Ionising Radiation Regulations 2017 (IRR17): Possible changes to authorisation

15/03/2021

The Health and Safety Executive (HSE) is proposing changes to the consent authorisation process under the Ionising Radiation Regulations 2017 (IRR17). The proposed changes will require employers seeking ‘consent’ to prepare a safety assessment, which they will then send to HSE for review. Following this review, HSE will inspect the employer’s facility before granting a consent. Mr James Taylor, HSE, explains…

This proposed change is in response to the International Atomic Energy Agency (IAEA) Integrated Regulatory Review Service (IRRS) full UK mission in late 2019. This mission considered the totality of the UK’s regulatory approach and framework for controlling the health and safety risks associated with work with ionising radiation. The IAEA made a number of recommendations for improvement, which the government has accepted^[1,2].

One recommendation was for HSE to request employers seeking authorisation for the safety significant activities and facilities to submit a safety assessment, which should be reviewed by the regulatory authority before granting the authorisation. Changes to the consent authorisation process will deliver this recommendation and over the past months HSE has been working on ways these changes can be introduced.

This is a significant change and will involve more regulatory work by HSE specialist radiation inspectors. Employers, too, will have to prepare and send a formal safety assessment to HSE for review. HSE has been considering the content of the safety assessment and it is likely to consist mainly of the information already required for the radiation risk assessment under IRR17. In addition, HSE is also considering an appropriate information system for both employers and HSE to receive, process and store the safety assessment information.

HSE will work closely with employers and relevant professional bodies during the development of these changes. In particular, employer engagement will help in the design of the supporting information system particularly from a usability perspective. HSE intends to start some engagement very soon through preliminary interviews with employers.

In addition, the extra regulatory work by HSE specialist inspectors reviewing a safety assessment is likely to be cost-recovered from employers and there will be a formal consultation on this in due course.

Changes are proposed to take effect some time in 2022. They will apply to all new applications for consent authorisation from the date the changes are introduced. In addition, because HSE believes the proposed changes will strengthen the approach to consent, all existing consents will be reviewed and inspected from this date, with a phased approach adopted. Until changes are made, however, the current arrangements apply.

Further information can be obtained from reading the referenced documents below. The British Institute of Non-Destructive Testing will keep its readership and members informed of all discussions, where practical, during the consultation process.

References

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