HSE statement on radiation protection advisers

Purpose

1. This document, published by the Health and Safety Executive (HSE), specifies HSE’s Criteria of Core Competence for Radiation Protection Advisers (RPAs).  The criteria cover both any individual or body that may be consulted or appointed by an employer as an RPA to give advice on compliance with the Ionising Radiations Regulations 2017 (IRR17) and/or The Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR19). The Statement also includes the specific requirements that Assessing Bodies have to meet to be recognised by HSE for the purpose of assessing the competence of individuals to act as RPAs. This statement replaces and supersedes the requirements of that published on 31st March 2007. For new individual applicants seeking to obtain certificate of competence, applicants wishing to be recognised as an Assessing Body or RPA Body and Assessing Bodies and RPA Bodies recognised under the 2007 system the provisions of this 2020 document come into effect 4 months from its date of publication (unless, in the case of Assessing Bodies and RPA Bodies, an extended period has been agreed with HSE).

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Introduction

2. The role of an RPA is set out in Regulation 14(1) and Schedule 4 to the IRR17. Broadly, it is to advise an employer engaged in work with ionising radiation on compliance with IRR17 and/or REPPIR19. This includes those radiation protection matters necessary to comply with the Regulations.

3. The purpose of the recognition procedure described in this Statement is to give employers confidence that any person or body recognised as an RPA has essential competence in giving advice on compliance with IRR17 and the applicability of REPPIR19. An employer who works with ionising radiations is required to consult, and where necessary, appoint an RPA on the matters set out in Schedule 4 of IRR17 and Regulation 24 of REPPIR19.  In addition, an employer should also consult an RPA on other matters where advice is needed to comply with IRR17. Further guidance is provided in ‘Work with Ionising Radiation’ L121 (second edition) paragraph 254 and 255. The employer must select an RPA, or an RPA body with the necessary knowledge and experience to make them suitable to give advice in relation to the employer’s particular line of work and the particular compliance questions to which they require an answer.

4. Regulation 2 of IRR17 defines an RPA as “an individual who, or a body which, meets such criteria of competence as may from time to time be specified in writing by the Executive” [Footnote 1]. An individual awarded a Certificate of Core Competence from an HSE recognised RPA Assessing Body or holding a Radiological Protection Level 4 National or Scottish Vocational Qualification (N/SVQ) is considered by HSE to meet the IRR17 core competency requirements for their appointment as an RPA by an employer. The Criteria of Core Competence for an individual RPA are outlined in Part I of Annex 1 of this Statement. A body which meets the Criteria of Core Competence is known as an RPA Body. The Criteria of Core Competence for an RPA Body are outlined in Part II of Annex 1 of this Statement.

5. This Statement lays down the written criteria of competence referred to in Regulation 2 and contains the following:

• the HSE Criteria of Core Competence for individuals and bodies intending to give advice as RPAs;
• the HSE requirements for organisations which undertake the task of assessing individuals against the relevant Criteria of Core Competence (these organisations are referred to in this document as Assessing Bodies).

Key definitions and terms used within the Statement are included at Annex 4 Criteria of core competence

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Criteria of core competence

6. The HSE Criteria of Core Competence for individuals who wish to act as RPAs are set out in Part I of Annex 1. These Criteria of Core Competence are appropriate for work in all sectors. Applications for recognition by individuals who do not hold a valid N/SVQ should be made to an Assessing Body recognised by HSE for this purpose and not to HSE. Certificates awarded by an Assessing Body will be subject to periodic reassessment, normally every five years.

7. The HSE Criteria of Competence and other requirements for RPA Bodies are set out in Part II of Annex 1 (details on how to apply can be found in HSE’s guidance on the Criteria of Core Competence and other requirements for RPA Bodies). HSE letters of recognition of RPA Bodies will be valid from the date of issue and may be reviewed or reassessed from time to time by HSE. Any organisation wishing to act as an RPA Body should apply to HSE with sufficient information to show that it meets these requirements. Arrangements for HSE assessment of applications for recognition (and renewal of recognition) are set out in Part II of Annex 1. HSE will maintain a publicly available list of all organisations which it has recognised as RPA Bodies, together with contact details. This information, and further guidance on the Criteria of Core Competence for RPA Bodies, may be found on HSE’s website (see http://www.hse.gov.uk/radiation/ionising/index.htm).

8. HSE and Assessing Bodies recognised by HSE will have regard for the principles and approach set out in HSE’s Enforcement Policy Statement when assessing a person or organisation for recognition as an RPA.  HSE will also apply these principles in assessing an organisation’s suitability to be an Assessing Body.  In particular, assessment processes and procedures will be proportionate and consistent. HSE and Assessing Bodies will help applicants understand what is expected of them and what they should expect from the HSE or Assessing Body and there will be effective arrangements for handling complaints.

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Assessing bodies

9. The purpose of an Assessing Body is to certificate individuals who wish to become or continue to be recognised as an RPA under IRR17. An organisation that wishes to be recognised by HSE as an Assessing Body must be able to demonstrate to HSE that it has:

• schemes in place which meet the requirements set out in Annex 2;
• an organisational structure and arrangements capable of ensuring that these schemes continue to meet the requirements; and
• sufficient human and other resources to operate efficiently and to maintain resilience such that they can continue to provide a service in accordance with their recognition by HSE.

10. Organisations wishing to become Assessing Bodies should apply to HSE with sufficient information to show that they meet the requirements set out in Annex 2. HSE will maintain a publicly available list of all organisations it recognises as Assessing Bodies, together with contact details. Arrangements for HSE assessment of applications for recognition as an Assessing Body, and renewal of recognition, are set out in Annex 2. The recognition of an Assessing Body may be reviewed or reassessed from time to time by HSE. However, if HSE receives a complaint / allegation about the operation of an Assessing Body HSE may review its operations immediately.

11. HSE recognition of organisations as Assessing Bodies will be restricted to the purpose of establishing the RPA core competence requirements for individuals. Assessing Bodies must recognise the certificates of other Assessing Bodies.

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Suitable RPAs

12. Holding a certificate from an Assessing Body (or possessing an appropriate National or Scottish Vocational Qualification) does not, of itself, make the holder a suitable RPA for an employer to consult, as required by regulation 14(1), IRR17 and regulation 24 of REPPIR19. It is only recognition of core competence to give advice on compliance with IRR17 including those radiation protection matters necessary to comply with the Regulations. Similarly, a written statement of HSE recognition held by an RPA Body only relates to that organisation’s Core Competence to give advice as an RPA. Employers will need to satisfy themselves that the individual RPA (or RPA body) they appoint also possesses the specific knowledge and experience required for giving advice on their particular work, working conditions or circumstances, in order to satisfy the test of suitability in regulation 14(1) IRR17 and regulation 24(1) of REPPIR. For example, an employer involved in the transport of radioactive material would need to consider whether the RPA they intend to consult or appoint was aware of the association between the IRR17 radiation risk assessment and the Class 7 emergency planning requirements of relevant transport regulations (Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009). Judgements about such knowledge and experience (and thus suitability) do not form part of the HSE Criteria of Core Competence.

James Taylor
RPA  Programme Manager
Health & Safety Executive
30th August 2021

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Annex 1: Criteria of core competence for radiation protection advisers

Introduction

1. This annex is in two Parts covering the separate circumstances of individuals wishing to be recognised as RPAs and organisations seeking recognition as RPA Bodies. Both parts are concerned with RPA core competence issues.

Part I - Individual RPAs

HSE Criteria of Core Competence for first time recognition

2. Individuals wishing to demonstrate for the first time that they satisfy the definition of an RPA in IRR17 must, either:

• obtain a valid certificate of core competence from an organisation recognised as an Assessing Body by HSE for this purpose; or
• obtain a Radiation Protection Level 4 National or Scottish Vocational Qualification (N/SVQ).

3. To obtain a certificate from an Assessing Body, individuals must provide evidence largely from education, training and/or experience that is sufficient to satisfy that Body that the individuals have:

• a knowledge and understanding that meet the level stated for each topic referred to in Annex 3 of this Statement;
• a detailed understanding of IRR17 and its ACOP, together with a knowledge of non-statutory HSE guidance in ‘Work with Ionising Radiation’ (HSE Books L121 second edition);
• knowledge of operational radiation protection methods, especially:
  • interpretation and application of radiation protection data;
  • work supervision;
  • radiological measurements;
  • control procedures for work involving the potential for significant radiation exposure; and
• The ability to give adequate advice or to have given adequate advice to duty holders and employers on compliance with IRR17 and the applicability of REPPIR19.

(Items a to c may be demonstrated via item d as the ability to give the correct advice often depends upon knowledge of these items).

4. Though it is possible for an individual to demonstrate aspects of their core competence through education only or training only, HSE requires candidates to have practical experience as well for the elements of the basic syllabus in Annex 3 where the definition of core competence calls for detailed understanding (DU). This practical experience will primarily be based on the individual’s workplace experience, although evidence derived from simulation exercises may also be acceptable. The evidence required should be proportionate and take into account the candidate’s qualifications, training and experience (see Annex 3).

5. Certificates awarded by Assessing Bodies may be withdrawn at any time subject to the provisions in Annex 2 paragraphs 15-19.

6. Many individuals develop their capability to act as RPAs through working in one of the main industry or service sectors characterised by significant use of ionising radiations. However, recognition of individuals as RPAs for the purpose of regulation 2 of the IRR17 is only concerned with RPA core competence and is not related to particular sectors.

7. An RPA Assessing Body, when assessing an individual’s competence to act as an RPA, must take into account the professional standing of that individual in radiological protection. Thus, if the individual is a Chartered or Incorporated Radiation Protection Professional (CRadP or IRadP) or a full member of the Society for Radiological Protection, the Association of University Radiation Protection Officers, or Institute of Physics and Engineering in Medicine, or a certified Medical Physics Expert or Radioactive Waste Adviser then the assessing body will not need to, except in exceptional circumstances, seek evidence related to that individual’s competence in relation to those items listed as GA and BU in Annex 3. In these circumstances the assessing body need only assess the items listed as DU in Annex 3.

HSE Criteria of Competence for renewal of recognition

8. Certification by an Assessing Body will be subject to periodic review, normally every five years. When a review is requested by the Assessing Body the individual will need to reapply to the Assessing Body that awarded the certificate, or apply to another recognised Assessing Body, providing suitable evidence that they have kept their knowledge of radiation protection legislation and developments of radiation protection practice up to date since last review (see Annex II).

9. Individuals who hold a relevant Level 4 N/SVQ issued more than five years previously will need to apply to an Assessing Body for renewal of recognition, providing suitable evidence that they have kept their knowledge of radiation protection legislation and developments of radiation protection practice up to date.

10. In either case acceptable evidence must include keeping up to date on the application of the IRR17 and may include reading relevant scientific or other journals, taking part in appropriate discussion groups and private study, as well as attendance at courses, HSE events, RPA update meetings, scientific seminars, etc. Acceptable evidence may also be derived from membership of a recognized and appropriate Continuing Professional Development (CPD) scheme.

11. Advice on the requirements of IRR17 (and REPPIR19 where relevant) will form the bulk of the evidence required for the review. For those seeking a certificate of competence for the first time or those who have not been formally appointed as an RPA, simulated evidence or evidence of the advice that would be given to an employer or similar should be acceptable. For those seeking a renewal of their certificate of competence who are practicing RPAs the evidence should consist of the advice they have provided to the employer(s). For those RPAs seeking renewal who have been on a career break or similar, the advice they would have given an employer should be acceptable.
12. The assessing body must take into account any information brought to their attention where advice provided by the RPA has directly resulted in non-compliance with IRR17 or REPPIR19 in the view of the relevant regulator. Where poor or incorrect RPA advice has led directly to enforcement action against an employer by HSE or ONR this may be reported by the relevant Regulator to the assessing body. In such cases, the assessing body should require evidence that the individual has subsequently adjusted their advice accordingly and passed any relevant lessons learned to any other employer for whom they act as RPA, and, if not, take appropriate action in line with their written complaints procedures.

13. During the review the assessing body should take into account any instances of inappropriate professional behaviour brought to its attention where that behaviour has or may have adversely affected the quality or implementation of RPA advice or the individual’s standing as an RPA.  The assessing body should also have procedures for reporting such incidences to the relevant professional institutions if the RPA holds such membership.

Part II - RPA Bodies

Criteria of Core Competence and other requirements

14. For a body to meet the definition of an RPA in IRR17 it must demonstrate to HSE that it:

• is constituted as, or comprises an identifiable part of, a legal entity or partnership or other grouping that is capable of being recognised;
• has personnel who include a sufficient number of persons who satisfy the Criteria of Core Competence for individual RPAs, either by holding relevant level 4 N/SVQs issued no more than five years previously or valid certificates from an Assessing Body to act as an individual RPA; and
• has management systems and written quality assurance procedures, such that any radiation protection advice given either internally to other parts of the organisation or externally on behalf of the organisation is consistent and traceable, as appropriate, to one or more individuals holding valid qualifications or certificates as provided by Part 1 of these HSE Criteria of Core Competence. (The requirement for management systems and written quality assurance procedures only applies where an RPA Body includes personnel other than RPAs).

15. The number of personnel required to hold a certificate in order to satisfy paragraph 14(b) will depend on the systems and procedures provided to ensure that any advice is traceable to generic or site specific guidance from an individual recognised as an RPA.

16. Any organisation wishing to be recognised as an RPA Body should apply to HSE using the [email protected] email address. They should provide sufficient information to show that it satisfies the requirements in paragraph 14. HSE may withdraw an RPA Body’s recognition at any time following an investigation that confirms that these requirements are no longer met (see paragraphs 20-24 below).

HSE arrangements for assessing applications

17. HSE will acknowledge all such applications promptly and indicate when the applicant will receive a response. Applications for recognition will be considered by the RPA Programme Manager and peer reviewed by another radiation specialist inspector. There will be adequate opportunity for an exchange of views and HSE may ask:

• for better evidence in support of the application; and
• that representatives attend a meeting at a suitable HSE office to clarify any points which are unclear in the information provided.

The RPA Programme Manager or a radiation specialist inspector acting on their behalf may arrange to visit the organisation to help determine whether that organisation is fit to be recognised as an RPA Body.

18. Where a body satisfies HSE that it meets the Criteria of Core Competence and other requirements, HSE will provide a written statement of recognition for the purposes of the definition of a radiation protection adviser in IRR17. That statement will specify any conditions which must be fulfilled for recognition to remain valid. HSE will notify the RPA Body if a reassessment of recognition is required giving three months’ notice for renewal to be obtained.

Refusal of HSE to recognise an organisation as an RPA body

19. If HSE intends to refuse an application for recognition as an RPA Body the organisation will be given reasons in writing why this action is being considered. The organisation will be given at least two weeks to make further representations, which will be considered by the RPA Programme Manager (who will decide on the appropriate action to take). Final decisions will be confirmed in writing and, where necessary, will include information on how to appeal against the RPA Programme Manager’s decision and to whom.

Investigation and withdrawal of recognition

20. HSE will investigate situations which come to its attention, for instance through a complaint, where it appears that an RPA Body that has been recognised by HSE does not meet the requirements in this Annex. HSE will also investigate situations brought to its attention where advice provided by the RPA Body has directly resulted in non-compliance with IRR17 or REPPIR19 in the view of the relevant regulator. Where any of these investigations confirms this to be the case, HSE will instigate a review process and may subsequently withdraw recognition.

21. Where HSE has concerns regarding the operation of or the advice given by an RPA body it will first write to the RPA body explaining the concerns and asking the RPA Body to conduct an initial enquiry, reporting back to HSE within an agreed timescale. HSE will only proceed with the investigation where it is not satisfied that all matters of concern have been satisfactorily resolved by the RPA Body’s response. Where HSE considers it necessary to proceed with the investigation, HSE’s published Complaints and Investigations Procedures will be followed.

22. If HSE intends to withdraw recognition from an RPA Body the Body will be given reasons in writing why this action is being considered. The RPA Body will be given at least one month to make further representations, which will be considered by the RPA Programme Manager who will decide on the appropriate action to take. Final decisions will be confirmed in writing, where necessary giving information on how to appeal against the RPA Programme Manager’s decision and to whom.

23. HSE will provide each RPA Body from which it has withdrawn recognition a written explanation as to why it is considered not to meet the requirements in this Annex. HSE will also remind the RPA Body that it should inform employers for whom it is acting as an RPA that its recognition has been withdrawn. HSE will also explain how the RPA Body can appeal against the decision.

24. HSE will give prompt notification of the outcome of the appeal to any appellant

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Annex 2: Requirements for RPA assessing bodies

Requirements to be met by organisations assessing individuals against the HSE Criteria of Core Competence to act as radiation protection advisers (RPAs) under the Ionising Radiations Regulations 2017 (IRR17)

HSE Recognition

1. Organisations acting as Assessing Bodies for certificating individuals who wish to become or continue to be RPAs under IRR17 need formal recognition from HSE. That recognition can be withdrawn by HSE as explained in paragraphs 21 to 23, though any certificates of core competence issued to individuals would remain valid. To gain recognition, an organisation must be able to demonstrate to HSE that it:

• is constituted as, or comprises an identifiable part of, a legal entity or partnership or other grouping that is capable of being recognised;
• has in place formal schemes which meet the requirements set out in this annex below; and
• has an organisational structure and management arrangements to ensure that these formal schemes are (i) subject to review and continuous improvement and in particular are not open to arbitrary change and will continue to meet those requirements (e.g. changes to the schemes have to be agreed by a Board, Governing Body or equivalent); and (ii) reflect the principles of the HSE’s Enforcement Policy Statement.
• Has adequate human and other resources to operate effectively and to maintain resilience.

2. An organisation wishing to be recognised as an Assessing Body for the purpose of certificating individuals as radiation protection advisers in accordance with the criteria in this statement should apply to HSE via the [email protected] email address. They should supply sufficient information to show that it satisfies the requirements in this Annex. HSE will acknowledge all such applications promptly and indicate when the applicant will receive a response. Applications for recognition will be considered by the RPA Programme Manager. HSE may ask, after any necessary discussion:

• for better evidence in support of the application; and
• that representatives attend a meeting at a suitable HSE office to clarify any points which are unclear in the information provided.

The RPA Programme Manager or a radiation specialist inspector acting on their behalf may arrange to visit the organisation to help determine whether that organisation is fit to be recognised as an Assessing Body.

3. HSE requires those seeking to be assessing bodies to supply, as a minimum, the following documentation:

• The procedures for assessing applicants (see paragraphs 12 & 13)
• Any guidance on making applications
• Any guidance given to assessors
• The procedures for dealing with appeals, complaints, and for the withdrawing of certificates
• Details of the management and administration of the organisation.
• Evidence that they possess adequate human and other resources to operate effectively and to maintain resilience.

4. HSE recognition of Assessing Bodies will be subject to conditions and may be reassessed from time to time. HSE will consider whether the organisation continues to satisfy the requirements in this Annex and remains fit to be recognised as an Assessing Body. Arrangements for dealing with reviews will be similar to those in paragraph 2, except that the Assessing Body will not be required to make a fresh application.

5. Conditions of recognition will include the maintenance of arrangements to satisfy the HSE requirements and a requirement to notify HSE of any material changes to the Assessing Body’s formal procedures, guidance or management systems that will have a significant effect on these arrangements.

6. Assessing Bodies must publicise the procedures for assessing individual applicants, including the standards of evidence required for recognition, details of the charges made and time scales for processing applications for certification and renewal of certificates.

7. For verification purposes, Assessing Bodies will be expected to provide both HSE and enquirers with a list of all individuals holding a valid certificate awarded by that organisation (this list to include, as a minimum, details of an individual RPA’s name and validity of their certificate, including date of issue).

8. HSE recognition of organisations as Assessing Bodies will be restricted to the purpose of establishing the RPA core competence requirements for individuals. Assessing Bodies must recognise the certificates of other Assessing Bodies.

Refusal of HSE to recognise an organisation as an Assessing Body

9. If HSE intends to refuse an application for recognition as an Assessing Body, the organisation will be given reasons in writing why this action is being considered. The organisation will be given at least one month to make further representations, which will be considered by the RPA Programme Manager who will decide on the appropriate action to take. Final decisions will be confirmed in writing, where necessary giving information on how to appeal and to whom.

Coverage of certificates

10. The Assessing Body must be able to offer a certification service that provides assessment against all the Criteria of Core Competence specified by HSE in paragraphs 2 and 3 of Part I, Annex 1. HSE may, on request, agree to an Assessing Body limiting its service to stated groups (e.g. their own employees), but it cannot restrict any certificate of core competence awarded to work in a particular sector.

Application process

11. The Assessing Body must require applicants to:

• provide adequate and sufficient personal identification information;
• indicate whether it is a new application or a renewal;
• provide evidence of their chartered status, membership or fellowship of any relevant national or international professional institution
• provide evidence, if appropriate, of their recognition as a Radioactive Waste Adviser or Medical Physics Expert.
• provide sufficient information and evidence, appropriate to the type of their application, to demonstrate that they meet, or continue to meet, the HSE Criteria of Core Competence for individuals as set out in paragraphs 2 and 3 (first time recognition) or paragraph 7 (renewal of recognition) of Part I of Annex 1.

Assessment procedures

12. The Assessing Body must have written procedures by which to assess individual applicants against HSE’s Criteria of Core Competence.

13. These procedures must:

• include a process of assessment by peer review of the information and evidence provided by each applicant, using standards and criteria in accordance with this document and established by the Assessing Body;
• differentiate between new applications and renewals;
• involve, for each application, at least two certificated RPAs (the assessors);
• allow for assessors to seek reasonable relevant additional relevant information or evidence to meet the requirements in paragraph 11(e) above from the applicant, where this seems necessary to them;
• provide for assessors making a formal record of their decisions on each applicant and the retaining of these records by the Assessing Body for 6 years;
• provide for the recording and retaining, for as long as is necessary, of such information as may be relevant to any appeal; and
• include periodic peer review of decisions made by assessors.

Proof of assessed competence

The Assessing Body must provide every applicant who meets HSE’s Criteria of Core Competence with a certificate which:

• identifies to whom it applies and states that, by virtue of the certificate, that person meets the requirements in paragraph 11 (e) above for the purposes of the definition of a radiation protection adviser in IRR17, without reservation;
• states when it was issued; and
• is signed by a person or persons who have been authorised by the Assessing Body for this purpose.

The certificate should only contain the information above, subject to the agreement of HSE.

Assessing body’s appeal and complaint procedures

15. The Assessing Body must have an adequate appeal procedure open to each applicant who is deemed not to have met the HSE’s Criteria of Core Competence and to each individual who has had a certificate withdrawn.

16. The Assessing Body must provide to each such unsuccessful applicant a written explanation as to why that individual is considered not to have met the required standards of competence. It must also explain how the applicant can appeal against the decision. Records of this correspondence must be kept for at least 5 years and be made available to HSE upon request.

17. The Assessing Body must publish a written complaints procedure that explains how complaints against RPA certificate holders should be made, how they will be dealt with and what sanctions could be applied. Including arrangements for the withdrawal of certificates.

18. The Assessing Body must provide each individual subject to sanctions a written explanation as to why these have been imposed, and how that person can appeal against the decision. When withdrawing a certificate, the Assessing Body must also remind the individual RPA that they should inform employers for whom they are acting as an RPA that their recognition has been withdrawn.

19. Each such applicant and individual must be notified promptly of the outcome of the appeal.

Reporting to HSE

20. The HSE requires the Assessing Body to report to HSE on an annual basis.  The information required is:

• the number of certificates issued to successful applicants;
• the number of times further evidence has been requested from applicants;
• the number of unsuccessful applications;
• the number of certificates withdrawn;
• the number of certificates not renewed;
• the number of appeals processed;
• the number of applications and appeals outstanding at the end of the reporting period;
• the maximum, minimum and average time taken to process applications and reassessments;
• the number of assessors available to assess applications and undertake reassessments.

In addition, the Assessing Body should inform HSE immediately of any significant problems that arise from the operation of its systems and/or procedures.

Investigation and withdrawal of recognition as an Assessing Body

21. HSE will investigate situations which come to its attention, for instance through a complaint, where it appears that an Assessing Body recognised by HSE no longer meets the requirements in this Annex.

22. Where HSE has concerns regarding an Assessing body such as its effectiveness, its operation or its failure to follow agreed procedures  it will first write to the Assessing Body explaining the concerns and asking the Assessing Body to conduct an initial enquiry, reporting back to HSE within an agreed timescale. HSE will only proceed with the investigation where it is not satisfied that all matters of concern have been satisfactorily resolved by the Assessing Body’s response. Where HSE considers it necessary to proceed with the investigation, HSE’s published Complaints and Investigations Procedures will be followed.

23. Where the decision of the RPA Programme Manager is to consider withdrawal of recognition written notice bringing forward the review process and explaining the reasons for this decision will be given to the Assessing Body.  Following an exchange of views the Assessing Body will be given one month to make further representations to the RPA Programme Manager who will then decide on the appropriate action to take.  Final decisions will be confirmed in writing.

24. HSE will provide the Assessing Body from which it has withdrawn recognition a written explanation as to why it does not meet the required standards.  HSE will also explain how it can appeal against the decision and HSE will give prompt notification of the outcome of any appeal to the appellant.

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Annex 3: Basic underpinning knowledge for radiation protection advisers

Introduction

1. The purpose of this Annex is to provide advice on the extent of the knowledge and training, in respect of the basic syllabus, required by a radiation protection adviser under IRR17 and/or REPPIR19.

2. Previous education and training will usually have addressed part or all of this syllabus, particularly those elements requiring Basic Understanding.

3. The evidence required by the assessing body should be proportionate and can include a detailed job description and evidence of work history. The portfolio of evidence required of a candidate will vary according to that person’s professional standing, chartered status, membership or fellowship of a relevant professional institution, qualifications, training and experience. HSE does not expect that chartered or incorporated radiation protection professionals, or those with membership or fellowship of a relevant professional institution, and/or many years’ experience of radiation protection and the application of IRR17 and/or REPPIR19, will need to submit the same quantity of evidence as a new graduate or someone new to this area of expertise. Individual examples may demonstrate evidence relating to more than one requirement of DU, GA, or BU. (For further information and examples of acceptable evidence see Annex 1)

4. Candidates will need to supply evidence that they do or have the ability to give adequate advice to duty holders and employers on compliance with IRR17 and/or REPPIR19. However, evidence that a duty holder has heeded that advice is not usually necessary.

Key

GA(*) - General Awareness: knows that the topic exists and aware of its significance to work activities in context. Also knows how and where to obtain help on the topic if needed.

BU(*) - Basic Understanding: has a basic understanding of the topic with a level of detail that allows the RPA to apply it to familiar work activities in context. If necessary, can research further knowledge using readily available sources and apply it in less familiar circumstances.
DU - Detailed Understanding: has a good understanding of the topic and the underlying principles and can apply the knowledge in appropriate contexts. Can apply the knowledge working from basic principles to deal with situations in new or unfamiliar areas and can identify and influence the peripheral and long term issues arising from its application.

(*) The assessing body must not insist on evidence of GA or BU if the individual is a chartered or incorporated radiation protection professional or holds membership of a relevant professional institution or is a certified RWA or MPE. Relevant professional institutions include the Society for Radiological Protection (SRP), the Institute of Physics and Engineering in Medicine (IPEM) and the Association of University Radiation Protection Officers (AURPO).

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Annex 4: Glossary of terms and definitions

Radiation Protection Adviser

A Radiation Protection Adviser (RPA) is an individual who, or RPA Body which, meets HSE’s Criteria of Core Competence in this Statement. The Criteria of Core Competence for individual RPAs and RPA Bodies are laid down in this statement. (REPPIR19 defines an RPA in same terms as the IRR17.)

Role of the RPA

The role of the RPA is set out in regulation 14(1) and Schedule 5 to the IRR17. Broadly, it is to advise an employer on compliance with IRR17 in work related situations. This includes those radiation protection matters necessary to comply with the Regulations. The RPA’s role is to advise an employer; therefore whilst an RPA may be an employee, their advice should be independent from for example, production and operational management.

Core Competence

An individual has achieved RPA core competence when they have obtained either 1) a Radiation Protection Level 4 National or Scottish Vocational Qualification (N/SVQ) or 2) a certificate of RPA core competence from an Assessing Body, by providing evidence from education, training and/or experience that is sufficient to satisfy that Body that they meet all the requirements laid down in the Statement. At the point of obtaining either a N/SVQ or a certificate of RPA core competence, an individual satisfies for the first time the definition of an RPA in regulation 2 of IRR17 and are thus legally recognised as an individual RPA.    

Suitable RPA

An individual RPA or RPA Body has achieved ‘Core Competence’ when they have met HSE’s Criteria of Core Competence contained in this Statement (see definition of an RPA above). However, it is then for the employer to select an RPA who, or an RPA Body which, has the necessary knowledge and experience to make them ‘suitable’ to give advice in relation to the employer’s particular line of work. A ‘suitable’ RPA or RPA Body should possess the requisite knowledge and experience relevant to the employer’s type of work. In relation to an individual RPA, the judgment about suitability would principally be derived from the appropriateness of the RPA’s working history. In relation to an RPA Body, the judgements would be principally derived from the RPA Body’s statement that should be made available to potential clients. This statement will include the scope of advice that the RPA Body is able to provide and the experience and qualifications of the individual RPAs employed within that Body.

RPA body

Is an organisation recognised by HSE that can act as a Radiation Protection Adviser having met HSE’s Criteria of Core Competence for RPA Bodies.

Assessing body

Is an organisation recognised by HSE that assesses individuals against HSE’s Criteria of Core Competence to act as Radiation Protection Advisers (RPAs) under the Ionising Radiations Regulations 2017(IRR17). An Assessing Body must meet the requirements for Assessing Bodies in Annex 2 of this Statement.

Any person wishing to practise the profession of Radiation Protection Advisor must hold a qualification from the HSE List of approved RPA bodies. There is no application process within the scope of Sections 8(2)(b) or 8(2) of the Professional Qualifications Act 2022

Footnote

1. REPPIR19 references the IRR17 definition for the purpose of Regulation 24 of REPPIR19. Back to reference of footnote 1

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no