Ionising Radiations Regulations 2017: Notification of offshore site radiography work

In 2017 the Ionising Radiations Regulations came into force. With regards to Industrial radiography this meant that there were changes to how Dutyholders undertaking this kind of work were to operate compared to the previous requirements of the 1999 regulations.

Regulation 7 of the Ionising Radiation Regulations 2017 (IRR17) requires employers who carry out industrial radiography to gain consent from the HSE. Once granted that consent is subject to conditions one of which is that:

no site radiography will take place without the consent holder receiving at least seven days' written notice from the client commissioning the site radiography work on each and every occasion the work is carried out, or written HSE agreement to waive this requirement

This condition is different as previously under the 1999 regulations Dutyholders used to have to contact HSE 7 days in advance to undertaking any radiography operations. Annex 1 to this Notice describes the notification requirements and indicates how they can be complied with for offshore site radiography, including repeat notifications, and notification of unforeseen and emergency work.

Annex 1 – Notification requirements for offshore site radiography work

Introduction

1. The Ionising Radiations Regulations 2017 (IRR17) require employers undertaking site radiography to have permission in writing from their client before carrying out the work. If there are special circumstances which mean that this advance notice cannot be achieved there are some waivers which can be granted if specified criteria is met. This annex describes the requirements and indicates how they can be complied with for offshore site radiography.

2. The term 'site radiography' means any radiography of inanimate objects other than that which is carried out in an enclosure or cabinet.

Notifications and waivers

3. Employers must have at least 7 days’ notice in writing from their client before carrying out site radiography. However, employers can apply to the HSE to have this condition waived and this document sets out the procedures for granting these waivers and the circumstances in which these waivers can be granted. A request for a waiver must be received through the [email protected] email account.

4. A 7-day prior notification should only cover a period of up to 1 week of continuous site radiography on a site with no breaks (days off) in the work.  At the end of the 7 days a new 7-day notification would need to come in to force or a waiver would need to be applied for.

There are three types of waiver requests

1. Applications concerning embedded work
2. Applications over a given time period for periodic work.
3. Applications in emergency situations.

5. Embedded work is when the site radiography company has a permanent presence on their client's site. They will store their radioactive sources and/or radiation generators on the client's site and will normally have an office or other premises on their client's sites which they use as a base and from which they operate.

6. Site radiography companies may be called upon to carry out site radiography periodically at the same client's site over a given time period. The nature of their client’s work means that they cannot be specific about the date and time the site radiography will be required, or how often, but they do know that it will be required over a given time period. (This is akin to the old 'blanket' notifications received under the IRR99). They have given written notice of this work to the site radiography company and the latter subsequently applies to the HSE to have the 7 day consent condition waived as they cannot be certain when they will be required to carry out the work.

7. In cases of an emergency a site radiography company may be called upon to carry out work without 7 days' written notice being given by their client. An example of an emergency situation is when site radiography is necessary in order to maintain, or minimise the loss of, an essential energy supply. In these cases the site radiography company will apply to the HSE to have the 7 day consent condition waived as it is impossible for the client to give the required written notice.

8. The consent to carry out industrial radiography is granted to the employer who carries out that practice. A waiver from a consent condition can only be requested by that employer. The client or another third party cannot apply for a waiver.

Waivers requested during office working hours

9. If a request for a waiver occurs during office working hours (i.e. 9am – 5pm, Monday to Friday), an email request must be sent to [email protected] with a brief outline of the reason for the waiver request. If further assistance is required during office working hours please call:

• 0203 028 3051
• 0203 028 3435

One of the Radiation Specialist Inspectors will assess the application and issue the appropriate waiver if deemed a suitable request. i.e., an emergency waiver will not be granted if it is considered that poor planning was the cause for the standard 7 days notification by the client could not be applied.

Waivers requested out of office working hours

10. If a waiver for emergency work is requested out of office hours or on a public holiday, there will be no appropriate HSE staff on duty to consider the request. In these circumstances, and ONLY in these circumstances, work may commence as long as the Dutyholder:

1. can satisfy the requirements listed below * and
2. ensure HSE is notified that the work has been carried out by sending an accompanying email to [email protected] (an automated reply will be emailed back stating work can undergo subject to conditions)

* The work may only be carried out provided they liaise fully with their client and relevant authorities in control of the site regarding your arrival, the assessment of non-radiological risks present on site, the radiological risks associated with the proposed work, and restriction of access to the controlled area(s). Any further work not included in this notification will be subject to the usual 7 day notification requirement.