Radiation protection legislation

Question 1

IRR99 overview

Answer 1

Concerned with safety of staff and members of public, not pxs
Stems from Management of Health and Safety at Work Act
Some of main requirements:
-RPAs
-Risk assessment
-Local rules and RPS
-Controlled areas
-Dose limits

Question 2

IRR99 Documentation

Answer 2

Approved Code of Practice

-contains both raw IRR and explanatory notes on interpretation and some official non-regulatory guidance

Question 3

Medical and Dental Guidance Notes

Answer 3

Contains advice of examples for all requirements of IRR and IRMER e.g.

• risk assessment forms
• incident forms
• signs and warnings

Question 4

Guidance notes for dental practitioners on safe use of x-ray equipment

Answer 4

More useful

What you need to know

Question 5

RPA

Answer 5

Radiation protection adviser
Appointed expert who can help you will all things legislative, assist in determining necessary requirements for your facilities and
setting up a QA programme for your equipment.
Can be found in local hospital Medical Physics departments or private
consultancies

Question 6

RPS

Answer 6

Radiation protection supervisor
Ensures that local rules are followed when
working in controlled areas. E.g. senior
radiographer, a senior partner in a private dental
practice

Question 7

Regulation 4: duties of employer

Answer 7

The employer is responsible for…
-Fulfilling IRR99 with regard to the exposure to employees
and exposure to members of public that arise from
work done within organisation
-Employer may delegate tasks and other managers may have some responsibilities under IRR99
-Responsible for managing risk to employees and public
-For NHS Trusts employer would be taken to Chief
Executive. If you run your own practice, YOU are the
employer

Question 8

Regs 5 and 6: authorisation and notification of work

Answer 8

Before starting any new work with IR:
• Appoint/notify a local Radiation Protection Adviser (RPA)
• Notify Health and Safety Executive (HSE)
• 28 days before commencing
• By email, fax or letter
• Generic Authorisation (providing all conditions are met)
• General info
• The necessary form

Question 9

Regulation 7: Prior risk assessment

Answer 9

Identify hazard –> evaluate risk –> record findings –> identify provisions –> review/ revise –> back to beginning
Must be done prior to commencing any new work involving ionising radiation

Question 10

Reg 7 - doing your assessment

Answer 10

Must be written down
Do one whenever introducing new procedures/ equipment/ locations
Update if anything changes and periodically changes and periodically review
Investigate incidents
Must involve RPA
Special procedures for expectant mothers
Should be ‘suitable and sufficient’

Question 11

ALARP

Answer 11

As Low as Reasonably Practicable

Question 12

Reg 8: Restriction of exposure (ALARP)

Hierarchy of controls

Answer 12

Engineering (design) –> Administrative –> PPE

Question 13

Reg 8: restriction of exposure

Answer 13

Acceptance testing for new equipment
Hierarchy of controls
Monitoring
Proper use of PPE
Dose constraints
Restrictions for pregnant workers
Formal investigation levels

Question 14

Regs 9 & 10

Answer 14

Wear and look after your PPE

Question 15

Reg 11: dose limitation

Answer 15

Employees ages 18+, whole body dose 20mSv/annum
Trainees under 18, whole body dose 6mSv/annum
General public, whole body dose 1mSv/annum

Question 16

Reg 12: contingency plans

Answer 16

If risk assessment shows radiation accident is reasonably
foreseeable, contingency plans must be designed to restrict
exposure
Must be reasonable grounds for believing it could
occur
E.g. failure of intraoral x-ray exposure to terminate – switch off at wall

Question 17

Reg 14: info, instruction and training

Answer 17

People need to be trained first, if you haven’t been trained, don’t do it!

Question 18

Reg 16: designation of controlled or supervised areas

Answer 18

Controlled: areas where there is potential to exceed 6mSv per year
>7.5 µSvh-1 (time averaged over 1min and untrained employees likely to gain access)
OR if special procedures needed to restrict exposure

Question 19

Reg 17: local rules and radiation protection supervisors

Answer 19

Must have local rules if there is a controlled area
Must contain
• Name of RPS/RPA
• Details and designation of area
• Summary of working procedures (including any ‘special
procedures’ for entry)
• Investigation dose level
• Contingency plans
RPS needs to be appointed to ensure adherence to LRs

Question 20

Referrer

Answer 20

Registered health care professional entitled in accordance with employers procedure to refer individuals for medical exposure to practitioner

Question 21

Practitioner

Answer 21

Registered health care professional entitled in accordance with employers procedures to take responsibility for an individual medical exposure

Question 22

Operator

Answer 22

An person entitled, in accordance with employers procedures, to carry out practical aspects of exposure
Can include radiographs, medical physics experts, engineers, dark room technicians or staff asking px identification questions

Question 23

Reg 15: co-operation between employers

Answer 23

Working for multiple trusts or private clinics, take care of combined dose

Question 24

IRMER 2000 - Employer’s duties

Answer 24

Written procedures:
– How is px identified?
– Enquiring if female pxs pregnant/ breastfeeding
– Reducing risk of accidental or unintended doses
as much as reasonably practicable
– Establishing ‘Reference Levels’ for diagnostic exams
Naming of Referrer, Practitioner and Operators and ensuring they have appropriate training
Establish a Quality Assurance programme

Question 25

Referrer duties

Answer 25

Shall supply practitioner with
sufficient medical data relevant to
medical exposure to enable practitioner
to decide on whether medical exposure
is justified

Question 26

Practitioner duties

Answer 26

Responsible for process of justification
of medical exposure
– Is there net benefit to px?
Must comply with employers procedures
Shall co-operate with other specialists and
staff involved in medical exposure
regarding practical aspects

Question 27

Operator duties

Answer 27

Operator who personally carries out any
practical aspect shall be responsible for
that aspect
Shall comply with employer’s
procedures
Shall co-operate with other specialists and
staff involved in medical exposure
regarding practical aspects

Question 28

Justification of medical exposures

Answer 28

Every exposure must be justified
• Does the benefit to the patient/society
outweigh the costs?
• Exposure objectives
• Individual detriment
• Alternative techniques
-if for research, must be approved by ethics committee

Question 29

Optimisation through

Answer 29

QA program
Assessment of px dose
Diagnostic reference levels (DRLs)

Question 30

DRLs

Answer 30

Ball park dose figure for typical
examinations for standard sized pxs for broadly defined types of equipment
• To be established by employer
• To be set in units directly applicable to exam to enable px dose to be calculated,
e.g. exposure time.
• National group including RCR, CoR, IPEM &
PHE collate data to set guideline figures

Question 31

Reporting incidents

Answer 31

Radiation incidents more common than you think
– Accidental exposures
– Wrong Exam/ Wrong Px
– Equipment faults
Care Quality Commission responsible for
enforcing IR(ME)R and incidents with a dose “much greater than intended” or unjustified must
be reported to them
Immediately inform your RPS, Consult your RPA, inform CQC if appropriate.

Question 32

PM 77

Answer 32

HSE guidance document

This is where dose ‘much greater than intended’ definitions come from