempt from formal RSA 93 notification to the relevant environment agencies, this item is to be included in the Annual Holdings Return to Dstl Leaflet 3 refers. If uninstalled, this item is to be stored in a dedicated area for radioactive materials see Leaflet 9. The equipment is to display the recognised radioactive valve warning label on it. The storage/installed area is also to have a sign showing radioactive material within i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard in appropriate languages Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item is damaged. If a breakage occurs the area is to be evacuated and ventilated. Tritium gas will disperse relatively quickly; however some may remain bonded to the component. Once a suitable amount of ventilation time (one hour) has passed, the broken item can be cleaned up using a breakage kit, see Leaflet 40. See below for disposal; if in doubt, seek RPA advice. Reporting of loss and certain other incidents is to be carried out in accordance with procedures described in Leaflet 14. This item may be transported within an excepted package provided the total package activity does not exceed 8000GBq. Units and Establishments are to return this item, unbroken, through the stores organisation. Broken items are to be disposed of in accordance with Leaflets 12 and 40.

Accounting

Radioactive Substances Act 1993

Storage and Labelling

Contingency Plans Spills/ Loss

Transport Disposal

Leaflet 19 Annex A Page 2

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JSP 392

LEAFLET 19 ANNEX B SUSAT SIGHT LIGHT ASSEMBLY EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

SUSAT Sight Light Assembly B4 Description GTLS Equipment marked with trefoil The GTLS light assembly 1240-99-967-0477 is a rod, which is screwed into the Susat sight 1240-99-967-0947 for internal illumination.

SUSAT Sight Use Supplier NSN IPT Details Radionuclide Ionising Radiation Half Life Original Activity

Sight internal illumination (Gaseous Tritium Light Device). RO Notts. 1240-99-967-0477 Combat Support. Tritium (H-3) Beta (0.019 MeV) 12.3 years. 4.07 GBq. This component is Class C under the GTLD Exemption Order 1985 SI 1047 Installed/awaiting installation in armed forces vessels, aircraft, vehicles or equipment. This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. Your RPA is to be contacted if further information is required. Tritium is a form of Hydrogen and in GTLSs and GTLDs, in the form of gas. If destroyed in a fire, the tritium is rapidly converted to tritiated water a more hazardous form of tritium. The escape of tritium will result in an internal radiation dose if taken into the body by inhalation, ingestion or absorption through the skin. Of the two forms of tritium, tritiated water presents the greater hazard due to its ability to enter the body both by inhalation and rapid absorption through the skin. Radiation levels on contact <0.1 Sv h-1. All components with tritium in them leak. The degree of risk from tritium leaking out of this component is negligible. The likelihood of accidental damage to this component to such a degree that tritium escapes is low. A more severe accident, for example, crushing, could possibly result in the release of tritium. Internal dose will be dependent on the duration of exposure and concentration of tritium. An adult in a 30m3 room breathing an atmosphere with 4.0GBq of tritium dispersed in it for an hour could receive an internal dose of around 100 Sv. (DRPS Report 289/2004 dated 10/12/04).

Classification

Hazard

Risk Assessment

Jan 2007

Leaflet 19 Annex B Page 1

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Radiation Safety Handbook

Local Orders Control measures during use Inspection Leak Testing

Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Item not to be carried on the person. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Although exempt from formal RSA 93 notification to the relevant environment agencies, this item is to be included in the Annual Holdings Return to Dstl Leaflet 3 refers. If uninstalled, this item is to be stored in a dedicated area for radioactive materials see Leaflet 9. The equipment is to display the recognised radioactive valve warning label on it. The storage/installed area is also to have a sign showing radioactive material within, i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard in appropriate languages Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item is damaged. If a breakage occurs the area is to be evacuated and ventilated. Tritium gas will disperse relatively quickly; however some may remain bonded to the component. Once a suitable amount of ventilation time (one hour) has passed, the broken item can be cleaned up using a breakage kit, see Leaflet 40. RPA advice is to be sought regarding disposal of the fragments. Reporting of loss and certain other incidents is to be carried out in accordance with procedures described in Leaflet 14. This item may be transported within an excepted package provided the total package activity does not exceed 8000GBq. Units and Establishments are to return this item, unbroken, through the Stores Organisation. Broken items are to be disposed of in accordance with Leaflets 12 and 40. Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers).

Accounting

Radioactive Substances Act 1993

Storage and Labelling

Contingency Plans Breakage/Loss/ Incident

Transport Disposal Local Orders

Leaflet 19 Annex B Page 2

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JSP 392

LEAFLET 19 ANNEX C DAS CONTROL PANEL EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

DAS Control Panel Defensive Aid Suits (Type 42 Destroyers) Control Panels, one either side of the ship. In the centre of the control panel is a white display plate, manufactured with 7 GTLSs, encapsulated in the plate where the legends are located.

Description Mode switch illumination

Use Supplier NSN IPT Details Radionuclide Ionising Radiation Half Life Original Activity

Panel illumination (Gaseous Tritium Light Device). SRB Technologies (UK) Ltd. 1220-99-851-1673 Panel Control (Port) / 1220-99-149-7317 Panel Control (Starboard). Above Water Systems. Tritium (H-3) Beta (0.019 MeV). 12.3 years. 259.74 GBq. This component is Class C under the GTLD Exemption Order 1985 SI 1047 Installed/awaiting installation in armed forces vessels, aircraft, vehicles or equipment. This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. Your RPA is to be contacted if further information is required. Tritium is a form of Hydrogen and in GTLSs and GTLDs, in the form of gas. If destroyed in a fire, the tritium is rapidly converted to tritiated water. The escape of tritium could result in a health risk particularly in a confined space. Of the two forms of tritium, tritiated water presents the greater hazard due to its ability to enter the body both by inhalation and rapid absorption through the skin. Radiation levels on contact <0.1 Sv h-1.

Classification

Hazard

Jan 2007

Leaflet 19 Annex C Page 1

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Radiation Safety Handbook

Risk Assessment

Local Orders Control measures during use Inspection Leak Testing

All components with tritium in them leak. The degree of risk from tritium leaking out of this component is negligible. The likelihood of accidental damage to this component to such a degree that tritium escapes is low. A more severe accident, for example, crushing, could possibly result in the release of tritium. Internal dose will be dependent on the duration of exposure and concentration of tritium. An adult in a 30m3 room breathing an atmosphere with 260GBq of tritium dispersed in it for an hour could receive an internal dose of around 7mSv, which would trigger a MOD investigation. The whole panel is fitted to the ship superstructure and no spares are carried. Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Item not to be carried on the person. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Although exempt from formal RSA 93 notification to the relevant environment agencies, this item is to be included in the Annual Holdings Return to Dstl Leaflet 3 refers. If uninstalled, this item is to be stored in a dedicated area for radioactive materials see Leaflet 9. The equipment is to display the recognised radioactive valve warning label on it. The storage/installed area is also to have a sign showing radioactive material within i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard in appropriate languages Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item is damaged. If a breakage occurs the area is to be evacuated and ventilated. Tritium gas will disperse relatively quickly; however some may remain bonded to the component. Once a suitable amount of ventilation time (one hour) has passed, the broken item can be cleaned up using a breakage kit, see Leaflet 40. RPA advice is to be sought regarding disposal of the fragments. Reporting of loss and certain other incidents is to be carried out in accordance with procedures described in Leaflet 14. This item may be transported within an excepted package provided the total package activity does not exceed 8000GBq. Units and Establishments are to return this item, unbroken, through the Stores Organisation. Broken items are to be disposed of in accordance with Leaflets 12 and 40. Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers).

Accounting

Radioactive Substances Act 1993

Storage and Labelling

Contingency Plans Breakage/Loss/ Incident

Transport Disposal Local Orders

Leaflet 19 Annex C Page 2

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JSP 392

LEAFLET 19 ANNEX D SPECIFIC GUIDANCE FOR GTLD REPAIR WORKSHOPS

1 In workshops where GTLDs are repaired, the number of radioactive items held in the work area is to be kept to a workable minimum. Equipments held in temporary storage within the workshop pending completion of repair are to be stored on fire proof racking marked with a radioactive warning trefoil and a suitable legend (e.g. RADIOACTIVE ITEMS CONTAINING TRITIUM). The number of spare GTLSs held within the room is to be kept to the minimum required for the work in hand, stocks being replenished from the main store on a daily basis. Where practicable, all items containing a GTLS are to display a radiation hazard trefoil, the symbol "T" or T and the activity of the GTLS. 2 Doors providing access to the building and to the workshop area are to display a radiation warning trefoil which are available through the appropriate service channels or obtained locally and should be in relevant foreign languages. 3 The fire officer is to be kept fully informed of the quantity and locations of all radioactive materials within the workshop. These locations are to be described in local radiation safety rules, preferably as a diagram. 4 In order to prevent the accumulation of tritium contamination, areas where equipment containing GTLSs/GTLDs are repaired/maintained or stored are to be cleaned at regular intervals. Bench tops are to be of a non-permeable material (e.g. Formica) having a post formed edge and sealed joints. Work surfaces are to be wiped down with damp tissues at the end of each work period. The tissues may be disposed of with domestic wastes. Once per month bench tops are to be thoroughly cleaned using a detergent solution. 5 Large stores or workshops which occasionally have to deal with broken GTLSs, are to seek specific advice from their RPA in relation to the procedures and control measure that they need to adopt with regard to monitoring work areas for tritium. A GTLS breakage kit (put together locally), with instructions for its use (Leaflet 40) is to be available in each work area. These instructions are to be included in local radiation safety orders.

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LEAFLET 20 INSTRUMENTS CONTAINING Ni-63 CONTENTS Para

1 2 3 4 5 6 7 Table 1 2 Annex A B C D

Scope Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Page Hazard .............................................................................................................................................3 Legal and MOD mandatory requirements .......................................................................................3

Summary radiation risks and regulatory requirements for CAM Summary radiation risks and regulatory requirements for ColProCAM Summary radiation risks and regulatory requirements for Mk10NHA Summary radiation risks and regulatory requirements for man portable chemical agent detector

SCOPE 1 This leaflet covers instruments containing Nickel-63 (Ni-63). The following information describes the requirements required for keeping, using and disposing of such equipment. Summaries of the radiation risks and regulatory requirements for common MOD equipment containing Ni-63 are included in the annexes of this leaflet. This is not a comprehensive catalogue of all equipment containing Ni-63. If equipment used by the unit or establishment is not included contact the RPA for further information. The summaries of the radiation risks satisfy the requirement for the radiological aspects of a risk assessment for normal operation and use and form the basis of information for input into the local orders. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

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Leaflet 20 Page 1

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DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping, using and disposing of instruments containing Ni-63 as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 5 An RPS must be appointed where an establishment has an area designated as controlled or supervised. Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Workplace Supervisor (WPS) (Radioactive Materials) 6 In units holding instruments containing Ni-63 but where it is unnecessary to appoint an RPS, a WPS (Radioactive Materials) is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Employees 7 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that these items are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager.

Leaflet 20 Page 2

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HAZARD Table 1 Hazard Radiation type Alpha Low energy that will not penetrate the instrument casing. Undamaged equipment does not present an external hazard during routine use. A leaking Ni-63 source will cause contamination that could lead to an internal hazard if Ni-63 enters the human body. Bremsstrahlung X-rays are absorbed by the casing and no significant radiation dose rates will be measured on the outside surface of the instrument Emitted Comments

Direct Beta Bremsstrahlung Gamma X-rays Neutrons

LEGAL AND MOD MANDATORY REQUIREMENTS Table 2 Legal and MOD mandatory requirements Requirement HSE authorisation HSE notification EA notification** Risk assessment Restriction of exposure PPE Maintenance of radiation engineering controls Contingency plans Designated areas Monitoring Training for users Local orders Appointed person Storage Keep a copy indefinitely. HSE will not provide acknowledgement of this. Only for GID-3 equipment. See Annexes; further specific risk assessments or prior risk assessments may be required. Comply with local orders see also Leaflet 4 and 16. 3 3 2 4, 16 Applic able Comments Related leaflet*

See Leaflet 40.

40

Information and Instruction only. See Leaflet 16 for guidance. WPS required; RPS not normally required. In a segregated labelled secure container/ cupboard.

15 16 3 9

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Table 3 Legal and MOD mandatory requirements (continued) Requirement Applic able Comments Regularly mustered, recorded and retained for 2 years. Recorded on a source list and retained for 2 years. Recorded on Dstl Annual Holdings Return, copy retained for 1 year. The following equipment require leak testing: Chemical Agent monitor (Z8 6665-99-225-3521) MCAD (6665-99-809-0326) COLPRO CAM (6665-99-609-8640) GID-3 (6665-99-292-4509) Otto fuel monitor (Z8 1065-99-765-5786) SIC MK10 NHA (6665-99-037-0455, 6665-99-197-1894, 6665-99-917-1194) Leakmeter Model 61 (6625-99-654-0124) The procedure for leak testing may be detailed in the operator/maintenance manual and will vary for each piece of equipment. Contact the RPA for further information. Details of the leak test undertaken and the results obtained are to be retained for 2 years. See leaflet 14 for details Related leaflet*

Accounting

Leak testing

Personal dosimetry Reporting procedures

Transport

Transported as an Excepted package

Sale/Transfer Disposal *JSP 392, unless otherwise stated

See leaflet 11 Return to stores. Keep records for 2 years

14 10 JSP 800 Vol. 4a & Vol. 4b 11 12

**Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI)

Leaflet 20 Page 4

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JSP 392

LEAFLET 20 ANNEX A SUMMARY RADIATION RISKS AND REGULATORY REQUIREMENTS FOR CAM

Chemical Agent Monitor (CAM) A Nickel 63 electroplated radioactive source is used by the Sensor Cell enclosed within the instrument. NSN 6665-99-2253836 is the complete set with case. NSN 6665-99-0511388 is the old version and looks identical.

Description

Monitor

Marking

Use Supplier NSN IPT details Radionuclide Ionising radiation Half life Original activity

Chemical Agent Monitor Smiths Detection Ltd, Watford. UK 6665-99-225-3521 / 6665-99-225-4126 Combat Support Equipment (CSE) IPT Nickel-63 (Ni-63) Beta (67 keV maximum) 100.1 years 370 MBq This monitor contains a radioactive Class 2 source under the radioactive substances (Testing Instruments) Exemption Order 1985 of the Radioactive Substances Act 1993 (RSA 93). This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. The RPA is to be contacted if further information is required. The beta particles are of low energy and are absorbed by the casing. Bremsstrahlung X-rays are absorbed by the casing and no significant radiation dose rates will be measured on the outside surface of the instrument. Consequently, the undamaged equipment does not present an external radiation hazard during routine use. The likelihood of accidental damage to this instrument so that Ni-63 could escape is low. The following internal doses have been estimated using pessimistic assumptions: A severe incident, for example, crushing or significant internal corrosion, could possibly result in the spread of Ni-63 if the source were damaged. Maximum calculated internal dose from one damaged CAM is 83 Sv. There is no external radiation hazard presented by the open source. During an intense fire, the calculated maximum internal dose to a fire fighter is 1.8 Sv per CAM. The equipment does not present an external radiation hazard if undamaged. (Ref DRPS Report 219/2004).

Classification

Hazard

Risk assessment

Jan 2007

Leaflet 20 Annex A Page 1

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Radiation Safety Handbook

Chemical Agent Monitor (CAM) Local orders Control measures during use Inspection Details of the control measures taken from this leaflet are to be included in the local orders for the use of CAM. JSP 392, Leaflet 16 gives guidance to the content of local orders. No special precautions are required when handling this equipment. Annually as well as during routine maintenance. A check is to be made for signs of damage. There is no requirement to leak test a CAM whilst it is hermetically sealed and stored in Method II packaging. Otherwise testing is required for this component on a 24 month basis. See Table 2 of this leaflet and JSP392 Leaflet 9. This item is to be accounted for on a Radioactive Source List. JSP 392, Leaflet 9 refers. Mustering is to be at a frequency determined by the potential for loss. A muster and associated records are to be undertaken at least monthly. Any change of location or custodian is to be entered in the Source Movement Log. This item is subject to RSA 93 and is to be included in the Annual Holdings Return to Dstl. See Leaflet 3. This item is to be stored in a dedicated area for radioactive materials. JSP392 Leaflet 9 refers. The equipment is to display the recognised radioactive warning trefoil label. The storage area is also to display a sign indicating the presence of radioactive material within. i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard - Items containing radioactive material. No radiation hazard from intact equipment. Radioactive contamination hazard if equipment is damaged. If a breakage occurs the area is to be cordoned off. The broken source fragments item can be cleaned up using a breakage kit. Leaflet 40 refers. Broken fragments to be disposed of as directed by the RPA. If this item is involved in any unusual occurrence, follow Leaflet 14. Contact the RPA. This item is to be transported as an Excepted Package. JSP 800 Vol. 4a or Vol. 4b refers. Units and establishments are to return this item to the Stores Organisation.

Leak test

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans Spills Loss Transport Disposal

Leaflet 20 Annex A Page 2

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LEAFLET 20 ANNEX B SUMMARY RADIATION RISKS AND REGULATORY REQUIREMENTS FOR COLPROCAM

Collective Protection Chemical Agent Monitor (ColProCAM) A portable monitor which is used to detect nerve blister and blood agents. It contains one 555 MBq Nickel-63 source, electroplated onto stable Nickel and then onto a brass substrate. The dimensions of each of the sources are 7.5 mm x 7mm high.

Description

Monitor

Marking

Use Supplier NSN IPT details Radionuclide Ionising radiation Half life Original activity

Chemical Agent Monitor Bruker Daltonics GMBH, Industriestrasse 26, CH-8117 Fallenden, Switzerland 6665-99-609-8640 / 6665-99-584-1766 Combat Support Equipment (CSE) IPT Nickel-63 (Ni-63) Beta (67 keV maximum) 100.1 years 555 MBq This monitor contains a radioactive Class 2 source under the radioactive substances (Testing Instruments) Exemption Order 1985 of the Radioactive Substances Act 1993 (RSA 93). This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. The RPA is to be contacted if further information is required. The beta particles are of low energy and are absorbed by the casing. Bremsstrahlung X-rays are absorbed by the casing and no significant radiation dose rates will be measured on the outside surface of the instrument. Consequently, the undamaged equipment does not present an external radiation hazard during routine use. During sieve changes and leak testing Ni-63 contamination could lead to an internal hazard if the source is leaking and contamination from hands enters the body.

Classification

Hazard

Jan 2007

Leaflet 20 Annex B Page 1

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Radiation Safety Handbook

Collective Protection Chemical Agent Monitor (ColProCAM) The likelihood of accidental damage to this instrument so that Ni-63 could escape is low. The following internal doses have been estimated using pessimistic assumptions: A severe incident, for example, crushing or significant internal corrosion could possibly result in the spread of Ni-63 if the source were damaged. Maximum calculated internal dose from one damaged CAM is 83 Sv. There is no external radiation hazard presented by the open source. During an intense fire, the calculated maximum internal dose to a fire fighter is 1.8 Sv per CAM. The equipment does not present an external radiation hazard if undamaged. (Ref DRPS Report 247/2004). Details of the control measures taken from this leaflet are to be included in the local orders for the use of ColProCAM. JSP 392, Leaflet 16 gives guidance to the content of local orders. No special precautions are required when handling this equipment. Annually as well as during routine maintenance. A check is to be made for signs of damage. There is no requirement to leak test a CAM whilst it is hermetically sealed and stored in Method II packaging. Otherwise testing is required for this component on a 24 month basis. See Table 2 of this leaflet and JSP392 leaflet 9. This item is to be accounted for on a Radioactive Source List. JSP 392, Leaflet 9 refers. Mustering is to be at a frequency determined by the potential for loss. A muster and associated records are to be undertaken at least monthly. Any change of location or custodian is to be entered in the Source Movement Log. This item is subject to RSA93 and is to be included in the Annual Holdings Return to Dstl. JSP 392 Leaflet 3. This item is to be stored in a dedicated area for radioactive materials. JSP392 Leaflet 9 refers. The equipment is to display the recognised radioactive warning trefoil label. The storage area is also to display a sign indicating the presence of radioactive material within. i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard - Items containing radioactive material. No radiation hazard from intact equipment. Radioactive contamination hazard if equipment is damaged. If a breakage occurs the area is to be cordoned off. The broken source fragments item can be cleaned up using a breakage kit. Leaflet 40 refers. Broken fragments to be disposed of as directed by the RPA. If this item is involved in any unusual occurrence, follow Leaflet 14. Contact the RPA. This item is to be transported as an Excepted Package. JSP 800 Vol. 4a or Vol. 4b refers. Units and establishments are to return this item to the Stores Organisation.

Risk assessment

Local orders Control measures during use Inspection

Leak test

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans Spills Loss Transport Disposal

Leaflet 20 Annex B Page 2

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JSP 392

LEAFLET 20 ANNEX C SUMMARY RADIATION RISKS AND REGULATORY REQUIREMENTS FOR MK10NHA

Mk10NHA A Nickel-63 check source is found within the detector. It is held in place on plastic supports in the twin-drift tube sensor cell

Description

Mk 10NHA unit Use Supplier NSN IPT details Radionuclide Ionising radiation Half life Original activity

Ni-63 Source

Markings

Ship Installed Chemical Agent Detector check source Smith Detection Ltd, Watford. UK 6665-99-037-0455 or 6665-99-591-3031 Marine Environment Survivability & Habitability Chemical Biological Radiological Nuclear (MESH) IPT Nickel-63 (Ni-63) Beta ( 67 keV maximum) 100.1 years 370 MBq This detector contains a radioactive Class 2 source under the Radioactive Substances (Testing Instruments) Exemption Order 1985. This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. The RPA is to be contacted if further information is required. The beta particles are of low energy and are absorbed by the casing. Bremsstrahlung X-rays are absorbed by the casing and no significant radiation dose rates will be measured on the outside surface of the instrument. Consequently, the equipment does not present an external radiation hazard during routine use. The likelihood of accidental damage to this source when installed to such a degree that Ni-63 escape is low. A more severe accident, for example, crushing, could possibly result in the spread of Ni-63 if the source were damaged. A body intake by ingestion could give an internal dose of around 55 Sv (DRPS Report 30/2003 dated 25/02/03). Details of the control measures taken from this leaflet are to be included in the local orders for the use of this source. JSP 392, Leaflet 16 gives guidance to the content of local orders. During normal use no special precautions are required. During maintenance, undertaken only by recognised calibration facilities, it is recommended that the maintainer wear waterproof gloves when opening the detector. Annually as well as during routine maintenance. Checks are to be made for signs of damage.

Classification

Hazard

Risk assessment

Local orders

Control measures during use Inspection

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Mk10NHA Leak testing A leak test is required every year. The leak test certificate must be retained for at least 2 years. See Table 2 of this leaflet and JSP392 Leaflet 9. The source must be accounted for on a Radioactive Source List under the care of an appointed RPS or WPS (see Leaflet 9). All radioactive material is to be mustered at least monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. This item is subject to RSA93 and is to be included in the Annual Holdings Return to Dstl. JSP 392 Leaflet 3 refers. If not installed, this item is to be stored in a dedicated area for radioactive materials. JSP392 Leaflet 9 refers. The equipment is to have the recognised radioactive trefoil on it. The storage/installed area is also to have a sign showing radioactive material within. i.e. a trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard - Items containing nickel-63. No radiation hazard from intact equipment. Radioactive contamination hazard if equipment damaged. If a breakage occurs the area is to be cordoned off. The broken source fragments item can be cleaned up using a breakage kit. Leaflet 40 refers. Broken fragments are disposed of as directed by the RPA. If this item is involved in any unusual occurrence, follow JSP 392, Leaflet 14 refers. Contact the RPA This item may be transported as an excepted item. JSP 800 Vol. 4a or Vol. 4b refer. Units and establishments are to return this item to the Stores Organisation.

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans Spills Loss Transport Disposal

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LEAFLET 20 ANNEX D SUMMARY RADIATION RISKS AND REGULATORY REQUIREMENTS FOR MAN PORTABLE CHEMICAL AGENT DETECTOR

Man Portable Chemical Agent Detector A portable monitor which is used to detect nerve blister and blood agents. It contains two electrodeposited Nickel-63 sources of 370 and 185 MBq (Total 555 MBq). The Nickel-63 is electroplated onto stable nickel and then onto a brass substrate

Description

Use Supplier NSN IPT details Radionuclide Ionising radiation Half life Original activity

Chemical Agent Monitor Smiths Detection Ltd, Watford. UK 6665-99-809-0326 CSE IPT Ni-63 Beta (67 keV maximum) 100.1 years 555 MBq This monitor contains two radioactive Class 2 sources under the radioactive substances (Testing Instruments) Exemption Order 1985 of the Radioactive Substances Act 1993 (RSA 93). This has implications for the legal licensing of the holder of the source in terms of use, storage and disposal, which are briefly outlined below. Your RPA is to be contacted if further information is required. The beta particles are of low energy and are absorbed by the casing. Bremsstrahlung X-rays are absorbed by the casing and no significant radiation dose rates will be measured on the outside surface of the instrument. Consequently, the undamaged equipment does not present an external radiation hazard during routine use. The likelihood of accidental damage to this instrument so that Ni-63 could escape is low. The following internal doses have been estimated using pessimistic assumptions: A severe incident, for example, crushing or significant internal corrosion, could possibly result in the spread of Ni-63 if the source were damaged. Maximum calculated internal dose from one damaged MCAD is 80 Sv. A worst case exposure during sieve pack replacement is 0.8 Sv. During an intense fire, the calculated maximum internal dose to a fire fighter is 28 Sv per MCAD. The equipment does not present an external radiation hazard if undamaged. Details of the control measures taken from this leaflet are to be included in the local orders for the use of this source. JSP 392, Leaflet 16 gives guidance to the content of local orders.

Classification

Hazard

Risk assessment

Local orders

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Man Portable Chemical Agent Detector Control measures during use Inspection No special precautions are required when handling this equipment. Annually as well as during routine maintenance a check is to be made for signs of damage. A leak test is required every 24 months under the rain-cap assembly & exhaust port. A supplementary leak test of the air inlet manifold (to coincide with a sieve pack replacement) is also required. The leak test certificates must be retained for at least 2 years. See Table 2 of this leaflet and JSP392 Leaflet 9. The source must be accounted for on a Radioactive Source List under the care of an appointed RPS or WPS (see JSP392 Leaflet 9). All radioactive material is to be mustered at least monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. This item is subject to RSA 93 and is to be included in the Annual Holdings Return to Dstl. JSP 392 Leaflet 3 refers. This item is to be stored in a dedicated area for radioactive materials. JSP392 Leaflet 9 refers. The equipment is to display the recognised radioactive warning trefoil label. The storage area is also to display a sign indicating the presence of radioactive material within. i.e. a radiation warning trefoil including the contact name and telephone number of the RPS and stating the nature of the radiological hazard - Items containing radioactive material. No radiation hazard from intact equipment. Radioactive contamination hazard if equipment is damaged. If a breakage occurs the area is to be cordoned off. The broken source fragments item can be cleaned up using a breakage kit. Leaflet 40 refers. Broken fragments to be disposed of as directed by the RPA. If this item is involved in any unusual occurrence, follow JSP 392 leaflet 14. Contact the RPA. This item is to be transported as an Excepted Package. JSP 800 Vol. 4a or Vol. 4b refer. Units and establishments are to return this item to the Stores Organisation.

Leak test

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans Spills Loss Transport Disposal

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LEAFLET 21 INSTRUMENT CHECK SOURCES CONTENTS Para 1 5 6 7 8 9 10 11 14 15 Table 1 2 Annex A B SCOPE 1 This leaflet covers instrument check sources used to assess the functionality of radiation monitoring equipment. The following information describes the requirements required for keeping, using and disposing of such sources. 2 Summaries of the radiation risks are detailed in JSP 515 Hazardous Stores Information System. Where equipment used by a unit or establishment is not included in JSP 515 Equipment Sponsor and RPA are to be contacted for further information. The summaries of the radiation risks satisfy the requirement for the radiological aspects of a risk assessment for normal operation and use and form the basis of information for input into the local orders. 3 For advice on the suitability of instrument check sources for use with particular radiation monitoring instruments, the RPA is to be contacted. 4 The Marine Environment Survivability and Habitability (MESH) IPT coordinate the issue of instrument check sources. STATUTORY REQUIREMENTS 5 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Example summary radiation risk assessment Example of instrument pre-use functional testing record sheet Scope Statutory Requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees How to use a check source Hazard Legal and MOD mandatory requirements Page Hazard .............................................................................................................................................3 Legal and MOD mandatory requirements .......................................................................................4

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Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 6 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and to secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment against risks to their health or safety arising from the MOD work activities (e.g. the general public). This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 7 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping and using of instrument check sources containing radioactive material as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 8 Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Further information on the requirements for appointment of an RPS is given in Table 2. Workplace Supervisor (WPS) (Radioactive Materials) 9 In units holding instrument check sources but where it is unnecessary to appoint an RPS, a WPS (Radioactive Materials) is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Employees 10 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that these items are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager. HOW TO USE A CHECK SOURCE 11 A check source is to be used in the pre-use functional testing of any instrument to be used in a radiation or contamination survey. 12 A record of this check is required which is to include: 12.1 12.2 12.3 Battery power check. The source reference number used to function check the instrument. The instrument serial number.

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12.4 The expected response obtained when placing the detector at a fixed position (geometry) relative to the instrument. 12.5 12.6 12.7 The actual number of counts or dose rate observed in the same geometry, as above. The name and signature of the individual carrying out the test. Time and date test is undertaken.

13 If the actual reading recorded deviates by more than 30% from the expected reading the user is to inform the RSO prior to use of the instrument. Further advice may be sought from the RPA. HAZARD 14 Instrument check sources may contain a variety of radioactive materials. Most emit more than one type of radiation and may contain more than one radionuclide. Table 1 Hazard Radiation type Emitted Comments Undamaged sources should not present a significant external hazard. A leaking source will cause contamination that could lead to an internal hazard if the radioactive material enters the human body. Undamaged sources should not present a significant external hazard during routine use, as generally the activities are low. A leaking source will cause contamination that could lead to an internal hazard if the radioactive material enters the human body. Low energy x-rays may be emitted, but these do not normally present a significant external hazard during routine use. Undamaged sources should not present a significant external hazard during routine use, as the activity is low. A leaking source will cause contamination that could lead to an internal hazard if the radioactive material enters the human body. Some check sources produce X-rays. Undamaged sources should not present a significant external hazard. Undamaged sources should not present a significant external hazard during routine use, as the activity is low. A leaking source will cause contamination that could lead to an internal hazard if the radioactive material enters the human body.

Alpha

Direct Beta Bremsstrahlung

Gamma

X-rays

Neutrons

LEGAL AND MOD MANDATORY REQUIREMENTS 15 The information given below is generic, for specific information on any particular instrument check source refer to JSP 515

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Table 2 Legal and MOD mandatory requirements Requirement HSE authorisation HSE notification Keep a copy indefinitely. HSE may not provide acknowledgement of this. Exempt from Notification, under the Testing Instruments Exemption Order provided specified conditions are met. Specific activity limits apply; for the majority of instrument check sources the maximum activity is 4 MBq. For sources containing Ni-63 or Fe-55 contact the RPA for further guidance. See example at annex to this leaflet. Further specific risk assessments or prior risk assessments may be required (see Leaflet 2). Comply with local orders see Annexes of Leaflet 16. 3 Applicable Comments Related leaflet*

EA notification**

(but see comment)

Risk assessment Restriction of exposure PPE Maintenance of radiation engineering controls Contingency plans Designated areas Monitoring Training for users Local orders

2 4, 16

See Leaflet 40.

40

Appointed person

Storage

Accounting

Leak testing

(but see comment)

Information and instruction only. See Annexes of Leaflet 16 for guidance. RPS not normally required except for storage areas required to be designated as controlled or supervised. Where an RPS is not required, a WPS (Radioactive Materials) needs to be appointed in accordance with Leaflet 39. In a segregated secure store/container/cupboard marked with radiation trefoil warning sign and stored in accordance with Leaflet 9. Recorded on a source list (retained for 2 years) and mustered in accordance with Leaflet 9. Recorded on Dstl Annual Holdings Return, copy retained for 1 year. Many instrument check sources require leak testing; Leaflet 9, Annex C provides examples of such sources. The procedure for leak testing may be detailed in a separate work instruction or risk assessment and will vary for each source. Contact the RPA for details, if unsure. Details of the leak test undertaken and the results obtained are to be retained for 2 years.

15 16

Personal dosimetry

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Table 2 Legal and MOD mandatory requirements (continued) Requirement Applicable Comments All losses and certain other incidents require to be reported to MOD authorities. Reporting to external regulatory authorities may also be required. See Leaflet 14 for details. Transported as an excepted package. Radioactive trefoil and identification marking Return to stores. Keep records for 2 years. See Leaflet 11 Related leaflet*

Reporting procedures

14 10, JSP 800 Vol. 4a & Vol. 4b 12 11

Transport Marking Disposal Sale/transfer

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 21 ANNEX A EXAMPLE SUMMARY RADIATION RISK ASSESSMENT

1623A NATURAL URANIUM CHECK SOURCE 1623A Natural uranium check source

Description

Use Supplier NSN / part number IPT Radionuclide

The check source is a disc of natural uranium (23.1 mm diameter, 1.12 mm thick) mounted in an aluminium container. The container lid is unscrewed to reveal the source, which is bonded to the circular aluminium base block. Recent modification of the source has been carried out which has further secured the radioactive component by way of a steel retaining ring and screws as shown above. Used in the functional testing of a wide range of radiation protection instruments. AEA Technology QSA K107-6665-99-193-3906 Marine Environment Survivability & Habitability Chemical Biological Radiological Nuclear (MESH) IPT. Natural uranium. Alpha, beta and gamma and X-ray radiation is emitted from the source.

Ionising radiation

Natural uranium contains 0.72% uranium- 235, 0.006% uranium-234 and 99.274% uranium-238. ~ 4.5x109 years for uranium 238 111 kBq The alpha radiation of the uranium isotopes in the source present an internal radiation hazard on ingestion or inhalation of the natural uranium. The beta radiation of some of the decay products present in the source, together with the weak gamma radiation emitted by all nuclides, present an external radiation hazard.

Half life Original activity

Hazard

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Risk assessment

Local orders

Control measures during use

During the functional testing on a wide range of radiation protection instruments, the radioactive source will be exposed for a short period only and will be directed away from the body. The most significant dose rate will be to the hand of the operator and will be shielded by the source housing. In this configuration the maximum dose rate to the hand is 1.5 Sv h-1. As the check source may be used on a daily basis, and a functional test is estimated to take 30 seconds, the maximum theoretical skin dose for a working year is estimated to be 5 Sv h-1. Whole body effective dose would be very much less than this value. Details of the control measures taken from this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). The source should only be unscrewed for use if this is necessary to check the function of particular type of instrument (e.g. alpha or beta contamination probe). The radiation monitoring instrument or detector is to be placed against the outer casing or close to (but not touching) the surface of the uranium disc to obtain a reading. This item is not to be carried on the person and handling of the item is to be kept to a minimum. The spread of contamination and the likelihood of any resultant personal contamination will be minimised where practicable by wearing disposable gloves when using the source and washing hands immediately afterwards as a precautionary measure. Leak testing is required at least every 24 months. This item is to be accounted for on a Radioactive Source List (Leaflet 9 refers) under the supervision of an RPS or WPS. All radioactive material is to be mustered at least monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. This item is exempt from notification to the relevant environment agencies under RSA 93, under the Testing Instruments Exemption Order. The item is, however, to be included in the Annual Holdings Return to Dstl ESD (Leaflet 3 refers). This item is to be stored in a dedicated area for radioactive materials (see Leaflet 9). The equipment is to have the recognised radioactive trefoil and marking on it. The storage/installed area is also to have a sign showing radioactive material within, i.e. a radiation warning trefoil including the contact name and telephone number of the RPS or WPS and stating the nature of the radiological hazard in appropriate languages: Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged. If a breakage occurs the area is to be cordoned off. The RSO and the RPA are to be contacted. Reporting of loss and certain other incidents are to be carried out in accordance with the procedures described in Leaflet 14. May be transported as an excepted package. Units and Establishments are to return this item, unbroken, through the Stores Organisation.

Leak testing

Accounting

Radioactive Substances Act 1993

Storage and labelling

Contingency plans breakage/loss/incident Transport Disposal

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LEAFLET 21 ANNEX B EXAMPLE INSTRUMENT PRE-USE FUNCTIONAL TESTING RECORD SHEET

Instrument Description

Serial Number

Battery Power Check

Check Source Reference Number

Instrument Response
Expected Actual

Name of person carrying out test

Signature

Date

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LEAFLET 22 LUMINISED EQUIPMENT CONTENTS Para 1 5 6 7 8 9 10 11 15 16 20 21 22 23 25 Table 1 2 3 Figure 1 2 Annex A B C Wrist Watch Divers 300m Example of a summary radiation risk assessment Chronograph Wrist Watch Luminous Example of a summary radiation risk assessment Silva Compass NATO 4B Example of a summary radiation risk assessment Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Classification of luminised articles Markings Historical Items Tritium monitoring and detection Risk assessments for luminised equipment Personal Protective Equipment Breakage of luminised equipment Legal and MOD mandatory requirements Page Maximum radionuclide content........................................................................................................3 Hazards associated with luminised equipment ...............................................................................5 Legal and MOD mandatory requirements for luminised equipment................................................6 Page Markings for luminised articles . ......................................................................................................4 Standard radiation trefoil. Colour of symbol: black on yellow or white background.......................4

SCOPE 1 Luminous articles to which this chapter applies are those in which the luminous paint contains radioactive material. Commonly used equipments of this type include watches, compasses, soundpowered telephones, telephone control boards and dials of instruments found in establishments or in vehicles, ships and aircraft. Modern equipment (post 1970s) uses tritium (H-3) as the radioactive material. However, in the past other radioactive materials have been used, including promethium-147 (1950s and 1960s) and radium-226 (pre-war to the 1950s). Further information regarding historical luminised items is provided in paragraph 16. 2 This leaflet describes the radiological requirements for keeping, using and disposing of equipment luminised using radioactive materials. Summaries of the radiation risk and regulatory requirements for some specific luminised equipments are provided at the Annexes to this leaflet. Summary risk assessments for a range of other in-service luminised equipments not listed in the Annexes are also available from the Dstl RPA Body. Additionally, the RPA is to be consulted where further information regarding the radiological hazards and safety requirements for luminised equipment is required.

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3 It should be noted that not all luminous articles are radioactive. Some are luminised using nonradioactive materials. 4 This leaflet does not describe the requirements for the de-luminsing and re-luminising of radioactive luminous components. These are specialist activities and must only be undertaken under controlled arrangements determined through consultation with the RPA. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 5 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Radioactive Substances (Luminous Articles) Exemption Order 1985 (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 6 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements is to be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 7 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping, using and disposing of luminised equipment as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 8 Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Further information on the requirements for appointment of an RPS is given in Table 3. Workplace Supervisor (WPS) 9 In units holding luminised equipment but where it is unnecessary to appoint an RPS, a WPS (Radioactive Materials) is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet.

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Employees 10 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that luminous articles are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager. CLASSIFICATION OF LUMINISED ARTICLES 11 Radioactive Substances (Luminous Articles) Exemption Order 1985 states that luminised articles containing tritium or promethium-147 are classified as Class A or Class B articles. The classification dictates the conditions under which holdings of such articles, and the arrangements for accumulation and disposal of such articles as waste, are exempt from specific requirements of the Radioactive Substances Act 1993. The classification criteria are outlined below: 12 Class A articles are instruments, illuminants or indicators which contain either tritium or promethium-147 paint, which is insoluble in water, and have a maximum activity as detailed in Table 1. 13 Class B articles are components of a clock, watch, instrument, illuminant or indicator that contain either tritium or promethium-147 paint, which is insoluble in water, and have a maximum activity as detailed in Table 1. Table 1 Maximum radionuclide content Radionuclide Promethium-147 (Pm-147) Tritium* (H-3) 14 Further advice is to be sought from the RPA. Maximum activity incorporated in an individual luminised article 80 MBq 4 GBq

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MARKINGS 15 The following markings are sometimes found on luminised equipment.

T P L

Radioactive containing tritium

Radioactive containing promethium-147

NOT radioactive

Figure 1 Markings for luminised articles

Figure 2 Standard radiation trefoil. Colour of symbol: black on yellow or white background.

HISTORICAL ITEMS 16 Promethium-147, which has a radioactive half-life of only 2.6 years, was used until the 1970s as a luminising agent. A few items containing promethium-147 remain in service but the limited activities of promethium-147 that generally remain on any such equipment are such that the radiation emitted is difficult to detect, Furthermore, such items are unlikely to remain luminous. The hazards associated with promethium-147 luminised articles are summarised in table 2. 17 Radium luminised compounds, unlike other luminised materials, can be identified by the easily measurable gamma radiation emitted. The age of the equipment can also be an indicator of the potential presence of radium. Many items dating from pre-war to the 1950s were luminised with radium based paint, and the luminous material is now likely to be dirty brown in appearance. As is the case for articles luminised using promethium-147, radium luminised articles are unlikely to remain luminous today. However, much of the original radioactivity will remain as the half life of radium-226 is approximately 1600 years. 18 Where radium luminised equipment is held by museums and in historical collections, such articles are not to be stored, used, handled or placed on display, unless a risk assessment has been completed in consultation with an RPA as there can be external dose rates from the luminised surface. The RPA is to be contacted for further guidance on the use and handling of radium luminised equipment. Radium items other than those held by museums or historical collections are to be removed from service and arrangements put in place to dispose of the items through authorised disposal routes. 19 Equipments containing radium must not be passed for any sale involving members of the public.

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HAZARDS Table 2 Hazards associated with luminised equipment Radiation type Emitted Comments *For radium-226 luminised articles only Radium-226 emits alpha radiation. This radiation will be fully attenuated by the instrument casing but will present an internal hazard if the casing is damaged and the luminising material is inhaled, ingested or contaminates the skin. Low energy beta radiation is emitted by tritium and promethium147 luminised articles, but the energy of the beta is insufficient to penetrate beyond the instrument casing. Radium-226 luminised articles emit higher energy beta radiation which may not be fully attenuated by the instrument casing. Tritium and promethium-147 can present a hazard internal to the body if taken in by ingestion, inhalation, and absorption through the skin or through cuts in the skin. The beta radiation emitted by radium-226 can give rise to a radiation dose to the skin in the event of skin contamination and will present an internal hazard if the material is ingested, inhaled, or absorbed through cuts in the skin. Low levels of Bremsstrahlung radiation (X-rays) can be emitted from luminised equipment. *For radium-226 luminised articles only Radium luminised equipment can present an external hazard during use or storage as dose rates of 10-100s Sv h-1 could be measured. A leaking source will cause contamination that could lead to an internal hazard if the radioactive material enters the human body.

Alpha

Direct Beta

Bremsstrahlung

Gamma

X-rays Neutrons

TRITIUM MONITORING AND DETECTION 20 Monitoring the radiation dose rate from a tritium luminised article is difficult due to the very low energy beta radiation emitted and will therefore record a level less than 1 Sv h-1. Similarly, it is very difficult to detect tritium contamination without the use of specialised monitoring instrumentation. Tritium surveys are therefore generally carried out by indirect means involving the taking and analysis of smears of the surfaces to be monitored. RISK ASSESSMENTS FOR LUMINISED EQUIPMENT 21 The range of luminised articles in service within MOD is too large to describe in this publication. Similarly, it is not possible to include risk data for all items. However, summary risk assessments for a selection of luminised articles are provided at Annexes A to C of this leaflet. These summary risk assessments can be used to scope the hazard and control requirements for a wider range of luminised equipment and can be used, where appropriate, as input to the risk assessments and local orders required in accordance with Leaflets 2 and 16 respectively. Advice on further detail and assessments can be sought from the RPA. PERSONAL PROTECTIVE EQUIPMENT (PPE) 22 PPE is not required for the routine handling of intact luminised equipment.

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BREAKAGE OF LUMINISED EQUIPMENT 23 Luminised equipments are not to be damaged deliberately or have protective covers removed by unauthorised persons. 24 Broken luminised articles are potentially hazardous because loose radioactive material can enter the body by a variety of means including inhalation of radioactive dust and absorption through cut or damaged skin. Detailed guidance on the procedure for dealing with broken luminised equipment is in Leaflet 40. LEGAL AND MOD MANDATORY REQUIREMENTS 25 Table 3 below summarises the legal and MOD mandatory requirements for luminised equipment. In cases of doubt, the RPA is to be consulted for advice. Table 3 Legal and MOD mandatory requirements for luminised equipment Requirement HSE authorisation HSE notification The HSE is to be notified in accordance with leaflet 3. Holdings of tritium luminised equipment up to an individual activity of 4 GBq and of promethium-147 luminised equipment up to an individual activity of 80 MBq are exempt from notification to the relevant environment agency under the Radioactive Substances (Luminous Articles) Exemption Order 1985, provided the total activity of Class B equipment kept on a premises is less than 200 GBq for tritium and 4 GBq or promethium-147 luminised equipment. See examples at annexes to this leaflet. Further specific risk assessments or prior risk assessments can be required. (see Leaflet 2). Observe manufacturers instruction and guidance. Also, see Leaflet 4. Not required except when dealing with a breakage. Not required See leaflet 40 for contingency plans for incidents involving breakage of radioactive items or radioactive items involved in a fire. The presence of luminised equipment does not usually, lead to a requirement for area designation. See leaflet 4 for guidance. Not normally required except when dealing with a breakage Information and instruction only. See leaflet 16 for guidance. RPS not required except for when storage areas require to be designated as controlled or supervised. Where an RPS is not required, a WPS (Radioactive Materials) needs to be appointed in accordance with Leaflets 15 and 39. 15 16 3 Applicable Comments Related leaflet*

EA notification**

Risk assessment Restriction of exposure PPE Maintenance of radiation engineering controls Contingency plans

2 4

40

Designated areas Monitoring Training for users Local orders

(but see comment) (but see comment)

Appointed person

15, 39

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Table 3 Legal and MOD mandatory requirements for luminised equipment (continued) Requirement Storage Applicable Comments In a segregated secure store/container/cupboard marked with radiation trefoil warning sign and stored in accordance with Leaflet 9. Recorded on a source list (retained for 2 years) and mustered in accordance with Leaflet 9. Recorded on Dstl Annual Holdings Return, copy retained for 1 year. Leak testing is not appropriate for luminised equipment.
(but see comment)

Related leaflet* 9

Accounting

Leak testing Personal dosimetry

Personal dosimetry will only need to be worn if there is a requirement for a designated area. All losses and certain other incidents require to be reported to MOD authorities. Reporting to external regulatory authorities can also be required. See leaflet 14 for details. Items and bulk quantities can generally be transported as excepted packages as detailed in JSP 800 Vol. 4b (road, rail, sea) or JSP 800 Vol. 4a (air) provided that; For tritium, the total activity per package does not exceed 40,000 GBq For promethium-147 the activity per luminised item does not exceeded 20 GBq and the total activity per package does not exceed 2000 GBq. Radium is to not be transported without prior consultation with the RPA. All luminised equipment stores and containers are to be marked appropriately in accordance with this leaflet. See Leaflet 11 14

Reporting procedures

Transport

JSP 800 Vol. 4a & Vol. 4b

Marking Sale/Transfer

9 11

Jan 2007

Leaflet 22 Page 7

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Radiation Safety Handbook

Unbroken modern luminised are to be returned via Stores. Historic items, particularly those containing radium226 cannot be returned through stores. The RPA is to be contacted for specific advice. Broken luminised (except Radium luminised) equipment is to be placed in a suitable container (e.g. a paint tin) following the approved cleanup procedure. In the UK the disposal of the tin, luminous component fragments, cloths, gloves etc, may be via the normal refuse route, provided not more than 10 luminised items (or the fragments of 10 luminised items) are disposed per week from the premises. The disposal container is to not have any markings to indicate the presence of radioactive material. Disposal must not be to a tip on the establishment site. Where surplus MOD stocks are sold at auction, it is particularly important that sales items are checked for the presence of radioactive materials. See leaflet 12 for further guidance. Further advice can be sought from the RPA as necessary. Keep records of disposal for 2 years. *JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI)

Disposal of redundant items

12

Leaflet 22 Page 8

Jan 2007

Radiation Safety Handbook

JSP 392

LEAFLET 22 ANNEX A WRIST WATCH DIVERS 300M EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

Wrist Watch Divers 300M Description The Divers Watch contains 2.4 MBq of tritium paint, which is used to luminise the hands and numbers, in dark/ dimly lit conditions.

T
Use Supplier NSN IPT Details Radionuclide Ionising Radiation Half Life Original Activity Classification Hazard

Risk Assessment

Local orders Control measures during use Inspection Leak Testing

Watch marking Luminous watch for use underwater Cabot Co Ltd 0555-99-757-3314 Combat Support Tritium (H-3) Beta 12.3 years 2.4 MBq Class B article under the Luminous Articles Exemption Order 1985. Tritium is the radioactive form of hydrogen and is present within the luminising material on the watch dial. The glass face of the watch is sufficient to attenuate the beta radiation emitted by the tritium. If the watch is destroyed in a fire the tritium is rapidly converted to tritiated water a more hazardous form of tritium. Tritium and tritiated water emitted during such an event may present a hazard due through inhalation and absorption through the skin. The likelihood of accidental damage to this watch is low, because it would require a strong and directional force to break the glass face of the watch. If broken, and on the basis of an assumption that 10% of the tritium is removed of which 1% is ingested, a committed effective dose of 0.1Sv could be received. This dose is negligible. (Ref DRPS Report 289/2004 dated 10/12/04). Details of the required control measures as detailed in this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Exempt from formal RSA 93 notification to the relevant environment agencies, provided the total activity of Class B luminised equipment kept on the premises is less than 200 GBq. This item is to be included in the Annual Holdings Return to Dstl Leaflet 3 refers.

Accounting

Radioactive Substances Act 1993

Jan 2007

Leaflet 22 Annex A Page 1

JSP 392

Radiation Safety Handbook

Storage and Labelling

Contingency Plans

Transport

Disposal

This item is to be stored in a dedicated area for radioactive materials. Leaflet 9 refers. The storage area is to have a sign indicating the presence of radioactive material within i.e. a trefoil including the contact name and telephone number of the RPS and stating the nature of the radiological hazard e.g. Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged If a breakage occurs the area is to be cordoned off. The broken item can be cleaned up using a breakage kit (Leaflet 40 refers). Reporting of loss and certain other incidents are to be carried out in accordance with the procedures described in Leaflet 14. This item may be transported in an excepted package provided the total package activity does not exceed 40,000GBq and the surface dose rate of the package is less than 5 Sv h-1. JSP 800 Vol. 4a & 4b refer. Units and Establishments are to return this item, unbroken, through the Stores Organisation. Broken items are to be disposed of in accordance with Leaflet 40.

Leaflet 22 Annex A Page 2

Jan 2007

Radiation Safety Handbook

JSP 392

LEAFLET 22 ANNEX B CHRONOGRAPH WRIST WATCH LUMINOUS EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

Chronograph Wrist Watch Luminous Description The Chronometer watch contains a total of activity of 2.4 MBq of Promethium-147 in the form of luminised paint. This paint is used to luminise the hands and the numbers of the watch.

P
Watch marking Use Supplier NSN IPT Details Radionuclide Ionising Radiation Half Life Original Activity Classification Hazard

Risk Assessment

Local orders Control measures during use Inspection Leak Testing

Luminous watch Seiko 6645-99-814-9181 Combat Support Promethium-147 Beta 2.6 years 2.4 MBq Class B article under the Luminous Articles Exemption Order 1985. Promethium is present within the luminising material on the watch dial. The glass face of the chronometer watch is sufficient to attenuate the beta radiation. The likelihood of accidental damage to this watch is such a degree that the risk of Pm-147 release is low. A more severe accident, for example, smashing or crushing the watch face, could result in a small dose (0.6 Sv) through ingestion or inhalation of promethium 147. Reference DRPS Report 289/2004 - Combat Support Luminised Items. Details of the required control measures as detailed in this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No protective clothing or special precautions required. Annually as well as during routine maintenance. Check to be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location is to be entered in the Source Movement Log together with any change in custodian. Exempt from formal RSA 93 notification to the relevant environment agencies, provided the total activity of Class B luminised equipment kept on the premises is less than 4 GBq. This item is to be included in the Annual Holdings Return to Dstl Leaflet 3 refers.

Accounting

Radioactive Substances Act 1993

Jan 2007

Leaflet 22 Annex B Page 1

JSP 392

Radiation Safety Handbook

Storage and Labelling

Contingency Plans

Transport

This item is to be stored in a dedicated area for radioactive materials. Leaflet 9 refers. The storage area is to have a sign indicating the presence of radioactive material within i.e. a trefoil including the contact name and telephone number of the RPS and stating the nature of the radiological hazard e.g. Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged. If a breakage occurs the area is to be cordoned off. The broken item can be cleaned up using a breakage kit (Leaflet 40 refers). Reporting of loss and certain other incidents are to be carried out in accordance with the procedures described in Leaflet 14. This item may be transported in an excepted package provided the total package does not exceed 2,000GBq and the surface dose rate of the package is less than 5 Sv h-1. JSP 800 Vol. 4a & 4b refer. Units and Establishments are to return this item, unbroken, through the Stores Organisation. Broken items are to be disposed of in accordance with Leaflet 40.

Disposal

Leaflet 22 Annex B Page 2

Jan 2007

Radiation Safety Handbook

JSP 392

LEAFLET 22 ANNEX C SILVA COMPASS NATO 4B EXAMPLE OF A SUMMARY RADIATION RISK ASSESSMENT

Silva Compass NATO 4B


Description GTLD Paint Light Film Use Supplier NSN IPT details Radionuclide Ionising radiation Half life Original activity Classification Hazard Equipment marked with a trefoil
GTLD = 0.74 GBq (end of direction arrow). Paint = 0.33 GBq (Inside capsule 2 dots, 1 each side of red arrow) Light Film =0.22GBq (needle and scale).

Risk assessment

Luminous dial for compass Silva Sweden AB, BOX 998, 191 29 Sollentuna, SWEDEN 1430-99-529-3731 Combat support IPT H-3 Beta 12.3 years 1.29 GBq Class A under the GTLD Exemption Order 1985 SI 1047 Activity not exceeding 20GBq. Tritium is the radioactive form of Hydrogen and is a highly flammable gas. Tritium within the compass is in the form of gas (GTLS) and solid (luminous paint). If destroyed in a fire, the tritium is rapidly converted to tritiated water. Tritiated water presents the greater hazard due to its ability to enter the body both by inhalation and rapid absorption through the skin. In an enclosed space this constitutes an extra risk to personnel in the immediate vicinity. The likelihood of accidental damage to this compass is low, because it would require a strong and directional force to break the face. There is a low probability of release of tritium. If broken and 10% was removed and 1% of that were ingested a committed effective dose of 10Sv, could be received, which is less than two days natural daily background radiation in the UK. (Ref DRPS Report 289/2004 dated 10/12/04). Details of the required control measures as detailed in this leaflet are to be included in the local orders for radiation safety (Leaflet 16 refers). No special precautions are required. Annually as well as during routine maintenance. Check should be made for signs of damage. Leak testing is not required for this component. This item is to be accounted for on a Radioactive Source List. Leaflet 9 refers. All radioactive material is to be mustered monthly. Any change of location should be entered in the Source Movement Log together with any change in custodian. This item is subject to RSA93 and should be included in the Annual Holdings Return to Dstl. This item is to be stored in a dedicated area for radioactive materials. The equipment is to have the recognised radioactive trefoil on it. The storage area is also to have a sign indicating the presence of radioactive material within. i.e. a trefoil including the contact name and telephone number of the RPS and stating the nature of the radiological hazard - Items contain radioactive material. No radiation hazard from intact item. Radioactive contamination hazard if item damaged.

Local orders

Control measures during use Inspection Leak testing Accounting

Radioactive Substances Act 1993 Storage and labelling

Jan 2007

Leaflet 22 Annex C Page 1

JSP 392

Radiation Safety Handbook

Contingency plans

If a breakage occurs the area is to be evacuated and ventilated. Tritium gas will disperse relatively quickly, however some will remain bonded to the component. Once a suitable amount of ventilation time has passed (one hour) the broken item can be cleaned up using a breakage kit, see Leaflet 40. Reporting of loss and certain other incidents is to be carried out in accordance with procedures described in Leaflet 14. This item may be transported as an excepted package provided the total package does not exceed 8000GBq and the surface dose rate of the package is less than 5 Sv h-1 . JSP 800 Vol. 4a & 4b refer. Units and establishments are to return this item, unbroken, through the Stores Organisation. Broken items are to be disposed of in accordance with Leaflet 40.

Transport

Disposal

Leaflet 22 Annex C Page 2

Jan 2007

Radiation Safety Handbook

JSP 392

LEAFLET 23 HIGH VOLTAGE ELECTRICAL EQUIPMENT CONTENTS Para 1 5 6 7 8 9 10 Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Hazards Risk assessments for high voltage equipment Risk assessment at procurement Risk assessment for users Design of equipment Protection against parasitic X-ray emissions Increased ionising radiation hazard during maintenance Legal and MOD mandatory requirements Page Ionising radiation hazards associated with high voltage equipment ...............................................3 Legal and MOD mandatory requirements for work with high voltage equipment ...........................5

11 12 14 17 20 21 Table 1 2

SCOPE 1 Under certain circumstances, ionising radiation in the form of X-rays may be emitted by high voltage (HV) electrical equipments not specifically designed to produce such radiation. Charged particles (electrons) acquire high energy when accelerated under the influence of HV the energy lost by these electrons on striking target material may be emitted in the form of X-rays known as parasitic (or adventitious) X-rays. Where the HV involved exceeds 5 kV, the Ionising Radiations Regulations 1999 apply to work involving the equipment. This leaflet describes the resulting ionising radiation safety requirements for work with such equipment. 2 The most commonly found components producing parasitic X-rays are klystrons, magnetrons, high voltage valves, travelling-wave tubes and cathode ray tubes, although there are many other components capable of producing them in equipments such as high voltage rectifiers, display units and radar/electronic warfare equipment. Parasitic X-ray emissions should not be confused with radiofrequency emissions (non-ionising radiations) that may also be present and provide an additional hazard (see Leaflet 35). 3 High voltage equipment (>5 kV) containing a cathode ray tube or a visual display unit which, under normal operating conditions, does not produce a dose rate of more than 1 Sv h-1 at a distance of 0.1 m from any accessible surface benefits from some relaxations on the application of IRR99 (see Table 2). 4 This leaflet details the requirements for protection of persons from ionising radiations emitted by the HV equipment. The scope of the leaflet does not extend to the requirements for protection against non-ionising radiofrequency radiation. Nor does the scope extend to other items such as radioactive electronic valves, gaseous tritium light sources or smoke detectors which may also be associated with the electrical equipment. Such items are addressed in separate leaflets.

Jan 2007

Leaflet 23 Page 1

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STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 5 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 6 Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 7 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for high voltage equipment detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 8 An RPS must be appointed in respect of any area designated as controlled or supervised. Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Further information on the requirements for designated areas and the appointment of an RPS is given in Table 2. Workplace Supervisor (WPS) (X-ray) 9 In units operating or maintaining high voltage equipment capable of emitting parasitic X-rays but where it is unnecessary to appoint an RPS, a WPS (X-ray) is to be appointed with duties to ensure that work is carried out in accordance with the local orders which are to include the requirements of this leaflet. Employees 10 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that their exposure to parasitic X-rays is restricted as far as is reasonably practicable. Any incident is to be reported to the appropriate supervisor or line manager.

Leaflet 23 Page 2

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JSP 392

HAZARDS Table 1 Ionising radiation hazards associated with high voltage equipment Radiation type Alpha Beta Direct Bremsstrahlung Parasitic X-rays are a by-product arising from many types of high voltage equipment (>5 kV). They may be emitted from klystrons, magnetrons, high voltage valves, travelling-wave tubes, cathode ray tubes and many other components such as high voltage rectifiers, display units and radar/electronic warfare equipment. Emitted Comments

Gamma

X-rays

Neutrons RISK ASSESSMENTS FOR HIGH VOLTAGE EQUIPMENT Risk assessment at procurement 11 In the acquisition of equipment which may emit ionising radiation, safety and environmental management is to begin at the requirements definition stage of procurement and is to be carried forward through service to disposal. All aspects of maintenance and operation (including military service) are to be taken into account. Those managing the procurement process and specification development of the equipment which may emit ionising radiation are to assess the risk areas and recommend solutions to reduce the risks to as low as reasonably practicable (see also Leaflet 1 and Leaflet 2). Where it is possible to produce a generic risk assessment, this is to be carried out and made available to users. Risk assessment for users 12 A risk assessment is to be carried out by the unit or establishment in consultation with the Radiation Protection Adviser (RPA) prior to any new activity involving high voltage equipment that may generate parasitic X-radiation. This risk assessment is to take into account the generic risk assessment carried out at the procurement stage (if available) and take into account the recommended solutions to reduce risk provided by the acquisition process and the local conditions of use. Details of the form of the risk assessment and the actions to be taken arising from it are described in Leaflet 2. Risk assessments are to be reviewed as detailed in Leaflet 2. 13 The following are key inputs into the risk assessment: 13.1 Advice from the manufacturer and information from the IPT.

13.2 RPA information and advice the Dstl ESD RPA may be able to provide detailed hazard and risk assessment information on the equipment. 13.3 Radiation survey information estimated dose rates when operating and during maintenance (if carried out). 13.4 Planned systems of work and routine operation profile e.g. continuous, intermittent, 1 hour per day etc. Routine maintenance profile e.g. 8 hour per week at operating voltage. 13.5 Personnel access and occupancy of areas subject to levels of ionising radiation.

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13.6 13.7

Assessment of reasonably foreseeable fault conditions and resultant dose rates. Assessment of the impact of reasonably foreseeable accidents/incidents.

DESIGN OF EQUIPMENT 14 All high voltage electrical equipment is to be provided, where reasonably practicable, with shielding to ensure that beams or fields of radiation do not produce dose rates in excess of 1 Sv h-1 in the working area. If this is not reasonably practicable, other control measures may be necessary and are to be determined in consultation with the RPA. 15 The equipment is to, by design, or by the provision of safety devices prevent anyone reaching inside to an area where the dose rate exceeds 7.5 Sv h-1. Where practicable, the safety devices are to be fail-safe. 16 Where access to the inside of any equipment is permitted, protective covers providing shielding to components producing parasitic X-rays are to be incorporated in the design. PROTECTION AGAINST PARASITIC X-RAY EMISSIONS 17 X-ray emissions identified by a unit or establishment that are not referred to in the equipment handbook are to be reported to the equipment sponsor, the appropriate TLB safety authority and the RPA at Dstl ESD Alverstoke. 18 Sponsors of equipments producing parasitic X-ray emissions are, where reasonably practicable, to introduce modifications to minimise the hazard to personnel. This may be by the provision of shielding around the equipment or part of the equipment which generates the parasitic X-rays. 19 Where removable radiation shielding is provided, it is to be used as directed in the equipment handbook. Such shielding is to be marked to indicate the presence of an increased radiation hazard if it is removed. Equipments with removable shielding are to, whenever practicable, be fitted with interlocks to prevent the equipment from operating when the shielding is removed. INCREASED IONISING RADIATION HAZARD DURING MAINTENANCE 20 Where users carry out maintenance or inspection tasks which require the equipment to be powered up, account must be taken of the increased hazard faced by maintainers. The increased hazard may be due to the need for access to components which are normally shielded or due to the need for a maintainer to be positioned closer to the source of ionising radiation than is necessary during normal operation. Consideration of these issues must be carefully considered in the risk assessment and appropriate measures to restrict exposure introduced. Such measures must be included in local orders for radiation safety (see Leaflet 16) and must also be included in the training of maintainers.

Leaflet 23 Page 4

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LEGAL AND MOD MANDATORY REQUIREMENTS 21 Table 2 below summarises the legal and MOD mandatory ionising radiation requirements for high voltage equipment. In cases of doubt, the RPA is to be consulted for advice. Table 2 Legal and MOD mandatory requirements for work with high voltage equipment Requirement Applicable Comments Not required for electrical equipment emitting parasitic X-rays. In general, work involving high voltage equipment (> 5kV) is to be notified to HSE in accordance with Leaflet 3. The following work need not be notified: Operation of any cathode ray tube for the display of visual images provided that the dose rate at a distance of 0.1m from any accessible surface does not exceed 1 Sv h-1. Operation of other electrical apparatus (>5kV and 30kV), provided that the dose rate at a distance of 0.1m from any accessible surface does not exceed 1 Sv h-1. Operation of any other electrical equipment (>5kV), if of a type approved by HSE, provided that the dose rate at a distance of 0.1m from any accessible surface does not exceed 1 Sv h-1. Not required for electrical equipment. A risk assessment is required to identify radiation dose rates and control measures at accessible positions during operation and maintenance. Reasonably foreseeable fault conditions are also to be considered. Observe manufacturer/equipment instruction and guidance. Ensure exposure of all personnel is as low as reasonably practicable (ALARP). Set dose investigation levels. Not required unless advised by the RPA for specific maintenance tasks. Where design features include safety devices to restrict exposure by shielding or preventing access to areas of high dose rate, these devices are to be properly inspected, tested and maintained at suitable intervals. Required where the risk assessment identifies any immediate measures to be taken in the event of reasonably foreseeable faults, accidents or incidents leading to enhanced exposure levels. Related leaflet*

HSE authorisation

HSE notification

EA notification**

Risk assessment

Restriction of exposure

PPE

Maintenance of radiation engineering controls

(but see comment)

Contingency plans

(but see comment)

40

Jan 2007

Leaflet 23 Page 5

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Table 2 Legal and MOD mandatory requirements for work with high voltage equipment (continued) Related leaflet*

Requirement

Applicable

Comments Equipment is normally to be designed such that dose rates in the working area are ALARP and area designation is unnecessary. Designated areas may be required for some equipments during certain maintenance tasks. Normally, a controlled area will be necessary where the dose rate in the area exceeds 7.5 Sv h-1 and a supervised area if any person could receive more than 1 mSv in a year - the RPA is always to be consulted regarding area designation and the associated control measures. Not normally required. However, where personnel could receive annual dose levels in excess of 6 mSv whole body (or other levels specified in Annex E to Leaflet 4) then they are to be made a classified person. Local orders are to specify radiation surveys to be conducted, at regular intervals, around equipment that may produce dose rates exceeding 1 Sv h-1. The orders are also to specify dose rate action levels and the action to be taken. Instruments used for surveys are not to be susceptible to interference by radiofrequency radiation where this may be present. RPA advice must be sought on the suitability and calibration requirements for survey instruments and regarding action to be taken if radiation levels exceed the action levels. Information and instruction required so that users are aware of the measures to be taken for restriction of exposure and the content of local orders relevant to their duties. See Leaflet 16 for guidance. RPS not required except for areas required to be designated as controlled or supervised. Where an RPS is not required, a Workplace Supervisor (Xray) needs to be appointed to ensure that local orders for radiation safety are followed. Not applicable. Not applicable. Not applicable.

Designated areas

(but see comment)

Designation of personnel

(but see comment)

4, 38

Monitoring

4, 8

Training for users

15, 16

Local orders

16

Appointed person

39

Storage Accounting Leak testing

Leaflet 23 Page 6

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JSP 392

Table 2 Legal and MOD mandatory requirements for work with high voltage equipment (continued) Requirement Applicable Comments Not normally required unless an area is designated as controlled or supervised or as advised by the RPA e.g. for personnel working in 909 radar compartments. An unusual radiation event or overexposure is to be reported in accordance with the procedures in Leaflet 14. Radiological controls are not applicable to electrical equipment but may be applicable to radioactive items within the equipment (see relevant leaflet for that item). High voltage equipment that produces dose rates in excess of 1Sv h-1 at the surface of the equipment is to be marked on the outside with a radiation warning sign. Where internal access to the equipment is permitted, protective covers shielding components emitting parasitic X-rays are also to be marked with a radiation warning sign. See Leaflet 11 Radiological controls are not applicable to electrical equipment but may be applicable to radioactive items within the equipment (see relevant leaflet for that item). Radiation warning signs are to be removed if the equipment earmarked for disposal has been permanently disabled. Related leaflet*

Personal dosimetry

(but see comment)

Reporting procedures

14

Transport

(but see comment)

Marking

Sale/Transfer

11

Disposal of redundant items

(but see comment)

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

Jan 2007

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Leaflet 23 Page 8/8

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LEAFLET 24 POSTAL AND BAGGAGE FLUOROSCOPES CONTENTS Para 1 3 4 5 6 7 8 Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Hazards Risk assessments Risk assessment at procurement Risk assessment for users Design of postal and baggage fluoroscopes Warning signals Installation Maintenance Operating Instructions Local orders for radiation safety Security General safety requirements Legal and MOD mandatory requirements Page Ionising radiation hazards associated with postal and baggage fluoroscopes ...............................3 Legal and MOD mandatory requirements for work with postal and baggage fluoroscopes ...........6

9 10 12 15 17 21 24 25 26 27 32 Table 1 2

SCOPE 1 Non-medical X-ray fluoroscopes are widely used for the examination of postal packages, luggage and other baggage. The fluoroscopes may be installed or portable. They may be of a compartment type allowing continuous viewing of the X-ray image of a package or conveyor type where images are converted to digital form and viewed on a computer monitor. Although very high radiation dose rates may exist within the equipment, design is such as to minimise exposure to operators and others. Operation of such equipment is subject to the Ionising Radiations Regulations 1999 (IRR99). This leaflet describes the radiation safety arrangements that employers must put in place to ensure compliance with the regulations. 2 This leaflet does not cover the radiation safety requirements for maintenance and testing of such fluoroscopes. Nor does the scope of this leaflet extend to the operation of X-ray generators for purposes other than postal and baggage security scanning by fluoroscopy. Separate leaflets cover industrial radiography, pulse and flash X-ray equipment (Leaflet 28), medical diagnostic X-ray (Leaflet 26), Dental X-ray (Leaflet 25) and Veterinary X-ray (Leaflet 27).

Jan 2007

Leaflet 24 Page 1

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STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 5 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for security scanning X-ray equipment detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 6 An RPS must be appointed in respect of any area designated as controlled or supervised. However, area designation is not normally necessary where the only work with ionising radiation in the area is the operation of postal and baggage fluoroscopes. Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Further information on the requirements for designated areas is given in Leaflet 4. Workplace Supervisor (WPS) (X-ray) 7 In units operating postal or baggage fluoroscopes but where it is unnecessary to appoint an RPS, a WPS (X-ray) is to be appointed with duties to ensure that work is carried out in accordance with the local orders which are to include the requirements of this leaflet. Employees 8 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that their exposure to X-rays is restricted as far as is reasonably practicable. Any incident is also to be reported to the appropriate supervisor or line manager.

Leaflet 24 Page 2

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JSP 392

HAZARDS Table 1 Ionising radiation hazards associated with postal and baggage fluoroscopes Radiation type Alpha Beta Direct Bremsstrahlung Emitted Comments

Gamma X-ray generators used in postal and baggage fluoroscopes generate high in-beam dose rates capable of delivering up to a few mSv per minute. However, design of such equipment is to ensure that dose rates to operators are normally restricted to no more than 1 Sv h-1. Faults or other occurrences, which may be reasonably foreseeable, could reduce the effectiveness of shielding and lead to higher dose rates such X-ray leakage may give a general increase in exposure levels or may be confined to narrow beams (streaming pathways). During maintenance work, involving access (by a suitably qualified engineer) to internal components, higher dose rates may be encountered. Neutrons RISK ASSESSMENTS FOR POSTAL AND BAGGAGE FLUOROSCOPES Risk assessment at procurement 9 In the acquisition of equipment which may emit ionising radiation, safety and environmental management is to begin at the requirements definition stage of procurement and is to be carried forward through service to disposal. All aspects of maintenance and operation (including military service) are to be taken into account. Those managing the procurement process and specification development of the equipment which may emit ionising radiation are to assess the risk areas and recommend solutions to reduce the risks to as low as reasonably practicable (see also Leaflet 1 and Leaflet 2). Where it is possible those managing the procurement are to produce a generic risk assessment, this is to be carried out and made available to users. Risk assessment for users 10 A risk assessment is to be carried out by the unit or establishment in consultation with the Radiation Protection Adviser (RPA) prior to any new activity involving X-ray fluoroscopes. This risk assessment is to take into account information from the manufacturer, the generic risk assessment carried out at the procurement stage (if available) and take into account the recommended solutions to reduce risk provided by the acquisition process and the local conditions of use. Details of the form of the risk assessment and the actions to be taken arising from it are described in Leaflet 2. Risk assessments are to be reviewed as detailed in Leaflet 2. 11 The following are key inputs into the risk assessment: 11.1 Advice from the manufacturer or supplier and information from the IPT if applicable.

X-rays

11.2 RPA information and advice the Dstl ESD RPA may be able to provide detailed hazard and risk assessment information on the equipment.

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11.3 Radiation survey information estimated dose rates when operating and during maintenance (if carried out). 11.4 11.5 11.6 11.7 Planned systems of work and routine operation profile e.g. hours per day, per shift etc. Personnel access and occupancy of areas subject to levels of ionising radiation. Assessment of reasonably foreseeable fault conditions and resultant dose rates. Assessment of the impact of reasonably foreseeable accidents/incidents.

DESIGN OF POSTAL AND BAGGAGE FLUOROSCOPES 12 Non-medical fluoroscopes are normally to be designed such that the dose-rate on the external surface of the equipment or at any routinely accessible openings does not exceed 2.5 Sv h-1 so that the dose to any person does not exceed 1 mSv in a year. Where the equipment is used in a public place, this value is not to exceed 1 Sv h-1. 13 Automatic equipment, such as a conveyor belt security X-ray machine, where the production of Xrays is triggered by the presence of a parcel, are to be designed so that cutting the power to the conveyor belt will prevent X-ray production. An emergency stop button to isolate the power to the conveyor is also to be located at the entry and exit ports to the X-ray chamber and where appropriate, also at the control panel. 14 The fluoroscope is to, by design, or by the provision of safety devices, prevent anyone reaching inside it to an area where the dose-rate exceeds 7.5 Sv h-1. WARNING SIGNALS 15 A warning light is to be provided on the equipment to indicate when X-rays are being generated. For non-medical fluoroscopes in which the control panel is not within sight of the fluoroscope, an additional warning light is to be provided on the control panel. Notices are to be displayed to indicate the purpose of the warning lights. 16 All warning lights are to be tested on an annual basis and following any maintenance or repair. Records are to be kept of the tests to indicate the type of test carried out and when the next test is due INSTALLATION 17 The installer of the equipment has a number of duties imposed by IRR99, in particular: 17.1 They must carry out a critical examination of the way in which the equipment has been installed ensuring that safety features and warning devices operate correctly and that there is sufficient protection for persons from exposure to ionising radiation. 17.2 They must consult with their RPA or with the operators RPA with regard to the extent of the critical examination and in regard to the results of that examination 17.3 They must provide the radiation employer (the radiation employer being the operator of the fluoroscope e.g. the CO, Head of Establishment) with adequate information about proper use, testing and maintenance of the equipment. 18 The radiation employer must consult their RPA regarding the plans for installing the equipment in relation to engineering controls, design features, safety features and warning devices. They are also to consult the RPA regarding the acceptability of the test results of the critical examination and the requirements and results of any further commissioning tests or radiation surveys. 19 The radiation employer is to ensure that they understand the information provided by the manufacturer and installer and that a radiation survey is carried out prior to first use.

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20 The fluoroscope is not to be operated until any deficiencies identified in the initial inspection have been repaired by a suitably qualified person, and the fluoroscope has been re-inspected and monitored. MAINTENANCE 21 The radiation employer must ensure that engineering controls, design features, safety features and warning devices are properly maintained, examined and tested at suitable intervals (typically annually). The radiation employer is to arrange maintenance and testing in accordance with the manufacturers information, Leaflet 8 (Radiation Monitoring Instruments) and the advice of the RPA. 22 Records must be kept of the examinations and tests to identify if any faults were found, how they were rectified and when the next examination or test is due. 23 In many cases, it is permissible for employers to hand-over the area in which the equipment is housed to maintenance staff. In this case, the radiation employer is to ensure that suitably competent staff will undertake the maintenance/repair and that it is clear that the maintenance employer has control of the area the maintainer is to then operate to their own local orders. If this arrangement is inappropriate, then the radiation employer retains all safety responsibilities and must ensure that local orders are adequate to cover the maintenance task and that appropriate training of their own supervisory staff has been carried out. If the maintenance requires area designation, then an RPA must be consulted. OPERATING INSTRUCTIONS 24 A set of operating instructions is to be drawn up by the unit or establishment for each fluoroscope. Each operator is to comply with the operating instructions. LOCAL ORDERS FOR RADIATION SAFETY 25 The requirements for radiation safety are to be drawn up in accordance with Leaflet 16. The local orders are to include the requirements for periodic radiation surveys, as advised by the manufacturer or RPA, and are also to specify dose rate action levels. RPA advice is to be sought regarding the action levels and the action to be taken if they are exceeded. SECURITY 26 The equipment is to be kept locked and secured when not in use and the key kept in safe custody; the names of persons authorised to draw the key are to be recorded. GENERAL SAFETY REQUIREMENTS 27 Where reasonably practicable, fluoroscopes are to be fitted with interlocks to prevent access to the examination compartment during X-ray emission. 28 The condition of lead impregnated rubber curtains is to be checked regularly. curtains are to be repaired or replaced immediately. Any damaged

29 Non-medical fluoroscopes are to have viewing facilities which do not permit direct viewing of the fluoroscopy screen. 30 Fluorescent screens onto which the primary X-ray beam is directed are only to be viewed indirectly by the use of mirrors or other means to prevent exposure of the observer to the useful beam. 31 No alterations or additions are to be made to fluoroscopes after installation except by qualified authorised staff.

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LEGAL AND MOD MANDATORY REQUIREMENTS 32 Table 2 summarises the legal and MOD mandatory ionising radiation requirements for postal and baggage fluoroscopes. In cases of doubt, the RPA is to be consulted for advice. Table 2 Legal and MOD mandatory requirements for work with postal and baggage fluoroscopes Requirement Applicable Comments Not required for electrical equipment producing X-rays for the purpose of security scanning. Work involving postal and baggage fluoroscopes must be notified to HSE in accordance with Leaflet 3. Not required for postal and baggage fluoroscopes. A risk assessment is required to identify radiation dose rates and control measures at accessible positions during operation. Reasonably foreseeable fault conditions during operation are also to be considered. The risk assessment must also cover maintenance operations if these are to be supervised by the employer operating the equipment. Observe manufacturer/equipment instruction and guidance. Ensure exposure of all personnel is as low as reasonably practicable (ALARP). Set dose investigation levels. Not required. Where the equipment includes engineering controls, design features, safety features and warning devices provided to restrict exposure (e.g. shielding, safety interlocks, warning signals), these devices must be properly inspected, tested and maintained at suitable intervals usually in accordance with the information provided by the manufacturer. Related leaflet*

HSE Authorisation

HSE Notification

EA Notification**

Risk assessment

Restriction of exposure

PPE

Maintenance of engineering controls

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Table 2 Legal and MOD mandatory requirements for work with postal and baggage fluoroscopes (continued) Requirement Applicable Comments Required where the risk assessment identifies any immediate measures to be taken in the event of reasonably foreseeable faults, accidents or incidents leading to enhanced exposure levels. Equipment is normally to be designed such that dose rates in the working area are ALARP and area designation is unnecessary. Designated areas may be required for some equipment during certain maintenance tasks. Normally, a controlled area will be necessary where the dose rate in the area exceeds 7.5 Sv h-1 and a supervised area if any person could receive more than 1 mSv in a year - the RPA is always to be consulted regarding area designation and the associated control measures. Not normally required as operators are most unlikely to receive annual dose levels in excess of 6 mSv whole body (or other levels specified in Annex E to Leaflet 4). Local orders are to specify the radiation surveys to be conducted, at regular intervals, around the equipment. Frequency of monitoring is to be that advised by the manufacturer or RPA. Local orders are to include provision for monitoring following any accident or incident that could have caused damage to the equipment and following maintenance or repair. RPA advice must be sought on the suitability and calibration requirements for survey instruments and regarding appropriate action levels. Persons employed as operators are to be formally trained in its use the training must include appropriate radiation safety aspects. Documentary evidence of the training is also to be retained. Personnel carrying out radiation monitoring duties must also be suitably trained. Information must be provided to other persons, such as couriers, who may need to spend time in the vicinity of the equipment so that they are aware of the measures to be taken for restriction of exposure and the content of local orders relevant to their duties. Related leaflet*

Contingency plans

40

Designated areas

(but see comment)

Designation of personnel

(but see comment)

4, 6

Monitoring

4, 8, 16

Training for users

15, 16

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Table 2 Legal and MOD mandatory requirements for work with postal and baggage fluoroscopes (continued) Requirement Local orders Applicable Comments See Leaflet 16 for guidance. RPS not required except for areas required to be designated as controlled or supervised. Where an RPS is not required, a local workplace supervisor needs to be appointed to ensure that local orders for radiation safety are followed. Not applicable. Not applicable. Not applicable. Unless advised by the RPA, personnel do not require personal dosimetry as their doses are likely to be much less than 1 mSv per year. An unusual radiation event or overexposure is to be reported in accordance with the procedures in Leaflet 14. Radiological controls are not applicable to the transport of X-ray generators. Postal and baggage fluoroscopes are to be marked on the outside with a radiation warning sign. See Leaflet 11 Radiological controls are not applicable to electrical equipment. Disposal of redundant items
(but see comment)

Related leaflet* 16

Appointed person

39

Storage Accounting Leak testing

Personal dosimetry

(but see comment)

Reporting procedures

14

Transport

Marking

Sale/Transfer

11

Radiation warning signs are to be removed if the X-ray tube has been removed and the equipment earmarked for disposal has been permanently disabled.

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 25 DENTAL X-RAY MACHINES CONTENTS Para 1 2 3 4 5 6 Table 1 2 Annex A B NOTE The instructions in the leaflet apply to MOD units and establishments; they do not apply within Ministry of Defence Hospital Units where responsibility for health and safety in general and radiation safety in the particular context of this publication, rests with the Chief Executive of the NHS Trust concerned. SCOPE 1 This leaflet describes the requirements for keeping and use of dental X-ray machines. Summaries of the radiation risks and regulatory requirements for such equipment are included in the annexes of this leaflet. STATUTORY REQUIREMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974, and the Management of Health and Safety Regulations 1999, the following specific legislation applies: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Ionising Radiation (Medical Exposures) Regulations 2000 (IRMER2000) (apply directly). Specific Requirements and Recommendations for Dental X-ray Machines Content of Employers Written Procedures for Dental Exposures Scope Statutory Requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Employees Page Hazard .............................................................................................................................................2 Legal and MOD Mandatory Requirements......................................................................................3

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DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. In regard to equipment used for dental exposure, the CO must ensure that such equipment is designed, installed and maintained so far as is reasonably practicable to restrict the exposure of any person undergoing a dental exposure to that which is compatible with the intended purpose. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure that they are familiar with the specific radiation hazards at their unit or establishment and that adequate radiation protection arrangements are made to minimise the radiation hazard. Radiation Protection Supervisor (RPS) 5 The RPS is to ensure that X-ray equipment is correctly used and reporting procedures for incidents are followed. The RPS is normally the practice manager or senior dental officer within the department. Employees 6 It is the responsibility of all employees to ensure that X-ray equipment is used correctly and not deliberately misused or interfered with. Any incidents are to be reported appropriately (see Leaflet 14). HAZARD Table 1 Hazard Radiation type Alpha Beta Direct Bremsstrahlung A dose rate of approximately 5 mGy s-1 is produced at the end of the collimator on a typical Gendex intraoral machine. Emitted Comments

Gamma X-rays Neutrons

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LEGAL AND MOD MANDATORY REQUIREMENTS Table 2 Legal and MOD Mandatory Requirements Requirement HSE authorisation HSE notification EA notification** Risk assessment Restriction of exposure PPE Maintenance of radiation engineering controls Contingency plans Designated areas Monitoring Training for users Local orders Appointed person Storage Accounting Leak testing Personal dosimetry Whole body dosimeters are worn by staff routinely involved in radiography procedures. See Leaflet 14 and Annex A of Leaflet 26. 6 Comply with local orders see Annexes of Leaflet 16. A radiation safety assessment of new and refurbished surgeries and X-ray rooms by the RPA is required. Not normally used. For example, power-on warning light, exposure warning light, automatic exposure termination at end of set time and on release of exposure button. See Leaflet 40. See Annex A of Leaflet 25 and Leaflet 4. See Annex A of Leaflet 25 for IRMER training requirements and Leaflet 15 for RPS and user training requirements. See Annexes of Leaflet 16 for guidance. RPS required. Recorded on Dstl Annual Holdings Return (copy retained for 1 year) and for IRMER purposes, see Annex A of Leaflet 25. Applicable Comments Related leaflet* 3 2 4, 16

4 40 4

15 16 3

Reporting procedures 14 Transport Sale/transfer See Leaflet 11 11 Return to stores. 12 Disposal Ionising Radiation (Medical Exposure) See Annexes of Leaflet 25. Regulations (IRMER) 2000 *JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 25 ANNEX A SPECIFIC REQUIREMENTS AND RECOMMENDATIONS FOR DENTAL X-RAY MACHINES CONTENTS Para 1 2 3 4 7 8 9 10 11 12 13 14 15 Radiation safety assessment for new or refurbished facilities Acceptance testing of new X-ray equipment Critical examination and design of new X-ray facilities Controlled and supervised areas Exposure protocols Practitioners, operators and referrers Training Employers procedures Referral criteria Quality assurance and patient dose assessment Protection of patients X-ray equipment records Reporting procedures for patient doses much greater than intended

REFERENCES A B C D E F Medical and Dental Guidance Notes, Prepared by Institute of Physics and Engineering in Medicine, 2002. Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment, British Dental Association et al, 2001. Ionising Radiation (Medical Exposure) Regulations 2000. Selection Criteria for Dental Radiography, Faculty of General Dental Practitioners (UK) Good Practice Guidelines. Defence Dental Service, Safety, Health, Environment and Fire (SHEF) Handbook. Institute of Physics and Engineering in Medicine (IPEM) Report 91, Recommended Standards for the Routine Performance Testing of Diagnostic X-ray Imaging Systems.

RADIATION SAFETY ASSESSMENT FOR NEW OR REFURBISHED FACILITIES 1 For new or refurbished dental X-ray facilities the RPA is to be consulted at the design stage to ensure that the design of the facility, including any shielding required, is sufficient to keep doses to personnel as low as reasonably practicable. ACCEPTANCE TESTING OF NEW X-RAY EQUIPMENT 2 Acceptance tests are to be carried out on all newly installed dental X-ray equipment and when an X-ray tube is replaced as advised by the RPA to ensure that radiological functions are satisfactory and to specification. 2.1 Dental X-ray machines are to be designed, constructed and installed in accordance with British Standard 60601. Guidance on design, construction and installation of dental X-ray machines is given in References A and B. CRITICAL EXAMINATION AND DESIGN OF NEW X-RAY FACILITIES 3 A critical examination including an assessment of the adequacy of room shielding is to be carried out on all new or structurally modified dental X-ray facilities prior to being brought into routine use as advised by the RPA. Guidance on design of dental X-ray facilities is given in References A and B.

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CONTROLLED AND SUPERVISED AREAS 4 General requirements relating to controlled and supervised areas are provided in Leaflet 4. For specialist techniques, such as cephalometry, guidance is to be sought from the RPA. 5 A dental surgery or X-ray room need not be demarcated as a controlled area where all of the following conditions apply: 5.1 A single intra-oral dental X-ray equipment or dental pantomograph is the only equipment operated in the examination room at any one time. 5.2 The workload does not exceed in any week 100 single X-ray exposures or 50 panoramic examinations. 5.3 5.4 The equipment is of sound construction and properly maintained. The operator can see any person within the vicinity of the controlled area defined as: 5.4.1 Within the primary beam until it has been sufficiently attenuated by distance or by absorption, and 5.4.2 Within 2m of the X-ray tube or the patients head in any other direction, or unless at a lesser distance, the radiation has been adequately absorbed. 5.5 The X-ray equipment can be quickly de-energised from the normal operating position.

6 Radiation warning signs incorporating the radiation trefoil warning symbol and wording X-rays are to be posted on entry doors to dental surgeries and dedicated X-ray rooms containing installed X-ray sets, together with the name and contact number of the RPS. EXPOSURE PROTOCOLS 7 Where pre-set exposure times are not programmed into the X-ray controller, written protocols must be in place for each type of standard radiological practice for each piece of equipment. This will involve noting the exposure time selected for different intraoral examinations on Secondent-type controllers and, for dental pantomographs, the exposure factors and Automatic Exposure Control (AEC) use as appropriate. These are to be recorded in the form of an exposure chart and signed and dated by the RPS. 7.1 A record of the type of exposure or exposure factors used must be made in each patients notes. PRACTITIONERS, OPERATORS AND REFERRERS 8 Reference C requires that each individual dental exposure is justified by an Ionising Radiation (Medical Exposure) Regulations (IRMER) practitioner and any practical aspect, including film processing, associated with the exposure carried out by an IRMER operator. 8.1 Requests for a radiological examination are initiated by the referrer i.e. any registered medical or dental practitioner or other health professional who is entitled to refer individuals for dental exposure to a practitioner. 8.2 The dental practitioner is normally the IRMER practitioner and may simultaneously fulfil the roles of referrer, practitioner and operator. TRAINING 9 Adequate training is required for IRMER practitioners and operators. 9.1 In most circumstances, adequate training, as required by Reference C, is given during professional training or a MOD recognised training course, i.e. the DDS Spec Rad course. Leaflet 25 Annex A Page 2

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9.2 Adequate training comprises appropriate theoretical knowledge of elements as detailed in Schedule 2 of Reference C, together with relevant practical experience, mentoring and continuing professional training. 9.3 Each establishment or unit is to maintain a register of adequate training for IRMER practitioners and operators providing details and dates of adequate training undertaken. EMPLOYERS PROCEDURES 10 Reference C requires that there are written standard operating procedures for patient protection for medical exposures. The written procedures are to include the matters set out at Annex B, where appropriate. Procedures for work in DDS dental clinics are provided at Reference D. The regulations also require the employer to ensure that a medical physics expert is involved in medical exposures as appropriate, e.g. measurement and optimisation of patient dose. Guidance on the medical physics expert is given in References A and B, further information may also be obtained from the RPA. REFERRAL CRITERIA 11 Employers have a duty to define referral criteria for dental exposures, including radiation doses, to all those acting as referrer. Guidance on referral criteria is given at References D and E. QUALITY ASSURANCE AND PATIENT DOSE ASSESSMENT 12 All units and establishments are to operate a quality assurance (QA) programme for dental X-ray and film processing equipment. The QA programme is to include routine testing carried out by department staff and testing by the RPA every 3 years. Guidance on such testing is given in Reference F. 12.1 Routine testing comprises a radiographic image quality test prior to radiography or on a daily basis and recording reasons for radiographs assessed as less than perfect. It should also include a routine check of the condition of film processing equipment. PROTECTION OF PATIENTS 13 Radiation doses to patients are to be as low as reasonably practicable in accordance with the intended purpose. 13.1 If the patient is a woman who is or who may be pregnant and where the X-ray beam is directed towards the abdomen a protective apron of at least 0.25mm lead equivalence is to be used to protect the abdomen. 13.2 The patient record is to be annotated to confirm that each exposure has been justified and that evaluation of each radiograph has taken place. X-RAY EQUIPMENT RECORDS 14 All units and establishments are to maintain the following records for X-ray equipment: 14.1 An inventory of equipment including the name of manufacturer, model number, serial number or other unique identifier, year of manufacture and year of installation. 14.2 A record of all equipment defects, maintenance and QA tests.

REPORTING PROCEDURES FOR PATIENT DOSES MUCH GREATER THAN INTENDED 15 General requirements for the reporting and investigation of radiation occurrences are given in Leaflet 14. 15.1 Where as a result of a defect or malfunction in equipment, a person undergoing a medical exposure receives a radiation dose that is much greater than intended, the RSO or RPS is to be informed. Actions are then to be taken in accordance with Leaflet 14 and the RPA informed. Jan 2008 Leaflet 25 Annex A Page 3

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15.2 Where a significant exposure, resulting in a dose much greater than intended, is received by the patient as the result of operator error or equipment malfunction, advice on appropriate action is to be obtained from the RPA. A dose much greater than intended for dental exposure is typically 20 times (or greater) than the intended dose.

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LEAFLET 25 ANNEX B CONTENT OF EMPLOYERS WRITTEN PROCEDURES FOR DENTAL EXPOSURES

1 The written procedures for medical exposures should be produced to cover the following matters where appropriate: 1.1 1.2 1.3 Procedures to correctly identify individuals to be exposed to ionising radiation. Procedures to identify individuals entitled to act as referrer, practitioner or operator. Procedures to be observed in the case of medico legal exposures.

1.4 Procedures for making enquiries of women of child bearing age to establish whether the individual is pregnant. 1.5 1.6 Procedures for the following of quality assurance programmes. Procedures for the assessment of patient dose.

1.7 Procedures for the use of diagnostic reference levels for radiodiagnostic examinations, specifying that these are expected not to be exceeded for standard procedures when good and normal practice regarding diagnostic and technical performance is applied. 1.8 Procedures for the use of dose constraints established by the employer for biomedical and medical research programmes where no direct medical benefit for the individual is expected from the exposure. 1.9 Procedures for carrying out and recording of an evaluation for each medical exposure including factors relevant to the patient dose. 1.10 Procedures to ensure that the probability and magnitude of accidental or unintended doses to patients from radiological practices is reduced so far as reasonably practicable. 2 The following procedures should also be established: 2.1 For ensuring that all practitioners and operators who are contracted to work in the radiological departments are appropriately trained and undertake continuing education and training. 2.2 For keeping records of training for practitioners and operators.

2.3 For the reporting of all incidents involving a medical exposure (excluding equipment defect) which has resulted in a patient dose much greater than intended. 2.4 2.5 For ensuring that all exposures are justified prior to a medical exposure taking place. For ensuring that clinical audit is carried out in accordance with national procedures.

2.6 Written protocols for every type of standard radiological practice for each equipment, e.g., providing an exposure factors chart for each equipment. 2.7 Recommendations concerning referral criteria for medical exposures including radiation doses, and shall ensure that these are available to the referrer.

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LEAFLET 26 MEDICAL DIAGNOSTIC X-RAY MACHINES CONTENTS Para 1 2 3 4 5 6 7 Table 1 2 Annex A B Specific requirements and recommendations for medical diagnostic x-ray machines and fluoroscopes Content of employers written procedures for medical exposures Scope Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Practitioners, operators and referrers Employees Page Hazard .............................................................................................................................................2 Legal and MOD mandatory requirements .......................................................................................3

SCOPE 1 This leaflet covers medical diagnostic X-ray machines (including fluoroscopes). The following information describes the requirements for keeping and using such equipment. Summaries of the radiation risks and regulatory requirements for such equipment are included in the Annexes of this leaflet. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 2 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Ionising Radiation (Medical Exposures) Regulations 2000 (IRMER2000) (apply directly).

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DUTIES Commanding Officer (CO) and Head of Establishment 3 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. In regard to equipment used for medical exposure, it must be ensured that such equipment is designed, installed and maintained so far as is reasonably practicable to restrict the exposure of any person undergoing a medical exposure to the extent that this is compatible with the intended purpose. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 4 The Radiation Safety Officer (RSO) is to ensure that they are familiar with the specific radiation hazards at their unit or establishment and that adequate radiation protection arrangements are made to minimise the radiation hazard including the drawing up of local orders for radiation safety and the issue of local orders, instructions and procedures. Radiation Protection Supervisor (RPS) 5 The RPS is to ensure that X-ray equipment is correctly used in accordance with local orders for radiation safety including local orders, instructions and procedures. The RPS is also to ensure that reporting procedures for any incidents are followed (see Annex A to this leaflet and also Leaflet 14). The RPS is normally the superintendent radiographer within the department. Practitioners, operators and referrers 6 Practitioners, operators and referrers have specific duties under IRMER2000, further information on these duties is contained within Annex A. Employees 7 It is the responsibility of all employees to ensure that X-ray equipment and personal protective equipment is used correctly and not deliberately misused or interfered with and that work is carried out in accordance with local orders, instructions and procedures. Any incidents are to be immediately reported to the RPS. HAZARD Table 1 Hazard Radiation type Alpha Beta Direct Bremsstrahlung X-ray sets generate an in beam exposure hazard. In addition, radiation from X-ray head leakage and scatter from the beam may affect areas around the X-ray head and beam. Emitted Comments

Gamma X-rays Neutrons

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LEGAL AND MOD MANDATORY REQUIREMENTS Table 2 Legal and MOD mandatory requirements Requirement HSE authorisation HSE notification EA notification** Risk assessment Restriction of exposure PPE Maintenance of radiation engineering controls Contingency plans Designated areas Monitoring Training for users See Annex A of Leaflet 26 for IRMER 2000 training requirements and Leaflet 15 for RPS and user training requirements. See Leaflet 16 for guidance on the requirements of local orders and the requirements of IRR 99 for local rules. RPS required Recorded on Dstl Annual Holdings Return (copy retained for 1 year) and for IRMER 2000 purposes, see Annex A of Leaflet 26. Whole body dosimeters are to be worn by staff routinely involved with radiology procedures. It may also be necessary to monitor doses to the extremities/thyroid/eye depending on the type and amount of X-ray work being carried out. See Leaflet 14 and Annex A of this leaflet for further guidance on the reporting of incidents. Return to stores. See Leaflet 11 See Annexes of this leaflet. 15 Applicable Comments Related leaflet* 3 2 Restriction of exposure is addressed in Leaflet 4 and local orders in Leaflet 16. PPE is covered in general in Leaflet 4. See also Annex A of this leaflet for specific guidance for medical PPE. Tests for: mains on and exposure indication, automatic exposure termination at end of set time and on release of exposure button; room warning lights. See Leaflet 40 Designated areas are required and are covered in general in Leaflet 4. See Annex A of this leaflet for detailed guidance including requirements for mobile/field hospital radiography. 4, 16 4

4 40 4

Local orders Appointed person Storage Accounting Leak testing

16 3

Personal dosimetry

Reporting procedures Transport Disposal Sale/Transfer Ionising Radiation (Medical Exposure) Regulations (IRMER 2000)

14 12 11 -

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 26 ANNEX A SPECIFIC REQUIREMENTS AND RECOMMENDATIONS FOR USE OF MEDICAL DIAGNOSTIC X-RAY MACHINES CONTENTS Para 1 2 5 6 9 12 15 18 19 20 22 25 27 28 30 Radiation safety assessment for new or refurbished facilities Acceptance testing of new x-ray equipment Critical examination and design of new x-ray facilities Controlled and supervised areas Exposure protocols Practitioners, operators and referrers Training Employers procedures for patient protection Referral criteria Quality assurance and patient dose assessment Personal protective equipment Protection of patients X-ray equipment records Comforter and carer Reporting procedures including those for patient doses much greater than intended

REFERENCES A Medical and Dental Guidance Notes, Prepared by Institute of Physics and Engineering in Medicine, 2002 ISBN 1 903613 09 4. B Ionising Radiation (Medical Exposure) Regulations 2000.

C Making the Best Use of a Department of Clinical Radiology, Guidelines for Doctors, Fifth Edition, BFCR(03)3, Royal College of Radiologists. D Institute of Physics and Engineering in Medicine (IPEM) Report 91, Recommended Standards for the Routine Performance Testing of Diagnostic X-ray Imaging Systems 2005. E NRPB-W14, Doses to Patients from Medical X-ray Examinations in the UK 2000 Review.

RADIATION SAFETY ASSESSMENT FOR NEW OR REFURBISHED FACILITIES 1 For new or refurbished X-ray facilities the RPA is to be consulted at the design stage to ensure that design of the facility, including any shielding required, is sufficient to keep doses to personnel as low as reasonably practicable. General guidance on design of radiology facilities is given in Reference A. ACCEPTANCE TESTING OF NEW X-RAY EQUIPMENT 2 Acceptance tests are to be carried out as advised by the RPA on all newly installed medical X-ray equipment and when an X-ray tube is replaced to ensure that radiological functions are satisfactory and to specification. 3 Medical X-ray machines are to be designed, constructed and installed in accordance with British Standard 60601. Guidance on design, construction and installation of medical X-ray machines is given in Reference A.

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All new installed X-ray equipment is to be fitted with a dose area product (DAP) meter.

CRITICAL EXAMINATION AND DESIGN OF NEW X-RAY FACILITIES 5 A critical radiation safety examination including an assessment of the adequacy of room shielding is to be carried out as advised by the RPA on all new or structurally modified X-ray rooms prior to being brought into routine use. CONTROLLED AND SUPERVISED AREAS 6 General requirements relating to controlled and supervised areas are contained in Leaflet 4.

7 A dedicated X-ray room containing installed X-ray equipment is designated as a controlled radiation area during exposures. 8 For mobile X-ray machines, the controlled radiation area extends in the direction of the X-ray beam until the beam is sufficiently attenuated by distance or shielding (e.g. solid floor or wall) and out to 3 metres in all other directions. EXPOSURE PROTOCOLS 9 Written protocols are to be in place for each type of standard radiological practice for each piece of equipment. For radiography equipment this will involve noting exposure factors, focus to film distance, grid use and automatic exposure control (AEC) use as appropriate for each type of examination. For fluoroscopy equipment the protocol is to include, e.g. collimation, magnification and dose settings. Where exposure settings are programmed into the console, these are to match the values in the exposure chart. Exposure settings are normally recorded in the form of an exposure chart, which is to be signed and dated by a responsible person. 10 After each examination, a record of exposure factors, DAP meter reading or exposure time is to be made in the patients notes. 11 In the case of fluoroscopic devices, viewing facilities are to be provided which do not permit direct vision of the fluoroscopy screen. PRACTITIONERS, OPERATORS AND REFERRERS 12 Reference B requires that each individual medical exposure is justified by an IRMER practitioner and any practical aspect associated with the exposure carried out by an IRMER operator. 13 In MOD medical facilities, the role of IRMER practitioner and responsibility for justifying medical Xray exposures normally lies with DCA Radiology. Justification is effected through radiography protocols and guidelines issued by DCA Radiology and implemented by authorisation of the radiographer for each medical exposure. 14 Requests for a radiological examination are initiated by the referrer i.e. any registered medical or dental practitioner or other health professional who is entitled to refer individuals for medical exposure to an IRMER practitioner. TRAINING 15 Adequate training in the radiation protection of patients, as defined at Reference B, is required for IRMER practitioners and IRMER operators. Adequate training is obtained during professional training and qualification, or a MOD recognised course together with practical experience, mentoring and continuing education and training as appropriate. 16 In most circumstances, adequate training will be met by satisfying the requirements of the appropriate professional bodies, i.e. the Royal College of Radiologists and the College of Radiographers.

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17 Each establishment or unit is to maintain a register of adequate training for IRMER practitioners and IRMER operators providing details and dates of training undertaken. EMPLOYERS PROCEDURES FOR PATIENT PROTECTION 18 Written standard operating procedures for the radiation protection of patients are to be provided. The written procedures are to include the matters set out at Annex B and are to be signed by the Head of Establishment. REFERRAL CRITERIA 19 Referral criteria for medical exposures, including information on radiation doses to patients, are to be made available to those health professionals who refer patients for radiological examination. In MOD medical X-ray departments, referral criteria normally take the form of the RCR Guidelines at Reference C. QUALITY ASSURANCE AND PATIENT DOSE ASSESSMENT 20 All units and establishments are to operate a quality assurance (QA) programme for medical X-ray, film processing and CR equipment. The QA programme is to include routine equipment tests carried out by department staff and annual/biennial tests by medical physicists. Guidance on QA tests is provided at Reference D or may be obtained from the RPA. 21 The QA programme is to include an assessment of radiation doses received by patients from different types of examination. This will normally be carried out by the RPA/physicist on the basis of exposure information provided by the department. Patient doses will be used for comparison with diagnostic reference levels (DRLs) such as the national DRLs available at Reference E. PERSONAL PROTECTIVE EQUIPMENT 22 X-ray personal protective equipment (PPE) for staff includes aprons, gloves and thyroid shields incorporating lead to reduce radiation exposure during X-ray examinations. This PPE is not designed to provide protection from the primary beam, but only from scattered radiation and that transmitted through the patient. 23 Guidance on specific requirements for PPE is given in Reference A.

24 Each piece of X-ray PPE is to have its own identifying number. Gloves and aprons are to be visually examined at 3-monthly intervals and radiographically examined at least every 12 months for the determination of deterioration or reduction in shielding effectiveness. Records of examinations are to be kept for 2 years. PROTECTION OF PATIENTS 25 Radiation doses to patients are to be as low as reasonably practicable in accordance with the intended clinical purpose. 26 Notices are to be displayed requesting female patients to inform radiographers if they suspect or know that they are pregnant. X-RAY EQUIPMENT RECORDS 27 All units and establishments are to maintain the following records for X-ray equipment: 27.1 An inventory of equipment including the name of manufacturer, model number, serial number or other unique identifier, year of manufacture and year of installation. 27.2 A record of all equipment defects, maintenance and QA tests.

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COMFORTER AND CARER 28 Where it is necessary for a patient to be supported during a medical exposure, a log of persons acting as supporters is to be maintained. 29 The supporter is preferably to be an adult relative or friend of the patient and must not be pregnant. The supporter must be adequately protected from exposure to X-rays during the examination. REPORTING PROCEDURES INCLUDING THOSE FOR PATIENT DOSES MUCH GREATER THAN INTENDED 30 Requirements for the reporting and investigation of radiation accidents, incidents and occurrences are given in Leaflet 14. 31 Reporting procedures for a person undergoing a medical exposure who receives a radiation dose that is much greater than intended as a result of a defect or malfunction in equipment are given at Leaflet 14 Annex G. 32 Reporting procedures for a person undergoing a medical exposure who receives a radiation dose that is much greater than intended as a result of clinical error are equivalent to those given at Leaflet 14 Annex G except that the external body to be notified is the Department of Health (not the Health and Safety Executive) .

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LEAFLET 26 ANNEX B CONTENT OF EMPLOYERS WRITTEN PROCEDURES FOR MEDICAL EXPOSURES

1 The written procedures for medical exposures are to be produced to cover the following matters where appropriate: 1.1 1.2 1.3 To correctly identify individuals to be exposed to ionising radiation. To identify individuals entitled to act as referrer, practitioner and operator. To be observed in the case of medico legal exposures.

1.4 For making enquiries of women of child bearing age to establish whether the individual is pregnant. 1.5 1.6 For the following of quality assurance programmes. For the assessment of patient dose.

1.7 For the use of diagnostic reference levels for radiodiagnostic examinations, specifying that these are expected not to be exceeded for standard procedures when good and normal practice regarding diagnostic and technical performance is applied. 1.8 For the use of dose constraints established by the employer for biomedical and medical research programmes where no direct medical benefit for the individual is expected from the exposure. 1.9 For carrying out and recording of an evaluation for each medical exposure including factors relevant to the patient dose. 1.10 To ensure that the probability and magnitude of accidental or unintended doses to patients from radiological practices is reduced so far as reasonably practicable. 2 The following procedures are also to be established: 2.1 For ensuring that all practitioners and operators who are contracted to work in the radiology department are appropriately trained and undertake continuing education and training. 2.2 For keeping records of training for practitioners and operators.

2.3 For the reporting of incidents involving a medical exposure (excluding equipment defect) which has resulted in a patient dose much greater than intended. 2.4 2.5 For ensuring that all exposures are justified prior to a medical exposure taking place. For ensuring that clinical audit is carried out in accordance with national procedures.

2.6 For providing written protocols for every type of standard radiological practice for each equipment, e.g. an exposure factors chart. 2.7 For providing recommendations concerning referral criteria for medical exposures including radiation doses, and shall ensure that these are available to the referrer.

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LEAFLET 27 VETERINARY DIAGNOSTIC X-RAY MACHINES CONTENTS Para 1 3 4 5 6 7 Scope Statutory requirements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Employees

Table 1 2 Annex A SCOPE

Page Hazard .............................................................................................................................................2 Legal and MOD mandatory requirements .......................................................................................3

Specific requirements and recommendations for use of veterinary diagnostic x-ray machines

1 This leaflet describes the requirements for keeping and using veterinary diagnostic X-ray machines (including fluoroscopes). A summary of the associated radiation risks and regulatory requirements for such equipments are included in Annex A. 2 It should be noted that where veterinary units use standard dental X-ray equipment for animal dental radiography the worker safety requirements of Leaflet 25 are to be followed in addition to the requirements of this leaflet. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO).

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Radiation Safety Officer (RSO) 5 The Radiation Safety Officer (RSO) is to ensure that they are familiar with the specific radiation hazards at the establishment and that adequate radiation protection arrangements are made to minimise the radiation hazard including the drawing up of local orders for radiation safety and the issue of instructions and procedures. Radiation Protection Supervisor (RPS) 6 The RPS is to ensure that X-ray equipment is correctly used in accordance with local orders for radiation safety including instructions and procedures. The RPS is also to ensure that reporting procedures for any incidents are followed (see Leaflet 14). The RPS is normally the veterinary surgeon within the department. Employees 7 It is the responsibility of all employees to ensure that X-ray equipment and personal protective equipment is used correctly and not deliberately misused or interfered with and that work is carried out in accordance with local orders, instructions and procedures. Any incidents are to be immediately reported to the RPS. HAZARD Table 1 Hazard Radiation type Alpha Beta Direct Bremsstrahlung X-ray sets generate a significant in beam exposure hazard. In addition, radiation from X-ray head leakage and scatter from the beam may affect areas around the X-ray head and beam. Emitted Comments

Gamma X-rays Neutrons

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LEGAL AND MOD MANDATORY REQUIREMENTS Table 2 Legal and MOD mandatory requirements Requirement HSE authorisation HSE notification EA notification** Risk assessment Restriction of exposure Restriction of exposure is addressed in Leaflet 4 and local orders in Leaflet 16. A radiation safety assessment of new and refurbished X-ray rooms and facilities by the RPA is required. PPE is covered in general in Leaflet 4. See also Annex A of this leaflet for specific guidance for use of veterinary radiography PPE. Tests for: mains on and exposure indication, automatic exposure termination at end of set time and on release of exposure button; room warning lights. See Leaflet 40. Designated areas are required and are covered in general in Leaflet 4. See Annex A of this leaflet for detailed guidance including requirements for radiography outside of an X-ray room. See Annex A of this leaflet and Leaflet 15 for RPS and user training requirements. See Leaflet 16 for guidance on the requirements of local orders and the requirements of IRR 99 for local rules. RPS required. Recorded on Dstl Annual Holdings Return (copy retained for 1 year). Whole body dosimeters are to be worn by staff routinely involved with radiology procedures. It may also be necessary to monitor doses to the extremities/thyroid/eye depending on the type and amount of X-ray work being carried out. See Leaflet 14 for further guidance on the reporting of incidents. See Leaflet 11 Return to stores. Applicable Comments Related leaflet* 3 2 4, 16

PPE Maintenance of radiation engineering controls Contingency plans Designated areas Monitoring Training for users Local orders Appointed person Storage Accounting Leak testing

4 40 4

15 16 3 9

Personal dosimetry

Reporting procedures Transport Sale/transfer Disposal

14 11 12

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI).

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LEAFLET 27 ANNEX A SPECIFIC REQUIREMENTS AND RECOMMENDATIONS FOR USE OF VETERINARY DIAGNOSTIC X-RAY MACHINES CONTENTS Para

1 2 4 5 9 10 13 14 17 21 22 24 25 27

Radiation safety assessment for new or refurbished facilities Acceptance testing of new x-ray equipment Critical examination and design of new x-ray facilities Controlled and supervised areas Radiographic examination considerations Operation of veterinary X-ray machines Training and instruction Personal protective equipment Ancillary equipment X-ray equipment records Maintenance of veterinary X-ray equipment Quality assurance performance tests X-ray films, cassettes and film processing requirements Fluoroscopy

REFERENCE A Guidance Notes for the Safe Use of Ionising Radiations in Veterinary Practice, British Veterinary Association, June 2002.

RADIATION SAFETY ASSESSMENT FOR NEW OR REFURBISHED FACILITIES 1 For new or refurbished X-ray facilities the RPA is to be consulted at the design stage to ensure that the design of the facility, including any shielding required, is sufficient to keep doses to personnel as low as reasonably practicable. ACCEPTANCE TESTING OF NEW X-RAY EQUIPMENT 2 Acceptance tests are to be carried out as advised by the RPA on all newly installed veterinary Xray equipment and when an X-ray tube is replaced to ensure that radiological functions are satisfactory and to specification. 3 Guidance on design, construction and installation of veterinary X-ray machines is given in Reference A and from the RPA. CRITICAL EXAMINATION AND DESIGN OF NEW X-RAY FACILITIES 4 A critical radiation safety examination including an assessment of the adequacy of room shielding is to be carried out as advised by the RPA on all new or structurally modified X-ray rooms prior to being brought into routine use. CONTROLLED AND SUPERVISED AREAS 5 General requirements relating to controlled and supervised areas are provided in Leaflet 4.

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6 A dedicated X-ray room containing installed X-ray equipment is designated as a controlled radiation area during exposures. 7 For mobile X-ray machines, the controlled radiation area extends in the direction of the X-ray beam until the beam is sufficiently attenuated by distance or shielding (e.g. solid floor or wall) and out to 3 metres from the X-ray tube head and patient in all other directions. 8 For radiography outside an X-ray room, a controlled radiation area must be demarcated using cones, tapes or cordons displaying X-Ray Controlled Area: Do Not Enter signs in appropriate languages. The whole of the controlled area is to be visible to the radiographer. The X-ray set operator is to ensure that nobody is in the line of the useful beam taking into account the increasing spread of the beam with distance from the collimator. Special care is to be taken when the useful beam is horizontal. The X-ray beam is to be directed at an adequately shielded wall or at a suitable beam stop, such as a 2mm thickness of lead sheet. RADIOGRAPHIC EXAMINATION CONSIDERATIONS 9 Animal radiography is to be conducted only on the instructions of a Veterinary Officer, who will ensure that the radiographic examination is justified, be fully aware of radiation protection aspects, the radiographic procedures and techniques to be employed and that the radiation dose received by personnel present is minimised. OPERATION OF VETERINARY X-RAY MACHINES 10 Only suitably trained persons are to operate X-ray machines under the direction of a Veterinary Officer. 11 The person operating the X-ray machine is responsible for ensuring the radiation safety of persons present. Non-essential personnel are to be excluded from the radiography room or demarcated controlled radiation area during such examinations. The operator is to be fully aware of the radiation protection requirements and the radiographic techniques to be employed. 12 After use, X-ray machines are to be switched off at the mains and are to be secured against unauthorised use. TRAINING AND INSTRUCTION 13 Where veterinary assistants or other persons restrain animals, they are to be provided with appropriate protective clothing and properly instructed by the veterinary officer in the actions to be taken during radiographic examinations before the commencement of such examinations. PERSONAL PROTECTIVE EQUIPMENT 14 X-ray personal protective equipment (PPE) for staff includes aprons, gloves and thyroid shields incorporating lead to reduce radiation exposure during X-ray examinations. This PPE is not designed to provide protection from the primary beam, but only from scattered radiation and that transmitted through the patient. Guidance on specific requirements for the use and storage of PPE is given in Reference A. 15 Unless positioned behind protective screens all persons present are to wear protective aprons and stand at least two metres from the X-ray tube. No animal is to be manually restrained for radiographic examination unless there is a clinical reason for avoidance of sedation or anaesthesia. In such circumstances the individual restraining the animal is to ensure that no part of their body is in the primary beam. Where it is necessary for a person to place their hands close to the X-ray beam for manipulation, support or restraint of an animal, protective gloves together with lead rubber hand and forearm drapes are to be worn. Dosemeters issued by the Approved Dosimetry Service (ADS) are to be attached to each hand inside the glove to assess the radiation dose received.

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16 Each piece of X-ray PPE is to have its own identifying number. Gloves and aprons are to be visually examined at 3-monthly intervals and radiographically examined at least every 12 months for the determination of deterioration or reduction in shielding effectiveness. Records of examinations are to be kept for 2 years.

ANCILLARY EQUIPMENT 17 For fixed installations, a protective screen incorporating a lead-glass window and having a lead equivalence of not less than 1mm is to be provided at the control console. 18 For work without a purpose built table, a 1 mm thick sheet of lead larger than the maximum beam size employed is to be placed under the cassette or film in order to reduce scatter and protect feet and legs of anyone standing close to the table. 19 Special free standing or long handled cassette holders are to be available when it is necessary to support cassettes such as during horizontal beam radiography. 20 Suitable positioning aids, such as hoof blocks and lead-shot bags are to be available to assist patient positioning. X-RAY EQUIPMENT RECORDS 21 All units and establishments are to maintain the following records for X-ray equipment:

21.1 An inventory of equipment including the name of manufacturer, model number, serial number or other unique identifier, year of manufacture and year of installation. 21.2 A record of all equipment defects, maintenance and QA tests.

MAINTENANCE OF VETERINARY X-RAY EQUIPMENT 22 Veterinary X-ray sets are to be maintained in accordance with manufacturer's instructions, or as laid down by service maintenance departments. Servicing is to be carried out at least once a year. A record of defects and maintenance carried out on these units is to be kept by the establishment. The scattered radiation, leakage and radiation output of veterinary X-ray sets is to be examined during visits by the RPA. 23 Safety checks on the correct functioning of X-ray warning lights and automatic termination of X-ray exposures are to be carried out routinely. QUALITY ASSURANCE PERFORMANCE TESTS 24 The following QA tests are to be carried out: 24.1 24.2 24.3 Accuracy of alignment of the light beam delineator with the X-ray beam. Check of radiographic image quality using step wedge test tool. Analysis of undiagnostic radiographs.

X-RAY FILMS, CASSETTES AND FILM PROCESSING REQUIREMENTS 25 The fastest film and film intensifying screen combination compatible with a satisfactory radiograph is to be used. 26 To reduce the number of retakes of veterinary X-ray films arising from poor processing, the following darkroom requirements and processing instructions are specified:

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26.1 26.2

The darkroom must be light tight to prevent the fogging of X-ray films during development. The darkroom is to be kept in a clean condition to prevent film damage.

26.3 The darkroom is to be fitted with adequate safe lights normally consisting of a 25 Watt pearl bulb with a safe light filter which must be compatible with the films in use. 26.4 A warning light together with an explanatory notice are to be provided at the darkroom entrance, to indicate when film development is in progress. 26.5 Chemicals and films used in veterinary radiography are to be within date for use. Where manual processing is used, a programme of regular chemical changes is to be introduced in accordance with manufacturer's instructions, or at least every four weeks. A record of all changes of chemicals is to be kept. Film processing is to be carried out as a standardised procedure. 26.6 For manual processing basic darkroom equipment must include a suitable thermometer and accurate timer. 26.7 Routine checks are to be made on the processing system to detect any deterioration in the quality of radiographs. In the event of any deterioration in the film quality a review of the processing conditions is to be undertaken. If such a review does not resolve the problem then the X-ray machine must be checked. FLUOROSCOPY 27 Fluoroscopic examinations are only to be undertaken using specialist equipment and expertise. Fluoroscopic equipment is to include image intensification. The RPA is to be consulted prior to the use of fluoroscopic equipment in MOD veterinary facilities.

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LEAFLET 28 INDUSTRIAL RADIOGRAPHY INCLUDING ENCLOSURES, SITE AND UNDERWATER RADIOGRAPHY CONTENTS Para

1 4 5 6 7 8 9 10 11 13 16 18 19 20 Table 1 2 3 Annex A B C D E

Scope Statutory requirements and parallel arrangements Duties and appointments Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Adviser (RPA) Radiation Protection Supervisor (RPS) Employees Typical gamma and X-ray sources used in industrial radiography Risk assessments Training Legal and MOD mandatory requirements Radioactive sealed sources and their containers Physical security arrangements for high-activity sealed radioactive sources Contractors Page Data for typical gamma and X-ray sources used in industrial radiography within MOD .................3 Hazards associated with industrial radiography sources and X-ray generators .............................4 Legal and MOD mandatory requirements for industrial radiography ..............................................5

Requirements for radioactive sealed sources and their containers Guidance on radiation safety arrangements for industrial radiography in enclosures Radiation safety arrangements for site radiography Radiation safety arrangements for underwater radiography Radiation safety arrangements for industrial flash and pulsed X-ray equipment

SCOPE 1 Industrial radiography applications in MOD include: 1.1 Radiography in enclosures using both high activity sealed radioactive sources (HASS) and Xray generators. 1.2 Site radiography using high activity sealed sources or X-ray. 1.3 Underwater radiography using high activity sealed sources. 1.4 X-ray equipment used may be continuous, flash or pulsed. 2 This leaflet describes the radiological requirements for these types of radiography and includes the keeping, using and disposing of radioactive sources and equipment used in radiography. Summaries of the radiation risk and regulatory requirements are provided in the main body and the annexes of this leaflet. The RPA must always be consulted prior to any new activity or change in activity associated with industrial radiography. Leaflet 28 Page 1

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3 The scope of this leaflet does not extend to the use of accelerators. The scope of this leaflet does not extend to the use of X-ray or radioactive sources for instrument testing, security scanning nor does it extend to the use of X-ray for the processing of products, research, medical treatment, medical diagnosis or for dental and veterinary applications. STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 4 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR 99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). The High-activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly). Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (apply directly).

DUTIES AND APPOINTMENTS Commanding Officer (CO) and Head of Establishment 5 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 6 The Radiation Safety Officer (RSO) is to ensure that: On behalf of the CO, that a suitable RPA has been appointed and that the RPA is consulted prior to acquisition of radioactive sources or X-ray equipment and prior to any work commencing which involves industrial radiography each and every time. They are familiar with the specific radiation hazards of industrial radiography at their unit or establishment and that appropriate risk assessments are carried out before any new activity (or change in an existing activity) involving industrial radiography is commenced. Local orders include the specific requirements for the industrial radiography carried out. Staff are suitably qualified and experienced prior to them undertaking any industrial radiography work and that this process is documented. Staff competency is closely monitored, including the need for continuation training and recertification. Quality assurance requirements relating to industrial radiography are strictly adhered to, an audit programme is in place and audit recommendations are followed up and documented.

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Radiation Protection Adviser (RPA) 7 A suitable RPA must be appointed in writing and consulted prior to the acquisition of industrial radiography equipment and prior to commencing any industrial radiography work. For all units and establishments, other than those with a resident RPA, the RPA will normally be provided by the Dstl RPA Body. Radiation Protection Supervisor (RPS) 8 The RPS is to ensure that work is carried out in designated controlled areas in accordance with the local radiation safety orders for industrial radiography. These orders must include the requirements of local rules (as required by IRR 99) and the requirements of this leaflet. Employees 9 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that industrial radiography work is carried out safely. Regulations also require employees to comply with any reasonable requirement in regard to the following: 9.1 Their dose assessment. 9.2 Their medical surveillance. 9.3 Reporting of any loss or release of radioactive material (report to supervisor) 9.4 Reporting (to supervisor) of any failure of industrial radiography equipment to de-energise or return to its safe position after the intended exposure period. TYPICAL GAMMA AND X-RAY SOURCES USED IN INDUSTRIAL RADIOGRAPHY 10 Table 1 lists the main types of source used in MOD together with typical activities, half life and associated dose or dose rate. Table 1 Data for typical gamma and X-ray sources used in industrial radiography within MOD Typical Maximum Activity (TBq) 4 7 0.5 N/A N/A N/A Energy (keV) 1170; 1330 210-610 660 Up to 300 Up to 1000s Up to 300 Typical maximum dose or dose rate at 1m Approx 1.2 Sv h-1 Approx 800 mSv h-1 Approx 40 mSv h-1 Up to >10 Sv h-1 Up to >10 Sv per flash Up to 10 Sv per pulse

Radionuclide

Half Life

Cobalt-60 (Co-60) Iridium-192 (Ir-192) Caesium-137 (Cs-137) X-ray Generator (continuous) X-ray generator (flash) X-ray generator (pulsed)

5 years 74 days 30 years N/A N/A N/A

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HAZARDS Table 2 Hazards associated with industrial radiography sources and X-ray generators Radiation type Alpha Emitted Comments Alpha radiation is not normally emitted by radioactive sources used in industrial radiography and would be absorbed by the source capsule. Although most radioactive sources used in industrial radiography are beta emitters, design is such that beta radiation is absorbed by the source capsule. Sources are normally designed as special form sealed sources thus making it extremely unlikely that beta emitters could be released and cause an internal hazard. Levels of bremsstrahlung radiation (X-rays) are insignificant compared with gamma levels from the radioactive sources used in industrial radiography. Gamma radiation is emitted by radioactive sources used in industrial radiography. Such sources are high-activity sealed sources dose rates at ~ 1 m of an unshielded source could lead to whole body overexposure levels in minutes. An exposure of a few seconds in closer proximity to a source could be sufficient to initiate irreversible deterministic effects such as tissue damage. X-ray generators used in industrial radiography generate inbeam dose rates which could lead to overexposure levels in seconds. Significant (leakage) dose rates can also occur in out of beam areas around the X-ray set. Pulsed X-ray equipment gives lower in-beam time averaged dose rates due to the limited number of very short duration pulses of X-rays which are used to produce a radiograph. Flash X-ray equipment may operate at very high energy and high power giving rise to potentially lethal in beam dose levels. Neutron sources are not currently used within MOD for industrial radiography.

Direct Beta

Bremsstrahlung

Gamma

X-rays

Neutrons

RISK ASSESSMENTS 11 In the acquisition of equipment emitting ionising radiation, safety and environmental management is to begin at the requirements definition stage and is to be carried forward through service to disposal. All aspects of maintenance and operation (including military service) are to be taken into account and particular care is to be given in assessing risk and environmental impacts where there is no appropriate statute or comparative civil practice. Prior risk assessments are a statutory requirement before the commencement of any industrial radiography. Although generic information provided by manufacturers, IPTs and this publication may be useful as input to these assessments, these are not, in themselves, sufficient and considerations specific to the type of work and enclosure to be used must be included. It is a statutory requirement that the RPA is consulted regarding a number of aspects (see Table 3). Leaflet 2 gives further general instruction and guidance on the components of a prior risk assessment. 12 Recommendations for dose restriction arising from the risk assessment must be adopted, unless, following advice from the RPA, other effective alternative solutions are available. TRAINING 13 The RPS and the radiographers are to be formally trained and certificated in radiography and are to be formally instructed in the use of each type of radiographic equipment that they are to operate. Radiographers are to be trained to Personal Certification in Non-Destructive Testing (PCN) Level 1 (or equivalent) and the RPS to PCN level 2 (or equivalent) (see below).

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14 The RPS is to be familiar with the following publications, in addition to IRR99 and the associated Approved Code of Practice: 14.1 Radiation Protection Supervisors IRIS6 HSE 2000 www.hse.gov.uk/pubns/irp6.pdf

14.2 Personnel Certification in Non-Destructive Testing (NDT) General Information e.g.www.bindt.org/mk1site/PCN.html 14.3 HSE Information Sheet Industrial Radiography managing radiation risks www.hse.gov.uk/pubns/irp1.pdf 15 Records are to be maintained of the training undertaken. Persons assisting radiographers are to be instructed in the actions that they are to take before commencement of radiography. They are also to be instructed in the actions to be taken in the event of an incident or accident involving the radiographic equipment. LEGAL AND MOD MANDATORY REQUIREMENTS 16 Table 3 below summarises the legal and MOD mandatory requirements for industrial radiography using both high-activity sealed radioactive sources and X-ray generators. Consultation with the RPA is advisable for all aspects of this work and is a statutory requirement in a number of areas as indicated below. 17 Further guidance on the radiation safety arrangements for industrial radiography in enclosures; for site radiography; for underwater radiography; and for flash/pulsed X-ray equipment is given at Annexes B to E respectively. Table 3 Legal and MOD mandatory requirements for industrial radiography Requirement Applicable Comments Prior authorisation is required for the use of electrical equipment to generate X-rays for industrial radiography. HSE has issued a generic authorisation (see Annex A to Leaflet 3) which can be used provided that the conditions of the generic authorisation are met. Any planned use of the equipment for other purposes may require an individual prior authorisation Not required Notification is required in accordance with Leaflet 3. Re-notification is required if there is to be any material change in the type of work carried out. HSE may require notification prior to each occasion on which radiography is carried out however employers are exempt from this requirement for work carried out for or on behalf of MOD. Not required. Related leaflet*

HSE authorisation of specified practices (X-ray generators)

HSE authorisation of specified practices (radioactive sources)

HSE notification (X-ray generators and radioactive sources)

EA notification** (X-ray generators)

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Table 3 Legal and MOD mandatory requirements for industrial radiography (continued) Requirement Applicable Comments Radioactive sources used for industrial radiography are likely to be mobile high-activity sealed sources (HASS). Prior notification to EA to hold HASS placed on the market on or after 1 January 2006 is required by operators in accordance with Leaflet 3. HASS placed on the market on or before 31 Dec 2005 continued to be held under existing arrangements. These transitional provisions expired on 31 Dec 2007 and operators were required to apply for new permits at least 4 months in advance of this date. A prior risk assessment must be carried out prior to any new activity involving work with ionising radiation (see Leaflet 2). The external radiation hazard is very high and the primary means of restricting exposure must be by means of engineering controls and design features (e.g. shielding and beam collimation). This is to be supplemented by the provision of safety features (e.g. locks on exposure controls, door interlocks for enclosures, emergency off buttons) and warning devices. Finally, systems of work which prevent access to enclosures or controlled areas during irradiation must be in place. Where reasonably practicable, radiography is to be carried out in a purpose made enclosure. Consultation of an RPA is a statutory requirement with respect to prior examination of plans for new or modified sources of radiation in relation to engineering controls, design features, safety features and warning devices. Also the RPA must be consulted regarding the testing of same and to check that systems of work are adequate to restrict exposure. Radiation employers must ensure that engineering controls, design features, safety features and warning devices are properly maintained and tested at suitable intervals. Statutory requirement for RPA consultation as above. Not required significant attenuation of high energy X-ray or gamma radiation cannot be practicably achieved by any form of protective clothing. Plans for reasonably foreseeable radiation accidents must be included (or referred to) in local orders; plans must be rehearsed and employees must be given suitable instructions. Designated areas (e.g. controlled and supervised radiation areas) are necessary for all types of industrial radiography work. Leaflet 4 provides further instruction and guidance. Related leaflet*

EA notification** (radioactive sources)

Risk assessment (X-ray generators and radioactive sources)

Restriction of exposure (X-ray generators and radioactive sources)

4 (general requirements)

Maintenance of radiation engineering controls (X-ray generators and radioactive sources) PPE (X-ray generators and radioactive sources) Contingency plans (X-ray generators and radioactive sources) Designated areas (X-ray generators and radioactive sources)

40

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Table 3 Legal and MOD mandatory requirements for industrial radiography (continued) Requirement Applicable Comments Monitoring of designated areas (see Leaflet 4) and surrounding areas is required using appropriate instruments (see Leaflet 8). It is a statutory requirement that the RPA be consulted regarding calibration and checking of equipment provided for monitoring levels of ionising radiation. Survey records are to be kept for at least 2 years. Training and qualification of all supervisors and operatives is essential prior to carrying out any radiography. Provision of written local rules is a statutory requirement these may be encompassed within local orders - see Leaflet 16 for guidance. An RPS is required to ensure work is carried out in accordance with the local rules. Appointment to be made in accordance with Leaflet 39. Radioactive sources are to be installed in lockable containers where they can be safely and securely stored when not in use. Further guidance on storage and security is provided at the annexes and at Leaflet 9. HASS source security requirements will be issued separately. Facilities for X-ray equipment are to provide a lock-off arrangement in a physically secure and weatherproof environment. Radioactive sources are to be accounted for in source lists in accordance with Leaflet 9. Sources used in industrial radiography are subject to the requirements of the HASS regulations and records are required to be submitted to EA periodically in accordance with the terms and conditions for MOD users. Details of both sources and generators are to be provided on the Dstl Annual Holdings Return, copy retained for 1 year. Leak testing is to be carried out at intervals not exceeding 2 years. RPA advice is to be sought on the frequency and the most appropriate test method. A leak test is to be carried out following any accident involving possible damage to a radiography source. Radiographers and the RPS must normally be designated as classified persons (see Leaflet 4 and the annexes to this leaflet). Classified persons are to be provided with an annual health review to determine suitability to continue radiation work. Related leaflet*

Monitoring (X-ray generators and radioactive sources)

4, 8

Training (X-ray generators and radioactive sources) Local orders (X-ray generators and radioactive sources) Appointed person (X-ray generators and radioactive sources)

15

16

39

Storage (X-ray generators and radioactive sources)

Accounting (X-ray generators and radioactive sources)

Leak testing (radioactive sources)

Classified persons (X-ray generators and radioactive sources)

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Table 3 Legal and MOD mandatory requirements for industrial radiography (continued) Requirement Applicable Comments Classified persons must be provided with and wear appropriate dosimetry issued by an Approved Dosimetry Service. A radiation passbook must be raised for each classified person. In addition to the approved dosemeter, day to day monitoring of radiation dose for radiographers should normally be effected by the wearing of a suitable personal integrating electronic dosemeter providing audible alarms at predetermined dose rates and integrated doses. All losses and certain other unusual radiation events require to be reported to MOD authorities and external regulatory authorities in accordance with Leaflet 14. Note: this includes failure of a radiographic source to retract or an X-ray set to de-energise. Radiography sources must generally be transported in approved Type B containers. Transport must be in accordance with JSP 800 Vol. 4b for road, rail and sea transport or JSP 800 Vol. 4a for air transport. Movement of sources on site must be carried out under written procedures in accordance with Leaflet 10. Marking of items, equipment and containers is to be in accordance with Leaflet 9 and marking of designated areas in accordance with Leaflet 4. Further guidance is at the annexes to this leaflet. Disposal of high-activity radioactive sources must comply with the requirements of the HASS regulations and be in accordance with the terms and conditions for MOD users supplied by EA. (See also Leaflet 12). Arrangements for management of disused sources and financial provision for their disposal must be made before acquiring such sources. X-ray generators are normally to be disposed of via an appropriate manufacturer. Further guidance on disposal is at the annexes to this leaflet. Related leaflet*

Personal dosimetry (X-ray generators and radioactive sources)

Reporting procedures (X-ray generators and radioactive sources)

14

Transport (radioactive sources)

JSP 800 Vol. 4a & Vol. 4b and Leaflet 10

Marking (X-ray generators and radioactive sources)

9, 4

Disposal of redundant items (X-ray generators and radioactive sources)

12

*JSP 392, unless otherwise stated **Environment Agency (EA) for England and Wales, Scottish Environment Protection Agency (SEPA) for Scotland and Environment and Heritage Service for Northern Ireland (EHSNI). RADIOACTIVE SEALED SOURCES AND THEIR CONTAINERS 18 Detailed guidance on the requirements for industrial radiography radioactive sealed sources and their containers is at Annex A.

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PHYSICAL SECURITY ARRANGEMENTS FOR HIGH-ACTIVITY SEALED RADIOACTIVE SOURCES 19 Radiography facility managers are to be aware of the contents of Security Requirements for Radioactive Sources issued by the National Security Advice Centre. Copies of this document are available from the Counter Terrorism Security Adviser (CTSA) or the Dstl RPA Body. Advice on application of this guidance is to be sought from the appropriate Principal Security Adviser. CONTRACTORS 20 Where contractors are employed to undertake radiography at a unit or establishment, they are to work in accordance with the requirements of the IRR99 and the Approved Code of Practice. All contractors undertaking radiography on a MOD site are to meet the strict safety requirements attaching to such work, including the requirements of this leaflet, to the satisfaction of the CO through the RSO and/or RPS. Details of general contractor control arrangements are given in JSP 375.

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LEAFLET 28 ANNEX A REQUIREMENTS FOR RADIOACTIVE SEALED SOURCES AND THEIR CONTAINERS CONTENTS Para 1 9 12 Table A1 Radioactive sources and containers Loading and unloading of radioactive sources Physical security at sites holding high activity radioactive sources Page Maximum dose rate limits for exposure containers.2

RADIOACTIVE SOURCES AND CONTAINERS 1 Every radiography source is to have a unique means of identification, and no source is to be used without a valid leakage test certificate. The source is to be installed in a container where it can be securely stored when not in use. New exposure containers are to conform to ISO 3999:2004. If these containers are to be transported, they are also to meet current transport regulations detailed in JSP 800 Vol. 4b. All exposure containers are to be permanently and indelibly marked (possibly by fitting with a metal plate) with the following information: 1.1 The radiation trefoil. 1.2 The word RADIOACTIVE in letters not less than 10 mm high. 1.3 The maximum rating of the container, for example an Iridium-192 source with a maximum container rating of X Bq would be shown as: 1.3.1 Rating X Bq Ir-192

1.4 The manufacturer, type and serial number. 1.5 The mass of the exposure container if it is Class P, M or F as described below. 2 The following durably marked information is to be attached to the exposure container: 2.1 Chemical symbol and mass number of radionuclide, for example, Ir-192. 2.2 Activity and date activity was measured. 2.3 Identification number of sealed source. 3 ISO 3999:2004 classifies source containers according to their mobility. described as follows: The classification is

3.1 Class P: A portable exposure container, designed to be carried by one man alone. 3.2 Class M: A mobile but not portable exposure container, designed to be moved by a suitable means provided for that purpose. 3.3 Class F: A fixed installed exposure container or one with mobility restricted to the confines of a particular area.

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Dose rate limits for these containers are given in Table 1. Table A1 Maximum dose rate limits for exposure containers (in Sv h-1) Class P M F External surface of container 2000 2000 2000 50 mm from external surface of container 500 1000 1000 1 m from external surface of container 20 50 100

4 If the exposure container has a shutter, an indication of its status, whether open or closed, must be clearly indicated on the exposure container. 5 Every exposure container is to be provided with a lock to prevent unintended or unauthorised exposures. The lock is to be designed so that if it becomes defective it will not prevent retraction of the source. The act of unlocking the container must also not give rise to immediate exposure of the source. 6 Additional requirements for High Activity Sealed Sources placed on the market on or after 1 Jan 2006 include the engraving or stamping of a unique number on the source (where feasible) and container and the provision by the manufacturer of a photograph of the source type and typical source container. Holders are required to ensure that each source is accompanied by written information. These provisions, where practicable, will also apply to existing sources (placed on the market before 1 Jan 2006) and containers from 1 Jan 2008. 7 The source container when not in use must be kept locked and, unless the source is stored in an automatic exposure device and interlocked to the entrances to the enclosures, is to be stored in a radioactive source store which is designated a controlled radiation area. The store is to be physically secure and marked at the entrance with a radiation warning sign including details of the radioactive sources and the risks arising from these sources. Sufficient shielding is to be provided to ensure that persons outside the store will not receive a dose exceeding 1 mSv in a year. In practice this will normally be achieved by ensuring that the radiation dose rate at any point on the outside walls of the building is less than 1 Sv h-1. Arrangements are to be made for the keys of the store to be kept in a secure place and the number of persons authorised to draw them kept to a minimum compatible with operational requirements. 8 Exposure containers must be inspected and maintained in accordance with the manufacturers or suppliers recommendations. LOADING AND UNLOADING OF RADIOACTIVE SOURCES 9 Source assemblies used for radiographic examinations are only to be loaded into containers which are compatible with the type of assembly to be installed. 10 Changing of sealed sources will often be undertaken by the source manufacturer or their agent. Where this is not the case and the changing of sources is undertaken by the establishment it will be necessary to introduce a set of administrative controls and procedures to ensure that doses are kept as low as reasonably practicable. This will normally be achieved by using specially designed transfer equipment within a controlled area and will take the form of a system of work drawn up by the establishment, in consultation with the RPA. The system of work is to include the names of persons who may undertake the work under supervision. 11 Persons undertaking this work are to be adequately trained and experienced. The procedure is to be rehearsed using a dummy source to ensure that it can be carried out quickly and safely.

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PHYSICAL SECURITY AT SITES HOLDING HIGH ACTIVITY RADIOACTIVE SOURCES 12 Physical security at the site where the radioactive sources are normally stored is to be designed to accord with the principles described in the publication Security Requirements for Radioactive Sources issued by the National Security Advice Centre. Advice on the use of this document is to be sought from the Principal Security Adviser who is also to be approached for advice on the level of security appropriate for occasional storage at the client site.

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LEAFLET 28 ANNEX B GUIDANCE ON RADIATION SAFETY ARRANGEMENTS FOR INDUSTRIAL RADIOGRAPHY IN ENCLOSURES CONTENTS Para 1 2 7 8 19 28 Introduction Designation of radiography enclosures Access to radiography enclosures Design of enclosures Warning devices Operating procedures

INTRODUCTION 1 The main body of this leaflet details the general statutory and MOD mandatory instruction for radiation safety in industrial radiography. This Annex, which must be read in conjunction with the main body of the leaflet provides additional guidance specific to the radiation safety arrangements for industrial radiography undertaken in enclosures. Such radiography involves the generation of intense beams of radiation emitted from high-activity sealed sources or from X-ray generators. High-activity sealed sources used in radiography are capable of delivering overexposure levels of dose at 1 m in minutes whereas an overexposure from an X-ray generator at the same distance could occur in seconds. DESIGNATION OF RADIOGRAPHY ENCLOSURES 2 The designation of radiographic enclosures as controlled areas during the exposure of radiographic sources or the operation of an industrial X-ray set is to be undertaken in consultation with the RPA. 3 Suitable controlled radiation areas signs (see Leaflet 4), detailing the nature of the radioactive source and the risks arising from the source, are to be displayed around the perimeter of the controlled area and at each entrance to the enclosure. 4 Suitably worded signs are to be posted on each outside wall of the radiation enclosure to warn, where appropriate, against access to the roof without the permission of the RPS. 5 Where radiographic sources are used, the radioactive source store will be a controlled radiation area. The store is to be appropriately marked and display a sign on the door listing the radioactive contents within the store and the risks arising from the sources held. 6 All controlled and supervised areas are to be suitably described in local orders.

ACCESS TO RADIOGRAPHY ENCLOSURES 7 Entry to the radiography enclosure is prohibited during radiation exposure other than in special circumstances under a permit-to-work (see Leaflet 4) such as in returning a radiographic source to its container when it cannot be returned from outside the enclosure. All such special procedures are to be undertaken in consultation with the RPA.

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DESIGN OF ENCLOSURES 8 Enclosures for industrial radiography using radioactive sealed sources or X-rays must provide sufficient shielding to reduce the radiation dose rate to 7.5 Sv h-1 at any point on the surface of the outside wall of the enclosure. Additional shielding is to be provided for facilities in constant use. New facilities are to be designed, where reasonably practicable, to provide sufficient shielding such that the external dose rate will not exceed 1 Sv h-1. 9 Control panels for X-ray machines or radioactive sources must be situated outside the walled enclosure. 10 Where an X-ray machine is used, interlocks are to be provided and maintained to ensure that should any door to the enclosure be opened while an X-ray machine within it is energised, the machine will be automatically de-energised and cannot be operated so long as that door remains open. 11 Where a radioactive sealed source is used, where reasonably practicable, interlocks are to be provided and maintained at all entrances to an enclosure, such that while a sealed source is exposed no door to the enclosure can be opened, and that a sealed source cannot be exposed while any door is open. 12 Where an interlock has been opened, a radiographic exposure is not to re-start simply by remaking the interlock. It must be necessary to re-set the interlocks and the operator must go through the re-start sequence at the control point before the X-ray machine or sealed source can be exposed. 13 All interlocks are to be designed and positioned so that they cannot easily be interfered with, and are to be of a fail-safe type. 14 Interlocks are to be regularly examined and tested at a frequency laid down in the local orders. Records of such tests are to be maintained, to identify the tests carried out, any actions required to maintain the interlocks and the date the next examination is due. 15 For the protection of persons accidentally shut inside an enclosure, an alarm is also to be provided to summon help from outside the enclosure. In addition, in all X-ray facilities and, where reasonably practicable, sealed source radiography, a means of controlling the radiation source from inside the room is to be provided. Such a control is to prevent exposure from taking place if activated outside the exposure phase, and terminate if operated during an exposure. A sufficient number of prominently marked controls (stop buttons or pull cords) are to be provided such that they may be activated promptly and without crossing a main exposure beam. These controls are to be of a type that needs to be positively re-set from the location at which they were operated before further exposures may be initiated. Such devices are to be regularly tested and documented. If it is not reasonably practicable to control the sources from inside the room, a shielded refuge is to be provided inside the enclosure. The RPA must be consulted about the design of this refuge. 16 A prominent notice is to be displayed in the enclosure explaining the actions to be taken in the event of being accidentally shut inside the enclosure. 17 Where manually operated source wind out systems are used, or where the dose rate exceeds 50 mSv min-1 at 1 m from the source, a search-and-lockup system is to be provided and operated before each exposure, to ensure that no-one may be accidentally shut inside at the beginning of an exposure. 18 Where an enclosure has been designed such that there are limitations on the positioning of the radiography source or the X-ray machine within the enclosure, the equipment operating area is to be clearly marked. WARNING DEVICES 19 Adequate warning to all persons in the vicinity is to be given by appropriate visual or audible signals, or both:

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19.1 When a sealed source is about to be exposed, or when an X-ray machine is about to be energized (pre-exposure warning alarm), and 19.2 While a source is exposed or an X-ray machine is energised (continuous exposure warning alarm). 20 The duration of the pre-exposure warning alarm is to be sufficient for anyone accidentally shut inside the enclosure to take appropriate action. 21 The pre-exposure warning alarm must be easily distinguishable from the continuous exposure warning alarm and both warnings must be clearly explained on well sited signs. To achieve this, a warning signal may be combined with a sign in the form of an illuminated sign. 22 In the case of X-ray machines, and sealed sources capable of producing >10 mSv min-1 at a distance of 1 m, the warning signals and illuminated signs are to be arranged to operate automatically. 23 Warning signals are to be installed inside the enclosure and outside each entrance to the enclosure. 24 A further exposure warning signal (such as a red light) is to be activated on the control panel and is to remain on long enough for the indication to be seen by the operator irrespective of the exposure duration. 25 Warning devices for X-ray enclosures are to be fail-safe, i.e. if the warning device fails the exposure will not proceed. If reasonably practicable, warning devices for sealed source enclosures are to be fail-safe. 26 All warning signals are to be regularly examined and tested to ensure their satisfactory operation. Records of such checks are to be maintained, to identify the tests carried out, any actions required to maintain the interlocks and the date the next examination is due. 27 Explanatory notices are to be provided to inform employees and other persons as to the purpose of the warning signal. OPERATING PROCEDURES 28 Work involving the exposure of sealed sources or operation of an X-ray set is only to be undertaken in accordance with written arrangements (including local orders and systems of work) drawn up by the establishment in consultation with the RPA (see Leaflet 16). Unclassified persons are only to enter a controlled area under written arrangements (see Leaflet 5). 29 The movement or manipulation of sealed sources is to be undertaken by remote control. Radiographic sources must never be handled with bare or gloved hands. 30 The radiography set-up is to be completed before the X-ray machine is energized or the sealed source is exposed. No material is to be brought into the radiation beam except by the use of mechanisms operated from outside the enclosure. 31 Where there are limitations on the location of these equipments inside the enclosure, the radiography source or the X-ray machine is only to be operated in the demarcated area 32 Before an X-ray machine is operated, or a sealed source is exposed, a search of the enclosure is to be made to ensure that no one has been accidentally shut inside. 33 After each exposure, personnel entering the enclosure must enter with a dose rate monitoring instrument to verify that the X-ray machine has de-energized or that the source has retracted fully home into its container.

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34 The dose rate outside an enclosure is to be checked regularly and particularly after any change of radiation source or methods of work. The results are to be recorded in a survey report which is to be retained for a period of at least 2 years from the date of completion. 35 All radiation protection and monitoring instruments used in radiographic work are to be calibrated and tested in accordance with the requirements detailed in Leaflet 8.

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LEAFLET 28 ANNEX C RADIATION SAFETY ARRANGEMENTS FOR SITE RADIOGRAPHY CONTENTS Para 1 2 4 5 6 11 12 13 19 20 29 30 31 Introduction Co-operation between units Appointments Storage of radiography sources Controlled areas Equipment requirements X-ray apparatus Sealed sources Warning signals Precautions with high output machines Operating procedures Monitoring surveys Radiography safety audits Emergency procedures

INTRODUCTION 1 The main body of this leaflet details the general statutory and MOD mandatory instruction for radiation safety in industrial radiography. This Annex, which must be read in conjunction with the main body of the leaflet provides additional guidance specific to the radiation safety arrangements for site radiography. Such radiography involves the generation of radiographs using radiation emitted from high-activity sealed sources or from X-ray generators. High-activity sealed sources used in radiography are capable of delivering overexposure levels of dose at 1 m in minutes whereas an overexposure from an X-ray generator at the same distance could occur in seconds. CO-OPERATION BETWEEN UNITS 2 Prior to site radiography taking place the RSO, or other person(s) nominated by the RSO, such as an engineering officer or facility manager at the unit or establishment where radiography is to be undertaken is to be supplied with the following information by the Officer Commanding the NonDestructive Testing (NDT) team: 2.1 Prior notification and permission for the NDT source or X-ray machine to be brought on site 2.2 Name of RPAs and RPSs and how they can be contacted on or off site 2.3 Places where work will be carried out including dates and description of work procedures and work instructions 2.4 Details of radioactive sources or X-ray machines to be used 2.5 For sources only, their stowage requirements including both safety and security aspects 2.6 Description of monitoring procedure 2.7 Risk assessments and contingency plans 2.8 Details of methods of transportation of sources

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2.9 Health and Safety policy statement containing radiography local orders and procedures for the radiographers. 3 For repeated site radiography examinations undertaken at the same unit or establishment the RSO may agree with the officer commanding the NDT team to receive a single notification of those elements above that do not frequently change. After the initial notification the officer commanding the NDT team will be required to resubmit the notification to the units / establishments RSO for their approval annually, when there is a change to the RSO or whenever there is a change to these details. In addition, those elements above that do change frequently are to be supplied to the RSO or other appropriate person, each time before radiography is undertaken at the unit or establishment. APPOINTMENTS 4 Site radiography requires a number additional factors to be considered regarding the appointment of suitably qualified and experienced staff as follows: 4.1 An RPS is to be appointed in writing by the CO for site radiography undertaken within an establishment and for the storage of radiographic sources in a source store 4.2 Sufficient RPSs are to be appointed in writing by the CO so that whenever radiography is undertaken outside an establishment, or at another establishment, it is undertaken under the supervision of an RPS. The RPS is responsible for ensuring that radiation doses are kept as low as reasonably practicable for not only personnel involved in the radiography but for all other persons who may receive radiation doses from the radiography 4.3 All RPSs who undertake supervision of site radiography are to be trained in accordance with the requirements of this leaflet and Leaflet 15. The training is to specifically include radiation safety arrangements for site radiography 4.4 As well as the general duties of an RPS, the RPS is to ensure that: 4.5 All personnel directly involved in, or who may be affected by, the radiography are aware that such work is going to take place 4.6 Verbal contact is maintained with all relevant personnel while radiography is taking place 4.7 All equipment and services are compatible and in working order 4.8 No other work or conflicting activities takes place in the vicinity which could adversely affect the safety any person or the radiographic set-up STORAGE OF RADIOGRAPHY SOURCES 5 If it is necessary for a radiographic sealed source to be stored on the site, it must be stored in accordance with the general requirements of Leaflet 9 and, in addition, for high-activity sealed sources, the security arrangements for the store must be adequate in case of doubt the appropriate Principal Security Adviser is to be consulted. Suitable radiation warning signs are to be posted on the store, with the name and telephone number of the RPS and details of the source. A written system of work agreed with the RPA is to be made available to the CO and the RSO at the establishment and such personnel that may be affected by its storage (e.g. security and cleaning staff and the site fire officer). CONTROLLED AREAS 6 A controlled area is to be set up before any radiographic exposure is undertaken outside an enclosure. The extent of the controlled area is to fulfil the following: 6.1 Within an establishment, all areas outside the controlled area are to be at dose rates (averaged over one minute) of less than 7.5 Sv h-1. In public places barriers and signs are to be set up where dose rates exceed 2.5 Sv h-1.

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6.2 The extent of controlled areas is to be determined in consultation with the RPA, initially by calculating the appropriate distance from the source to the 7.5 Sv h-1 dose rate contour within an establishment or the 2.5 Sv h-1 dose rate contour in public places. On exposure of the sealed source or the X-ray machine, dose rate measurements are to be taken and the barrier moved until the dose rates do not exceed 7.5 Sv h-1 or 2.5 Sv h-1, as appropriate. 6.3 It is to be set up so that access control can be effectively achieved. Access to controlled areas is to be by the use of barriers or by the use of fixed structures, such as the walls of buildings or bulkheads of ships. 6.4 It is to be minimised by utilising local shielding such as walls, beam collimation etc. 7 No one is to work inside the area until the site radiographic exposures are complete. However, subject to the provisions of local orders, where it is unavoidable for the purposes of initiating or terminating an exposure, personnel may enter the controlled area provided they are not exposed to an instantaneous radiation dose rate in excess of 2 mSv h-1. 8 Where radiography is undertaken in a multi-storey building or on board ship, the controlled area is not only to include areas on the same level, but where appropriate, levels above and below the source of the radiation emission are to be designated as controlled areas. 9 Suitable warning signs (see Leaflet 4) are to be displayed at appropriate points around the perimeter of the controlled areas, such that a person approaching the controlled area from any direction would be made aware of the hazard. The signs are to state that the area is a controlled area and give details of the radiation hazard and the risks arising from the radiation source being used. An appropriate number of sentries are to patrol the perimeter of the controlled area to prevent unauthorised entry. 10 All controlled areas are to be suitably described in local orders. For site radiography, this can most easily be achieved by stating distances from the sealed source or X-ray machine. EQUIPMENT REQUIREMENTS X-Ray Apparatus 11 Where X-ray machines are used, the following requirements are to be fulfilled: 11.1 aluminium The beam filtration on the X-ray tube must be equivalent to at least 2 mm of

11.2 The leakage rate from the X-ray tube housing is to not exceed 2.5 mSv h-1 at 1 m from the focal spot at the maximum rated voltage and current, and for pulsed X-ray tubes at the maximum pulse rate 11.3 The lengths of cables from the X-ray machines are to be long enough to enable the control panel, whenever practicable, to be outside the controlled area 11.4 For X-ray units operating up to 300 kV, a cable of not less than 20 m in length are to be used. Longer cables are required for X-ray units operating at greater than 300 kV. Control cables to warning signal devices are to be equal or greater in length than the tube head to control panel cables 11.5 The X-ray set is to be provided with a means of collimation to restrict the radiation beam to the minimum size necessary for the work 11.6 The equipment is to be electrically safe

11.7 The equipment is provided with a means of preventing unauthorised use (e.g. a key operated switch)

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Sealed Sources 12 Sealed sources used in site radiography are to be provided with a suitable means of collimation to restrict the extent of the radiation beam to a minimum necessary to undertake the work and operated via a keyed switch to prevent unauthorised use. WARNING SIGNALS 13 Adequate warning of the impending or actual presence of radiation is to be given to all persons within or approaching the marked off area during site radiography by appropriate visual or audible signals, or both. The two signals are as follows: 13.1 When a source is about to be exposed or when an X-ray machine is about to be energized (pre-exposure warning alarm) and, 13.2 While a source is exposed or an X-ray machine is energized (continuous exposure warning alarm). 14 The duration of the pre-exposure warning alarm is to be sufficient for anyone within the controlled area to walk clear. 15 The pre-exposure and the continuous exposure warning signals must be easily distinguishable from each other. Both signals must be clearly explained on well sited notices at the boundary. The notice is to explain the significance of the barrier. Warning signals and notices may be combined in the form of illuminated notices. 16 In the case of sealed sources capable of delivering 600 mSv h-1 at a distance of 1 m in air, and all X-ray apparatus, the warning signals are to operate at or near the X-ray tube head, at the control panel and be clearly recognisable at the boundary of the area. The pre-exposure and the continuous exposure signals are to operate automatically and the equipment is to be unable to function unless they are connected. Work is to cease if the warning signals are not operating correctly. Interlock defeat switches are to not be fitted. A device is to be provided to enable the warning signals to be tested while the X-ray head remains de-energized. 17 In the case of other sealed sources, warning lamps are generally used which are switched on manually, and these are to be in good working order. They must be positioned so that they are clearly visible to all persons in the vicinity. The pre-warning alarm is usually an audible alarm, such as a manually operated air horn. 18 All warning signals are to be examined and tested on a regular basis and records are to be kept of the tests undertaken. PRECAUTIONS WITH HIGH OUTPUT MACHINES 19 Some X-ray machines, particularly those manufactured after 1992, feature an automatic warm-up facility. To ensure compliance with the manufacturers specification such sets are to be warmed up at least once in every four week period even if they are not in routine use. The leakage dose rates from such equipment during this warm-up period may be up to 2.5 mSv h-1 at 1 m, even when fitted with main beam blanking plugs. Local orders and written operating procedures are to address the precautions to be taken during the warm-up period. OPERATING PROCEDURES 20 Written operating procedures are to be drawn up for all X-ray machines and sealed sources by the parent establishment of the radiographers, in consultation with their RPA. A copy of the operating procedure is to be displayed at the control point during each such exposure. The general points to be considered in a written operating procedure are contained in the following paragraphs.

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21 A controlled area is to be set up in accordance with the requirements above. It is important that control cables are laid out so as to maximise the distance of the operator from the X-ray tube head. The control point is to be, whenever possible, outside the controlled area, and where this is so it is to be continuously manned throughout the whole period of the exposure. At least two classified persons are to be employed on each radiographic exposure, one of these must be an experienced radiographer and the other is to have sufficient knowledge of the actions to be taken in the event of an emergency. 22 Where the control point is inside the controlled area, operators are to only enter the controlled area to start the exposure, terminate the exposure or in the event of an emergency. In exceptional circumstances where it is necessary for an operator to man the control point inside the controlled area the dose rate at the control point is to not exceed 25 Sv h-1. 23 After setting up the controlled area and before exposure, all persons within the area not involved with the radiography are to leave. A thorough search of the area is to be conducted with special attention being paid to places where personnel may remain unobserved, such as remote compartments and the interior of empty tanks. 24 The radiography set-up is to be completed before any sealed source is exposed or X-ray machine is energized. No changes to the exposure arrangements are to be made during an exposure. 25 Sufficient sentries are to be posted around the perimeter of the area to prevent entry to the controlled area during radiography. Care is to be taken to ensure that there are no areas where personnel can enter unobserved. Where it is not practicable to provide line of sight communication between sentries it may be necessary to provide a voice communication system. 26 To ensure that radiation exposure to personnel is kept as low as reasonably practicable the following conditions are to be satisfied: 26.1 The useful beam is to be directed away from the control point and all occupied areas, unless these areas are adequately protected by distance or shielding 26.2 The beam size is to be kept to the minimum compatible with obtaining a satisfactory radiograph 26.3 Only authorised persons are to enter the controlled area

27 On completion of the radiation exposure, the X-ray set is to be switched off, or the radiation source retracted into its container. Where a sealed source is used, the radiographer must approach the source container using an appropriate dose rate meter and confirm that the source is fully home in its container. 28 The movement or manipulation of sealed sources is to be undertaken by remote control. Care is to be taken to prevent any part of the body coming close to the exposed source. Radiographic sources must never be handled with bare or gloved hands. All unnecessary movement of sources must be avoided. Sources are to only be moved about a unit when they are locked in their containers and their keys have been removed. MONITORING SURVEYS 29 A radiation survey record is to be maintained, containing details of radiation dose rates at the barrier and within controlled areas where persons are exposed to levels of radiation in excess of 7.5 Sv h-1. Radiation survey records are to be maintained for at least 2 years from the date of the survey, unless there is an incident in which case the records are to be kept indefinitely. RADIOGRAPHY SAFETY AUDITS 30 Regular and random checks on site radiography are to be made to ensure the procedures are being carried out to the required safety standards. Such checks are to be carried out by the site RSO or other suitably qualified and experienced person.

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EMERGENCY PROCEDURES 31 Contingency plans are to be drawn up (in accordance with Leaflet 2 and Leaflet 40) by the establishment in consultation with the RPA to cope with any foreseeable emergency. A copy of these plans and a set of emergency equipment described in these plans are to be carried to each radiographic site. Radiographic sources and containers are designed to withstand fire; if a fire occurs the sources are to only be removed from the area if this can be done without risk to life. If this cannot be done they are to be abandoned and the fire fighting services informed of their presence as soon as possible. 32 Special equipment is to be available to deal with emergencies such as detached sources, jammed sources and damaged containers. The equipment is listed as follows: 32.1 32.2 32.3 32.4 32.5 Audible alarm monitor Personal integrating dosemeter Tongs or CeeVee reachers (1 metre and 2 metre) Pliers, screwdriver, long-handled wire cutters Adjustable spanner or wrench, rope, hand lamp

32.6 Tripod (2 metres high - to hoist end of the projection tube to help gravity return of a detached source) 32.7 32.8 32.9 32.10 32.11 source Radiation barrier (quick erect type) Two bags of lead shot (2 kg each), for Iridium-192 source Ten bags of lead or lead shielded semi-cylindrical tunnel for Cobalt-60 sources, Emergency storage container Pouring funnel to suit emergency storage container, for speedy placing of the

33 Each person involved in site radiography is to be familiar with the content of these contingency plans. Contingency plans are to be regularly practised using dummy sources etc. to ensure that all personnel are aware of the actions they are to undertake. Records (including the names of personnel involved) should be kept of practices of contingency plans. 34 Contingency plans for site radiography are to be submitted to the Health and Safety Executive if requested by them.

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LEAFLET 28 ANNEX D RADIATION SAFETY ARRANGEMENTS FOR UNDERWATER RADIOGRAPHY CONTENTS Para 1 2 3 4 5 9 11 12 17 18 19 Introduction Co-operation between units Appointments Storage of radioactive sources Controlled areas Equipment requirements Local orders Warning signals Monitoring surveys Audits Emergency procedures

INTRODUCTION 1 The main body of this leaflet details the general statutory and MOD mandatory instruction for radiation safety in industrial radiography. Annex B provides guidance on radiation safety for site radiography, which includes a number of provisions common to those required for underwater radiography. This Annex, which must be read in conjunction with the main body of this leaflet and also Annex B (site radiography), provides additional guidance specific to the radiation safety arrangements for underwater radiography. Such radiography involves the generation of radiographs using radiation emitted from high-activity sealed sources. High-activity sealed sources used in radiography are capable of delivering overexposure levels of dose at 50 cm in minutes. CO-OPERATION BETWEEN UNITS 2 The procedures detailed at Annex B to this leaflet are to be followed.

APPOINTMENTS 3 Underwater radiography requires a number additional factors to be considered regarding the appointment of suitably qualified and experienced staff as follows: 3.1 A Radiation Protection Supervisor (RPS) is to be appointed in writing by the CO for underwater radiography undertaken within a ship or establishment and for the storage of radiographic sources in a source store. 3.2 All RPSs who undertake supervision of underwater radiography are to be trained in accordance with the requirements of this leaflet and Leaflet 15. The training is to specifically include radiation safety aspects of underwater radiography. 3.3 The RPS for underwater radiography is to normally be the diving supervisor (provided they have received the necessary training). Where the diving supervisor and the RPS are not the same person they are to establish close liaison to ensure radiation protection of all personnel, (especially those under pressure or underwater) and each is to be clear of their own individual responsibilities with regard to the radiation protection arrangements. 3.4 As well as the general duties of an RPS, the RPS is to ensure that:

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3.4.1 all personnel directly involved in, or who may be affected by, the radiography are aware that such work is going to take place 3.4.2 verbal contact is maintained with all relevant personnel, either under pressure or underwater, while radiography is taking place 3.4.3 3.4.4 all equipment and services are compatible and in working order no other diving or underwater activity takes place in the controlled area

3.4.5 no other work or conflicting activities takes place in the vicinity which could adversely affect the divers or the radiographic set-up 3.4.6 the exposure container and source are safely returned to the surface

STORAGE OF RADIOACTIVE SOURCES 4 The procedures detailed at Annex B to this leaflet are to be followed.

CONTROLLED AREAS 5 The boundary of the controlled area underwater is to generally be set at 8 m from the source, although this is to be confirmed by dose rate measurements. The figure of 8 m has been chosen because it is a safe practical distance for all radiography sources, and corresponds to current lengths of wind outs used in underwater radiography. In exceptional circumstances, where this distance cannot be achieved, measurements are to be made to ensure that the dose rate at the position to which the divers retire is less than 7.5 Sv h-1. This position is to be clearly identified e.g. by a sign or, in poor visibility, by a flashing light. 6 Supervision is to ensure that no-one is in a controlled area when the radiographic exposure is taking place. It is to be borne in mind that underwater dose rates increase very rapidly on approaching the source. 7 Providing that the above conditions are met, barriers and warning signs need not be erected around the controlled area. 8 If radiography is carried out within 8 m of the surface, surface supervision is to ensure that no-one enters the controlled area. Where the dose rate at the surface of the water exceeds 7.5 Sv h-1 the guidance for site radiography is to be followed. If this happens offshore that guidance is to be adapted to suit local conditions. EQUIPMENT REQUIREMENTS 9 Only exposure containers which meet the requirements of ISO 3999:2004 or its equivalent, and which are designed to be suitable for use underwater, are to be used. The additional features for use underwater are to include: 9.1 A depth rating for the container which is to state the maximum depth at which the container may be used. 9.2 Seals that either prevent the entry of gas or water into parts that are not designed to withstand them or, if designed to cope with water and gas, allow it to escape during ascent to the surface. 9.3 An integral locking device. The locking device when closed, is to retain the source in the shielded position and, if damaged while the source is exposed, is to not prevent the source from being returned to the shielded position. 9.4 A wind out, exposure or shutter mechanism which can be operated from outside the controlled area.

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9.5 For exposure containers with wind-out mechanisms, a method for securely attaching the guide tubes. The tubes are to be fitted before the container is taken into the water. 9.6 An emergency location device e.g. strobe light (see section on warning signals below). 10 Regular attention to and checking of radiography equipment used underwater is of great importance, because such equipment is subjected to environmental conditions that can cause rapid deterioration of its standard of performance. After an item of equipment is used under water it is to be cleaned with fresh water, have its moving parts checked for effective operation and, where necessary, be dried, lubricated and kept in a safe and secure store. Exposure containers are to be checked with a dose rate meter to ensure that wind-out and exposure mechanisms operate correctly before and after cleaning. These checks are to be made by an RPS in an area set aside for this purpose and a record of these checks maintained. LOCAL ORDERS 11 Local orders are to be provided and include the requirements laid down in Leaflet 16. Specifically the individual radiation protection responsibilities of the RPS and the diving supervisor are to be clearly defined and documented. In addition the local orders are to include the information that will enable the following to be carried out: 11.1 Designation and demarcation of controlled areas.

11.2 Restriction of access into controlled areas and prevention of accidental exposures, (e.g. intercommunication and supervision). 11.3 Prevention of interference with the radiographic set up, (e.g. by remotely operated vehicles or by umbilicals or down lines). 11.4 Training and familiarisation with equipment.

11.5 Dose assessment of personnel involved, (e.g. for all radiographers, radiographic assistants and divers directly involved in radiography). 11.6 Monitoring procedures, (e.g. to ensure after each exposure that the source has returned properly). 11.7 11.8 long; Safe operation of source exposure mechanism. Wind out cables where fitted are to be kept as straight as possible and at least 8 m

11.9 With remotely operated exposure equipment, only when instructions from the diver indicate that everyone is outside the controlled area; 11.10 An appropriate summary of the working instructions, including the written arrangements relating to unclassified persons entering or working in a controlled area. 11.11 the surface. 11.12 Prevention of accidental exposure whilst the source is being transferred to and from

Provision of adequate additional warning signals for work in poor visibility.

WARNING SIGNALS 12 When wet transfer is intended, a short line with a buoy and an emergency location device, e.g. a strobe light, is to be securely attached to it until it is returned to the store. This will aid recovery from the water if the container is dropped. The container is to then be attached to the down line for manual lowering.

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13 All warning signals are to be clearly discernable. The underwater detection unit is to include an automatic warning light which operates when the dose rate exceeds 25 Sv h-1 close to the container. Such a light is to be clearly visible to all in the vicinity of the controlled area and a repeater warning light and audible alarm are to be fitted near to the surface read out unit. The light is to be visible to any diver approaching the controlled area. It is advantageous to use a closed circuit TV system so that the diving supervisor and the RPS can see the underwater detection unit and check that the warning light operates correctly. Otherwise, the check is to be carried out verbally between the divers and surface personnel. 14 When visibility is poor, additional warning signals will be needed unless all personnel have returned to the surface before the exposure begins. 15 The divers (including standby divers) in the immediate vicinity are to have in their possession personal radiation alarms which give an instant indication of high dose rates. These alarms are to be properly calibrated and set to operate at 25 Sv h-1. An alarm is to trigger a flashing light which is to be visible to the diver in all light conditions. If personal alarms operate, those involved are to move to a safe place (i.e., where the alarms cease to operate) and immediately contact the RPS. 16 All warning signals are to be examined and tested on a regular basis and records are to be kept of the tests carried out. The frequency of examination and testing should be at least once per year. Records should be kept for at least 2 years, and form part of the maintenance log for the equipment. MONITORING SURVEYS 17 The procedures detailed at Annex B to this leaflet are to be followed.

AUDITS 18 The procedures detailed at Annex B to this leaflet are to be followed.

EMERGENCY PROCEDURES 19 Contingency plans adopted for underwater radiography are to be written as for site radiography. Any differences between underwater and site radiography will stem from the shielding effect of water, the depth of the water and the allocation of duties, e.g. the diving supervisor's involvement. A copy of these plans and a set of emergency equipment described in them must be carried to each radiographic site.

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LEAFLET 28 ANNEX E RADIATION SAFETY ARRANGEMENTS FOR INDUSTRIAL FLASH AND PULSED X-RAY EQUIPMENT CONTENTS Para 1 4 5 6 10 15 16 17 19 20 Introduction Monitoring surveys Flash X-ray equipment Classification of personnel and dosimetry Controlled areas Warning signs Operating procedures Pulsed X-ray equipment Classification of persons and dosimetry Controlled areas Operating procedures

INTRODUCTION 1 The main body of this leaflet details the general statutory and MOD mandatory instruction for radiation safety in industrial radiography. This Annex, which must be read in conjunction with the main body of the leaflet provides additional guidance specific to the radiation safety arrangements for industrial flash and pulsed X-ray equipment. 2 Flash X-ray equipment is used to provide images of extremely fast events. The duration of the exposure is therefore extremely short but, from the larger scale equipments, the dose at 1m from a single flash exposure could be in excess of lethal dose levels. 3 Pulsed X-ray equipment is normally associated with portable equipment, used for example to investigate potential explosive devices. This equipment involves a number of short pulses of X-rays being passed through the object to be radiographed. The total exposure depends on the number of pulses required and the X-ray energy. Typical dose from a single pulse at a distance of 1m is a few Sv but close in at a few cm rises to mSv levels per pulse. MONITORING SURVEYS 4 It is not possible to conduct surveys with standard radiation monitoring equipment as the exposure time is shorter than the response time of the equipment. Specialised equipment can be used to determine doses per flash or pulse the RPA is to be consulted for advice in this matter. FLASH X-RAY EQUIPMENT Classification of personnel and dosimetry 5 Generally, operators of flash X-ray equipment under site radiography conditions will be designated as classified persons (see Leaflet 4) and will be required to wear dosimeters (see Leaflet 6), issued by an Approved Dosimetry Service (ADS), usually the Dstl ESD Alverstoke ADS. Controlled areas 6 For flash X-ray carried out in an enclosure, the design of the enclosure and the requirements for a controlled area detailed in Annex A to this leaflet is to be followed.

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7 For site flash X-ray, a controlled area is to be established, and where necessary cordoned, around the X-ray equipment, as detailed in Annex B to this leaflet. The extent of controlled areas is to be determined by calculating the appropriate distance from the source of X-rays to the position where the dose rate (averaged over 1 minute) will not exceed 7.5 Sv h-1 within an establishment, or 2.5 Sv h-1 in public places. In determining this distance, account is to be taken of any shielding. Calculations are to be included with the prior risk assessments for the equipment. When calculating controlled area distances, consideration is to be given to equipment failure scenarios where more than one X-ray pulse may be discharged in any one minute. Such an incident would result in a greater instantaneous dose rate than normal. The RPA must be consulted on the distance to be used for controlled radiation areas for flash X-radiography. 8 All controlled and supervised areas are to be suitably described in local orders. This can most easily be achieved by stating distances from the X-ray equipment to the 7.5 Sv h-1 or 2.5 Sv h-1 time averaged dose rate contour, as appropriate. 9 Where it is reasonably practicable, the controlled area boundary is to be set at a distance greater than that which equates to 7.5 Sv h-1. Warning signs 10 Warning signs are to be displayed at appropriate points around the perimeter of the controlled areas, such that a person approaching the controlled area from any direction would be made aware of the hazard. 11 A pre-exposure alarm is to signal when the X-ray equipment is about to be energized prior to exposure. The pre-exposure alarm is to be audible up to the moment of exposure and then terminate automatically when the X-ray equipment is discharged. The duration of the pre-exposure warning alarm is to be sufficient for anyone within the controlled area to walk clear. An appropriate number of sentries are to patrol the perimeter of the controlled area to prevent unauthorised entry. 12 It is impracticable to provide a distinct exposure signal, due to the extremely short exposure time (in the order of micro-seconds). 13 The pre-exposure signal must be clearly explained on well sited notices at the boundary. The notices are to explain the significance of the barrier. Warning signals and notices may be combined in the form of illuminated notices. 14 All warning signals are to be examined and tested on a regular basis and records are to be kept of the tests undertaken. Operating procedures 15 Flash X-ray equipment is to be operated in accordance with local orders and the manufacturer's operating instructions. PULSED X-RAY EQUIPMENT 16 Pulsed X-ray equipment includes equipment such as the Golden and Inspector series of X-ray sets, used for radiography of potentially explosive devices. Classification of Persons and Dosimetry 17 It is not normally necessary for operators to become classified persons.

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18 Radiation dosemeters, issued by an Approved Dosimetry Service, usually the Dstl ESD Alverstoke ADS, may be required as advised by the RPA. A record of the number of pulses made is to be maintained for each operator. Controlled areas 19 A controlled area is to be established and where necessary cordoned, around the X-ray equipment. The extent of controlled areas are to be determined by calculating the appropriate distance from the source to the position where the time averaged dose rate will not exceed 7.5 Sv h-1 within an establishment, or 2.5 Sv h-1 in public places. In practice, it is explosives safety considerations which are most limiting, and the controlled radiation area will be contained within the explosive safety distance. Where consistent with explosives safety considerations, an appropriate number of sentries are to patrol the perimeter of the controlled area to prevent unauthorised entry. Operating procedures 20 Pulsed X-ray equipment is to be operated in accordance with local orders and the manufacturer's operating instructions. The controlled radiation area (as specified above) is to be cleared of personnel until the operation is complete. When using pulsed X-ray sets, where practicable, the X-ray set is to be directed towards solid walls.

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LEAFLET 29 ITEMS AND COMPONENTS CONTAINING THORIUM CONTENTS Para 1 3 4 5 6 7 8 9 13 14 15 Table 1 2 Annex A B C D E Thoriated magnesium alloy components hazard and risk information Thoriated lenses hazard and risk information Thoriated gas mantles hazard and risk information Thoriated welding electrodes hazard and risk information Thoriated night flares hazard and risk information Scope Statutory requirements and parallel arrangements Duties Commanding Officer (CO) Radiation Safety Officer (RSO) Radiation Protection Supervisor (RPS) Workplace Supervisor (WPS) Employees Nature of thorium Hazards Risk assessments for items and components containing thorium Risk assessments for work involving laboratory compounds of thorium Legal and MOD mandatory requirements Page Hazards associated with items and components containing thorium .............................................4 Legal and MOD mandatory requirements for items and components containing thorium..............5

SCOPE 1 Thorium, which is a naturally occurring radioactive material, is widely used within MOD in magnesium alloy aircraft components, optical lenses, night flares and some laboratory compounds. Less widely used, now, but still in service in some areas are thoriated gas mantles and thoriated welding rods. Thorium is not used for its radioactive properties but rather because of its physical properties such as a hardening agent in lightweight magnesium alloys, for the optical qualities it imbues when incorporated in lenses or lens coatings and for its incandescence properties. 2 This leaflet describes the radiological requirements for keeping, using and disposing of such items and components. General information and instruction on the hazards associated with thorium, personnel duties and responsibilities and statutory and MOD mandatory requirements is provided in the body of the leaflet. Further information and guidance on each major type of item or component and the risks posed is provided at the Annexes. The RPA is to be consulted for detailed advice on specific applications involving thorium.

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STATUTORY REQUIREMENTS AND PARALLEL ARRANGEMENTS 3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the Management of Health and Safety at Work Regulations 1999, the following specific legislation applies directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: Ionising Radiations Regulations 1999 (IRR99) (apply directly). Radioactive Substances Act 1993 (RSA93) (parallel arrangements). Radioactive Substances (Uranium and Thorium) Exemption Order 1962 (parallel arrangements). Radioactive Substances (Prepared Uranium and Thorium Compounds) Exemption Order 1962 (parallel arrangements). Carriage of Dangerous Goods and Transportable Pressure Equipment Regulations 2007 (apply directly).

DUTIES Commanding Officer (CO) and Head of Establishment 4 The Commanding Officer (CO) has a duty to the Secretary of State, and a personal responsibility, to protect the environment and secure the health, safety and welfare of their staff at work. The CO is also required to protect persons not in MOD employment (e.g. members of the public) against risks to their health and safety arising from the MOD work activities. This includes radiation safety. The COs authority (but not responsibility) for radiation safety management arrangements may be delegated to appropriate personnel, such as a Radiation Safety Officer (RSO). Radiation Safety Officer (RSO) 5 The Radiation Safety Officer (RSO) is to ensure that: They are familiar with the specific radiation hazards of work involving thorium items or components at their unit or establishment and that an appropriate risk assessment has been carried out. Local orders include the requirements for keeping, using and disposing of thorium items and components as detailed in this leaflet. Staff are appointed, instructed and trained in their duties relating to this leaflet. The requirements stemming from this leaflet are subject to audit.

Radiation Protection Supervisor (RPS) 6 An RPS must be appointed where it is necessary to designate areas as controlled or supervised for further details see Table 2. Where an RPS is appointed, they are to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet. Workplace Supervisor (WPS) 7 In units holding thorium items and components but where it is unnecessary to appoint an RPS, a WPS is to be appointed with duties to ensure that work is carried out in accordance with the local orders for radiation safety which are to include the requirements of this leaflet.

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Employees 8 It is the responsibility of all employees to ensure that they are familiar with the relevant parts of local orders to ensure that these items and components are handled safely and correctly. Any incidents are to be reported to the appropriate supervisor or line manager. NATURE OF THORIUM 9 The major source of thorium in nature is monazite sand containing up to 12% by weight of thorium oxide. Thorium occurs in nature as thorium-232 (Th-232) which has an extremely long half-life (many millions of years). Th-232 has 10 radioactive daughters (which include Th-228) of much shorter halflives which exist in equilibrium with the parent nuclide and contribute to the overall radioactivity of natural thorium. The activity of natural thorium is 4.1 kBq g-1 of Th-232 together with similar activity levels of each daughter (including Th-228). Th-232 together with its daughters emit alpha, beta and gamma radiation. 10 Thorium and thorium/magnesium alloys are prone to corrosion if allowed to weather, resulting in a loose powdery oxide which can pose a contamination hazard. 11 Specialised chemical processing, such as that used to prepare laboratory compounds, can separate Th-232 (and Th-228) from other daughter nuclides resulting in a rather different nuclide and radiation profile. For bulk solids containing processed thorium, the full equilibrium is slowly restored over about 30 years. Finely divided thorium (e.g. a powder) can allow the release of the gaseous daughter product radon-220 (also called thoron) which can affect the equilibrium and change the nuclide and radiation profile. 12 Detailed advice on the radioactive nature and properties of thorium can be sought from the RPA.

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HAZARDS Table 1 Hazards associated with items and components containing thorium Radiation type Emitted Comments High energy alpha radiation is emitted by Th-232 and 6 of its 10 radioactive daughter products. Alpha radiation is absorbed effectively by a thin layer of all materials including the dead surface layer of skin or a few cm of air and hence is not normally considered an external radiation hazard. However, in the case of some optical lenses containing or coated with thorium material, a significant alpha dose could be received by the eye (surface of the cornea) if the eye is placed close to the thoriated lens. Alpha radiation poses a potential internal hazard e.g. inhalation of airborne thorium material (machining, gas mantles, welding, night flares), ingress through or via the skin of loose thorium arisings and ingestion of contamination. Finely divided thorium (powders etc) can allow some Radon-220 (daughter product) gas to reach atmosphere this leads to an additional internal radiation hazard. Beta radiation is emitted by 5 of the 10 radioactive daughters of Th-232. Beta radiation penetrates through thin layers of material and travels up to a few metres in air. Beta will contribute to the external radiation dose received by the eye from some thoriated lenses (see above). Beta will also contribute to the external radiation dose where personnel are in close proximity to thorium items and components containing thorium alloys. In the latter case, only beta radiation from surface layers (a few mm in depth) contributes to dose due to self absorption of beta emitted within the bulk material. Beta radiation poses a potential hazard from inhalation, ingress through or via the skin and ingestion as indicated for alpha above. Low levels of Bremsstrahlung radiation (X-rays) are emitted from items and components containing thorium. Gamma radiation is emitted by thorium and its daughter products. This gives rise to an external radiation hazard. Dose rates are dependent on concentration and quantity of thorium and also the design and structure of the equipment. Dose rates can be sufficient to require areas to be designated as controlled or supervised (see annexes to this leaflet).

Alpha

Direct Beta

Bremsstrahlung

Gamma

X-rays Neutrons

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RISK ASSESSMENTS FOR ITEMS AND COMPONENTS CONTAINING THORIUM 13 A risk assessment is to be carried out by units and establishments, in consultation with the RPA, on each new or existing activity using equipment containing thorium. The assessment must take account of local factors and recommended control measures. Leaflet 2 describes the process to be followed in carrying out a radiological risk assessment. The general legal and MOD mandatory requirements for work with thorium are given in Table 2. Specific hazard and risk information for the following applications is given at Annexes A to E respectively: Thoriated magnesium alloy components (e.g. aircraft engine components). Thoriated lenses. Thoriated Gas Mantles. Thoriated welding electrodes. MILAN thoriated night flare.

Risk assessments for work involving laboratory compounds of thorium 14 Work with thoriated laboratory compounds invariably involves work with open sources of radioactivity. The hazards and risks of this work and the necessary control measures vary widely depending on the application. For this reason, the RPA must always be consulted prior to the work commencing in regard to the prior risk assessment, the need for area designation, contingency plans and the control measures necessary for safe management of the work and use and disposal of the radioactive materials. LEGAL AND MOD MANDATORY REQUIREMENTS 15 Table 2 below summarises the legal and MOD mandatory requirements for work involving thorium items and components. Further guidance for the thorium in optical lenses, thoriated engine components, MILAN flares, thoriated welding electrodes and radioactive gas mantles is given at the Annexes to this leaflet. For other applications of thorium or in cases of doubt, the RPA is to be consulted for advice. Table 2 Legal and MOD mandatory requirements for items and components containing thorium Requirement HSE Authorisation HSE Notification In general, work carried out involving thorium items and components is to be notified to HSE in accordance with Leaflet 3. Exceptionally, where the concentration of thorium is less than 10 Bq g-1, HSE need not be notified. Items and components containing 4% by weight or less of natural thorium are exempt from notification (this includes most MOD applications). Incandescent mantles are exempt from notification. Items containing more than 4% of natural thorium are exempt from notification provided that the total weight of thorium present on the premises at any one time does not exceed 2 kg. This is required for work with thorium items and components in accordance with Leaflet 2. Basic information on the major MOD applications is provided at the Annexes to this leaflet. Applicable Comments Related leaflet*

EA Notification**

(but see comment)

Risk Assessment

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JSP 392

Radiation Safety Handbook

Table 2 Legal and MOD mandatory requirements for items and components containing thorium (continued) Requirement Applicable Comments Gas mantles are to re-stocked using nonradioactive variants. Use of thoriated welding electrodes is to be avoided if practicable. Alternatives to thoriated lenses are to be considered in the design of equipment. Stocks of spares of thoriated items and components are to be kept to the minimum necessary to meet operational requirements. See Annexes to this leaflet for further specific information on the control measures advised for rest