Health and Safety Executive Health and Safety Executive Moving ACOP material into Regulations - HSE...

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Health and Safety Executive

Health and Safety Executive

Moving ACOP material

into Regulations - HSE

ProposalsSheila Rees

OEWG Meeting 11 November 2014

Topics covered

• Natural radiation sources

• Controlled area – local rules

• Radiological surveillance of areas

• Categorisation of workers

• Individual measurements

• Accidental exposure

• Medical surveillance – further action

• Medial surveillance - general

Approved code of practice

• Content of ACOP material alone does not secure compliance with the Directive. Only Regulation can achieve this.

• Effects of following changes expected to be minimal. HSE expects compliance with ACOP requirements.

• Please challenge the following assumptions.

ACOP1. Natural radiation sources

Current arrangements

• ACOP para 11 includes interpretation of the Regulations to include natural radiation sources.

BSS requirement

• Article 2.2(c) sets out the scope of the Directive to include natural radiation sources.

ACOP1. Natural radiation sources

• HSE Proposal

• To move the ACOP material into new Regulations.

Preliminary estimated impact

• Familiarisation costs.

ACOP2. Controlled areas–local rules

Current arrangements

• IRR regulation 17 requires every radiation employer to make local rules in respect of controlled areas. ACOP details the advised content of the rules.

BSS requirement

• Article 37.1 of the Directive sets out minimum requirements for a controlled area.

ACOP2. Controlled areas – local rules.

HSE Proposal

• To move the ACOP material into new Regulations.

Preliminary estimated impact

• Familiarisation costs.

ACOP3. Radiological surveillance of areas

Current arrangement

• IRR regulation 19 partly covers the monitoring of designated areas. ACOP advises how this should be achieved.

BSS requirement

• Article 39.1 of the Directive sets out specific requirements for radiological surveillance

ACOP3. Radiological surveillance of areas

HSE Proposal

• Move relevant ACOP provisions into Regulation.

Preliminary estimated impact

• Familiarisation costs.

ACOP4. Categorisation of workers

Current arrangement

• IRR reg 20 requires designation of classified persons.

• ACOP requires employers to consider the potential for exposure and to carry out regular health reviews.

BSS requirement

• Article 40.2 requires categorisation prior to taking up work and regular review of categorisation.

ACOP4. Categorisation of workers

HSE Proposal

• New regs to reflect the BSSD requirement

• Move relevant ACOP provisions into Regulation.

Preliminary estimated impact

• Familiarisation costs

ACOP5. Individual measurements

Current requirement

• IRR reg 22 requires doses to be estimated when doses cannot be assessed. ACOP material supplements this.

BSS requirement

• Where individual monitoring is not possible or inadequate, Article 41.3 requires the monitoring to be based on measurements made on other workers, or calculation methods approved by HSE.

ACOP5. Individual measurements

HSE Proposal

• To move the ACOP material into new Regulations.

Preliminary estimated impact

• Familiarisation costs.

ACOP6. Accidental exposure

Current requirement

• Where accidental dose exceeds 6mSv, employer must arrange dose assessment. Records must be kept and result of assessment made available to employee.

• ACOP guidance suggests follow up of all those affected by accident and dose assessment to be carried out.

BSS requirement

• Accidental doses must be assessed and their distribution in the body.

• Exposures must be recorded separately.• Records must be accessible.

ACOP6. Accidental exposure

HSE Proposal

• To move the ACOP material into new Regulations.

Preliminary estimated impact

• Familiarisation costs.

ACOP7. Medical Surveillance – further action

Current requirement

• IRR reg 24 requires adequate medical surveillance is carried out.

• ACOP material supplements what this surveillance should include.

BSS requirement

• Article 45 includes precise requirements of what medical surveillance must include.

ACOP7. Medical Surveillance – further action

HSE Proposal

• To move the ACOP material into new Regulations.

Preliminary estimated impact

• Familiarisation costs.

ACOP8. Medical surveillance - general

Current requirement

• IRR reg 24 states who medical surveillance applies to.

• ACOP material describes what the surveillance should include.

BSS requirement

• Certain specifics to be included in medical surveillance.

ACOP8. Medical surveillance - general

HSE Proposal

• To move the ACOP material into new Regulations.

Preliminary estimated impact

• Familiarisation costs.