Work with ionising radiation that requires consent

You will need to apply to HSE for consent if you wish to administer radioactive substances to:

• people for medical purposes
• animals for veterinary purposes

This consent will apply to all fixed sites operated by the employer where you carry out this practice.

Examples

You work in an NHS Trust administering radioactive substances to patients:

• through either the injection, ingestion or inhalation of radioactive substances
• in the form of a sealed source (brachytherapy) (HASS used for brachytherapy is covered by the working with HASS practices).

You work in a veterinary practice administering radioactive substances to animals, through either the injection, ingestion or inhalation of radioactive substances. 

If you manufacture or produce products that have radioactive substances deliberately added to them, you will need consent from HSE for this work practice. This includes where radioactive substances are added to medicinal products by a radiopharmacy.

The consent will only apply to the addition of radioactive substances in the production and manufacture of these products. Any other practice associated with these products, including the sale of the products, is not covered by the consent. The consent will apply to all fixed sites you operate where this practice is carried out.

The deliberate addition of radioactive substances in the production or manufacture of any consumer product will require justification under the Justification of Practices Involving Ionising Radiation 2004 (on legislation.gov.uk).

Examples

You work in:

• an NHS Trust radiopharmacy
• the radiopharmaceutical industry
• a research facility that adds radioactive substances to make tracers 

The regulations define an accelerator as an apparatus or installation in which particles are accelerated and which emits ionising radiation with energy higher than 1 MeV.

You must apply for consent for an accelerator unless you are working with an electron microscope. The consent will apply to all fixed sites you operate where you carry out this practice.

Examples

You work:

• in an NHS Trust using an accelerator to perform radiotherapy
• with a particle accelerator for the purposes of research

The regulations define industrial radiography as the use of ionising radiation for non-destructive testing purposes where an image of the item under test is formed. This excludes any such testing which is carried out in a cabinet which a person cannot enter. A person being able to enter a radiography cabinet means a person being able to reasonably step into the cabinet and stand inside with the door closed. No crawling or shuffling or excessive contortion would be required to get inside.

If you are carrying out industrial radiography using either radioactive sources (for example HASS), accelerators or radiation generators, you will need consent from HSE for this practice.

The consent will apply to:

• industrial radiography in enclosures on all fixed sites you operate where you carry out this practice

• sites where you perform site radiography in line with the conditions associated with this consent
• the transport of the radiation sources used for the purposes of industrial radiography between sites.

HSE does not consider the use of X-rays for the inspection of mail, packages or baggage, or for security purposes as industrial radiography.

Examples

You use ionising radiation to inspect welds on a variety of structures at fixed locations you are responsible for. 

You inspect welds on a variety of structures at sites you are not responsible for (site radiography). 

The regulations define this as the use of ionising radiation to sterilise, process or alter the structure of products or materials.

You must apply for consent if you perform industrial irradiation using:

• radioactive sources (for example HASS)
• accelerators
• radiation generators

The consent will apply to all the fixed sites you operate where you carry out this practice.

Examples

Where you:

• work with a particle accelerator to perform ion implantation
• use ionising radiation to sterilise articles or food
• use neutrons to activate materials

The Ionising Radiations Regulations 2017 define this as a sealed source for which the activity of the radionuclide is equal to or exceeds the relevant activity value set out in Schedule 7, Part 4 (on legislation.gov.uk).

You must apply for consent if you are performing work with or transporting a HASS, unless you are performing the specified practices of industrial radiography or industrial irradiation and have consent for them.

The consent will apply to all fixed sites you operate where you carry out this practice. 

Examples

Where you:

• work in an NHS Trust using HASS for brachytherapy or radiotherapy
• supply HASS to other operators
• work in a research facility and irradiate biological materials with HASS

HSE considers the long-term storage or disposal of radioactive waste to be a very specific practice and, therefore, it only applies to a small number of sites in Great Britain. This will only appear as an option to the duty holders responsible for these sites.

Examples

You work:

• in a recognised installation for the long-term storage of radioactive waste facility  
• on a site that disposes of (non-exempt) radioactive waste to land, such as a landfill 

You will need to apply for consent if you discharge radioactive material with airborne or liquid effluent into the environment and expect the quantities of radioactive material, in a single discharge, to exceed the quantities specified in the Ionising Radiations Regulations 2017, Schedule 7, Part 1, column 5 (legislation.gov.uk). (Except for gallium-67 where the quantity exceeded is 10¹¹ Bq and for zirconium-89 it is 10¹⁰ Bq)

The consent will apply to all the fixed sites you operate where you carry out the practice.