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Policy on the use of ionising radiations and radioactive substances.

Purpose

The University is responsible for ensuring compliance with legislative requirements and for putting in place measures which safeguard the health of its employees and others associated with the University from harmful effects of ionising radiation and measures which protect the environment from contamination with radioactivity.

This Policy describes the management principles and administrative arrangements which must be implemented to ensure compliance.

Legislative Framework

Statutory Regulations apply to work with ionising radiations and radioactive substances. The University must ensure compliance with legislation governing work with sources of ionising radiation and radioactive substances, in particular the Health and Safety at Work etc. Act l974, the Ionising Radiations Regulations 2017 (IRR17) and the Environmental Permitting (England and Wales) (Amendment) Regulations 2011 (EPR11).

The regulatory agencies are the Health and Safety Executive for IRR17 and the Environment Agency for EPR11. The agencies take a strict approach to assessment of compliance by process of inspections and audits by appointed Regulatory Inspectors.

For purposes of Environmental Permits the main University campus and the Clinical Sciences Research Laboratory at Walsgrave (CSRL) each have their own Permits.

Scope

The Policy applies to all University campuses and to all Schools and Departments of the University.
It applies to University staff, students, visiting staff, contractors and members of the public.

Principles of risk management

Risks associated with use of ionising radiation and radioactive substances must be managed in accordance with legal requirements and management control principles.

Sources of ionising radiation i.e. radioactive substances, instruments and equipment capable of emitting radiation, must only be used if there is no safer alternative. Use of ionising radiation must be justified.

If use of ionising radiation cannot be avoided and is justified, exposure to ionising radiations must be restricted in accordance with “as low as reasonably practicable” (ALARP). This is achieved by an assessment of the risk of harm to individuals’ health from exposure to radiation. If an unacceptable level of risk is identified, measures must be put in place which minimise the risk in line with the ALARP principle.

If use of radioactive substances cannot be avoided, prevention of contamination of the environment by radioactive substances must be in accordance with “best available technique” (BAT). Radioactive substances must be obtained, stored, used and disposed of according to procedures (Schedules) described in Environmental Permits, granted to the University by the Environment Agency specifically for this purpose.

Work must be carried out in accordance with Instructions for Use of Radioactive Open Sources, Instructions for Use of Radioactive Sealed Sources including High Activity Sealed Sources and Instructions for Use of X-ray equipment.

Arrangements

1. Ultimate responsibility within the University rests with the Council.

2. Executive responsibility is delegated from the Council to the Registrar.

3. The Director of Health and Safety is accountable to the Registrar for appointing:
a. An external independent Radiation Protection Adviser (RPA); see Role and Responsibilities of the RPA.
b. An approved Personal Dosimetry Service provider.

4. The Director of Health and Safety ensures the University has access to expert advice on the management of radiation protection and radioactive waste.

5. The University has appointed a Radiation Protection Officer (RPO) and Radioactive Waste Adviser (RWA); roles and responsibilities are described in the links provided above.

6. A Radiation Protection Supervisor(s) (RPS) must be appointed in writing by a Head of Department.

7. The role of the RPS is to make sure work with ionising radiations is carried out in accordance with the Ionising Radiations Regulations 2017 and that Local Rules are followed; Role and Duties of a Radiation Protection Supervisor.

8. The Instructions for Use of Radioactive Open Sources, Instructions for Use of Radioactive Sealed Sources including High Activity Sealed Sources and Instructions for Use of X-ray equipment provide greater detail regarding:

• Environmental Permits
• Risk assessment
• Area designation
• Local Rules
• Area monitoring
• Source accountancy
• Storage
• Disposal
• Personal dosimetry
• Radiation workers (training)
• Movement and transport
• Contingency measures

9. Principle Investigators must ensure that before work involving use of ionising radiations commences that:

a. Researchers and radiation workers including themselves are trained and competent to carry out radiation work.
b. The work is risk assessed and carried out in accordance with Instructions for Use of Radioactive Open Sources, Instructions for Use of Radioactive Sealed Sources including High Activity Sealed Sources and Instructions for Use of X-ray equipment, whichever are relevant.
c. Local Rules are in place.
d. Researchers and radiation workers know the RPS for their area and or work.

10. Before any new work with ionising radiations is started, a Principle Investigator must send a completed application form to the Chair of the Department Health and Safety Committee and to the RPO; see Application for Application for New Work Involving use of Ionising Radiation.

11. On the basis of information provided in an application, the Chair of the Department Health and Safety Committee in consultation with the RPO (and other radiation protection experts in the Department) will advise the Head of Department about appointment of Radiation Protection Supervisor(s).

12. A Head of Department is responsible for appointing an RPS in writing. A copy of the letter of appointment must be sent to the RPO.

13. Researchers and radiation workers are responsible for ensuring that their work is carried out in accordance with Policy and with relevant Instructions and Local Rules.

14. When staff carry out work with ionising radiations at a different Institution and / or site the radiation safety policy of the host institution and / or site will apply. This applies to:

a) Visiting staff engaged in work at University of Warwick premises.
b) University of Warwick staff and students engaged in work at another Institution’s premises.

In the case of (b) the University of Warwick RPO must be notified in advance.

15. Compliance with this Policy is monitored and audited by the RPO / RWA and the external RPA and reported to the Director of Health and Safety.

16. The RPO / RWA is the main point of contact with external regulatory agencies namely, the Health and Safety Executive and the Environment Agency. Audits carried out by external agency Inspectors including those by the Counter Terrorism Unit are reported to the Director of Health and Safety.

17. The RPO / RWA carries out checks to make sure that Environment Permits are sufficient to meet research needs.

18. Audits and inspections carried out by the external RPA will be attended by the RPO and reports will be reviewed by the RPO. Actions and outstanding issues reported will be addressed by the RPO.

19. The Director of Health and Safety is accountable to the Registrar and the University Health and Safety Executive Committee to keep them informed about issues arising from audits.