REQUIREMENTS FOR THE APPROVAL OF DOSIMETRY SERVICES UNDER THE IONISING

RADIATIONS REGULATIONS 2017

Updated 2020

PART 3 - CO-ORDINATION AND RECORD KEEPING

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These requirements, which include technical criteria for approval and supporting

guidance, are issued by the Health and Safety Executive for the purpose of

approving dosimetry services under regulation 36, Ionising Radiations Regulations

2017. Following the supporting guidance is not compulsory and dosimetry services

are free to take other action to demonstrate that the criteria in this document have

been met.

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FOREWORD

Dosimetry services undertaking assessment and record-keeping of radiation doses received by classified persons must be approved for these purposes by the Health and Safety Executive (HSE) or by a body authorised in writing by HSE. The organisation responsible for approving dosimetry services is referred to in this document as the 'Approval Body'

The requirements which must be satisfied to obtain approval are specified in four parts. This part sets out the procedures and criteria that will be used by the Approval Body in the assessment of dosimetry services seeking approval for co-ordination and record keeping of radiation doses. Part 11 deals with approval for external radiations (including exposures resulting from accidents), Part 22 deals with internal radiations (including radon decay products) and a supplement3 deals with approval for emergency exposures during intervention.

These documents set out the objectives to be achieved and the requirements a service must satisfy to meet those objectives.

This document is in three sections. The first section gives an introduction; the second section describes procedural requirements; and the third section gives criteria for approval.

The criteria for approval are supplemented by guidance to indicate how they may be satisfied. This guidance is intended to help dosimetry services and the Approval Body. It shows ways in which services have met these criteria in the past, and illustrates good practice. Following the guidance is not compulsory and dosimetry services are free to take other action to demonstrate that they meet the criteria in this document. Separate guidance4 is available for employers summarising their responsibilities.

Printed and published by the Health and Safety Executive

RADS 3/2019

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CONTENTS

Page Number

FOREWORD SECTION ONE Introduction Background 6 Function and Scope of ADS (Records) 7 Objectives 7 SECTION TWO Procedural requirements for approval/revocation Applications for approval 9 Reassessment of approved dosimetry services 10 Assessment for approval/continuing approval 10 Fees for approval/continuing approval 11 Conditions of approval 12 Revocation of an approval 13 Figure 1 .... Flowchart showing steps in applications for approval 16 Figure 2 .... Flowchart showing steps in reassessment of an approval 17 SECTION THREE Criteria for approval General 18 Quality assurance 19 Design and definition of dose records 20 Content of dose records 21 Receipt and recording of dose information 21 Late and missing dose assessments 25 Identification of significant dose levels 25 Permitted alterations to dose records 26 Storage and security of records 28 Tracing basic data 31 Provision of information to the employer 31 Provision of information to HSE 35 Supplementary information to HSE CIDI 37 Content of 'termination records' 39 Information for HSE 40 Information for other approved dosimetry services 40

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Annex 1 to HSE criteria - Content of Dose Records Table 1 - Type of information 41 Table 2 - Occupational categories 44 Table 3 - Illustration of information required 48 Annex 2 to HSE criteria - CIDI reports - computer compatible records 50

References 69 Appendices 1. Statement of Service 70 2. Notional and Estimated Doses 73

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SECTION ONE

Introduction

Background

1. Regulation 36 of the Ionising Radiations Regulations 20175 (IRR17) enables the Health and Safety Executive (HSE) to approve suitable dosimetry services for some or all of the purposes of:

a) Regulation 22 (routine dose assessment and record-keeping for classified persons);

b) Regulation 24 (accident dosimetry); and/or

c) Regulation 13 (provision of dosemeters or other devices for contingencies),

and to revoke such approvals in writing at any time. HSE may at any time make an agreement in writing with another body to perform this approval function instead. In this document, the term 'Approved Body' is used to mean either the HSE or a body appointed by HSE to undertake the approval function.

2. HSE has issued a series of publications setting out requirements for the approval of dosimetry services under IRR17. This part deals with those aspects that are relevant to co-ordination of dose assessments from contributing Approved Dosimetry Services (ADS) and record-keeping of assessed doses. It explains:

a) the criteria the Approval Body will use to assess whether a dosimetry service appears fit for approval or for continuing approval;

b) the functions of the ADS responsible for co-ordinating dose assessments and maintaining dose records;

c) the minimum contents of dose records;

d) requirements for the transfer of information to the employer and to HSE's Central Index of Dose Information (CIDI); and

e) the circumstances in which an approval may be revoked.

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Function and Scope of ADS (Records)

3. Regulation 22 IRR17 sets out the key tasks which should be undertaken by the dosimetry service for the purpose of co-ordination and record-keeping on behalf of the employer. These key tasks include:

a) making and maintaining dose records for classified persons;

b) keeping dose records;

c) providing copies of dose records, suitable summaries and extracts (including 'termination records') as appropriate; and

d) the co-ordination of the individual dose assessments by other ADS where appropriate.

In this document, a service approved to carry out these tasks is referred to as ADS (Records); dosimetry services approved to make measurements and assessments of dose are referred to as ADS (Assessment).

4. In order to carry out these tasks an ADS (Records) has to be able to combine different elements of dose information, which may stem from dose assessments made by several different contributing ADS (Assessment), for inclusion in the dose record. An ADS (Records) may be a separate organisation acting to co-ordinate the contributions from or more ADS (Assessment); or it may be an integral part of an organisation which is also approved for the assessment of dose.

Guidance

on

paragraph 4

Dose record-keeping for non-classified persons Approved dosimetry services may keep records of reported doses for non-classified persons to help employers demonstrate compliance with regulation 19(3) IRR17. While a similar standard of service should normally be given for this purpose in terms of security of records, accuracy and reliability, the specific requirements set out in this document will not apply. For example, annual summaries of doses to non-classified workers should not be sent to CIDI. For this reason it is sensible to make sure that dose records for classified and non-classified persons are sufficiently clear and separate.

Objectives

5. Any dosimetry service seeking approval for co-ordination and record-keeping must demonstrate to the Approval Body that it has the necessary expertise for this work and can provide and maintain a service which:

a) produces and maintains accurate records which contain at least the minimum personal and dosimetric information required;

b) is highly reliable;

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c) gives long term security for such records; and

d) sends accurate information from the records of the employer and HSE, when required, within a reasonable time.

6. This document sets out the criteria developed by HSE, after consultation with Approved Dosimetry Services (ADS), which will be used to decide whether or not a dosimetry service can meet the objectives in paragraph 5. Any service that can satisfy the Approval Body that it meets the relevant requirements will receive formal approval under regulation 36 of IRR17, subject to certain conditions governing the scope of that approval and the maintenance of the standard of service.

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SECTION TWO

Procedural requirements for approval and arrangements for revocation of approvals

Applications for approval

7. The HSE Statement on the Approval of Dosimetry Services sets out:

a) the arrangements for making applications for approval and for reassessing approved services; and

b) the current fees charged by the Approval Body

The HSE Statement is revised from time to time and will include any changes to the requirements for approval including new or revised performance tests. The statement can be found at www.hse.gov.uk/radiation/ionising/dosimetry/dosimetry-state.pdf

8. Applications for approval should be made in writing or via email to the Approval Body specified in the current HSE Statement and must include:

i) A letter or email from the Head of the Service applying for the approval, detailing what dosimetry service(s) are to be approved. The details should include:

a) The full name and address of the dosimetry service (and other contact details, eg. telephone, email address and a contact name);

b) A description of the type and capacity of the service for which approval is sought (for example, "co-ordination and record-keeping for external radiation and internal radiation dose assessments");

c) (if the service is to be limited to certain clients or groups of clients) the names of clients or a description of groups of client;

ii) A Statement of Service (including samples of records) which gives the required details about the service (see paragraph 10 below);

iii) Examples of all types of output, eg. dose reports to employers and dose summaries to CIDI.

iv) The appropriate administration fee (see the current HSE Statement).

Reassessment of approved dosimetry services

9. Approvals are normally granted without a time limit but each approved dosimetry service (ADS) may be subject to formal reassessment, for which a fee will be charged. This is a standard condition of any approval The Approval Body will

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contact the ADS before to inform them that a reassessment will take place . They will then require the ADS to supply:

(a) copy of the version of the Statement of Service to be used by HSE for their reassessment. This Statement should cover all the relevant points listed in Appendix 1 of this document (see paragraph 10);

(b) examples of all types of outputs from the ADS (Records) to their clients; and

(c) the required administration fee (see the current HSE Statement).

(d) any additional items requested by the Approval Body at the time of reassessment..

Assessment for approval/continuing approval

10. The dosimetry service must ensure that the Statement of Service is accurate, up-to-date and sufficient to support the application for approval/continuing approval when considered with any referenced publications and supporting documents. It must cover all the relevant points in Appendix 1, providing a summary of how the criteria in Section 3 of this document are to be satisfied. The Statement of Service should identify how each element of Appendix 1 is addressed, for example by using the same layout or by including an executive summary which explains how each item is covered (eg. with cross-references to particular paragraphs in the Statement). If it is not clear whether the Statement of Service covers all the points required it will take longer to deal with the application. Inevitably, this will increase the fee for assessing the application (see paragraph 15).

11. If the approval body's assessor decides that the Statement of Service is incomplete or inadequate for the purposes of assessment, he or she will ask the dosimetry service to amend it. The assessor may also request copies of any relevant supporting documents whether or not they are referenced in the Statement of Service. If the dosimetry service does then provide an adequate Statement of Service for assessment (and copies of requested supporting documents) and appears to be incapable of demonstrating that it can satisfy the criteria in this document, the Approval Body will reject the application for approval/continuing approval.

12. The assessor will normally arrange an inspection of the applicant's facilities and this will be at a mutually convenient time. Usually, this inspection will take place after the assessor has received satisfactory replies to queries about the Statement of Service submitted with the application. The assessor will then sample inspect key features of the facilities and the arrangements for co-ordination and record-keeping to check that these match the description in the Statement of Service and are sufficient to indicate that the service is fit to be approved. (Figure 1 illustrates the process of dealing with applications for approval and Figure 2 relates to reassessments of approvals). Dosimetry services wishing to be approved are

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responsible for ensuring that they comply fully with the relevant criteria for approval and should not rely on the assessor to identify any gaps in their arrangements.

13. An assessor carrying out a reassessment of an ADS will take into account the overall performance of the service since the last assessment (including the supply of data to CIDI). If the co-ordination and record-keeping depends on two or more parts of the organisation (eg. dose records are compiled at one site, but they are archived at another) both may need approval either separately or jointly for the particular work they carry out.

Guidance

on

paragraph 13

Dosimetry services operating from more than one site In some cases, certain operations connected with the work of the service are carried out on another site. In such cases it may be necessary for both sites to be named in the approval or even for two separate approvals to be granted. A second site may need to be mentioned in the certificate of approval for a service where the amount or type of work done forms a significant part of that dosimetry service's work. The key test for separate approval is control: if the applicant for approval exercises control over the work at the second site separate approval will not be required. However, if the work at the second site is not under the effective control of the first dosimetry service a separate approval for that specific work may be required.

14. The Approval Body will aim to carry out an inspection of the applicant's facilities within two months of receiving a formal application and to reach a decision about approval within four months of that inspection. The inspection will be delayed if the Statement of Service is not adequate for the purposes of assessment (see paragraph 10). The Approval Body will explain in writing the reasons for rejecting any application. If the applicant is aggrieved by the decision it may use the Approval Body's disputes procedure. However, the decision of the Approval Body after use of this procedure will be final. If an application is unsuccessful the service may make a fresh application for approval but a further fee will be payable.

Fees for approval/continuing approval

15. Fees are payable for all applications, whether or not they are successful. The fees are set out in the current HSE Statement. The Approval Body will not make a final decision about approval until the fee for work undertaken by the assessor has been paid.

Conditions of approval

16. The scope of any approval will be limited by Schedule 1 of the certificate of approval. Schedule 2 may specify conditions which, for example, restrict the approval to keeping records on behalf of specified employers or workplaces. An approved dosimetry service proposing to extend the scope of its approval must make a further application to the Approval Body; an additional fee will be charged.

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Guidance

on

paragraph 16

Selection of ADS by the employer It is the employer's responsibility under regulation 22 IRR17 to appoint a suitable ADS (Records). The employer would be expected to consult the Radiation Protection Adviser (RPA) and to take account of any conditions placed on the ADS. Therefore, an ADS should take care to inform potential clients about the scope and conditions of its approval - normally a copy of the certificate of approval should be made available to clients or their RPA(s).

17. Schedule 2 of the certificate restricts the manner in which co-ordination and record-keeping are undertaken to those summarised in the relevant Statement of Service agreed at the time of approval. Any significant change to the system used (eg. the ADS proposes to use a new computer database) or to any key personnel (eg. the head or deputy head of the service) requiring a revision of the Statement of Service might invalidate the approval; changes restricted to supporting documents would not affect the certificate of approval. Therefore, an ADS should inform the Approval Body, in advance where practicable, for significant changes to the following:

a) key staff

b) the location of the service

c) means of producing and storing records, eg. changing paper records to electronic records

d) the specification of the computer system (hardware and software) for keeping records

e) the design of the dose record, termination record or employer summary

f) change of name/ownership of the service

where the change would require a significant revision to a critical part of the Statement of Service referred to in the certificate of approval. If the Approval Body decides that the changes could adversely affect the competence and performance of the ADS to maintain the service in accordance with the requirements in this document a partial reassessment may be needed. The Approval Body will arrange for an assessor to review the changes and to undertake a partial reassessment of those aspects of the service that have changed; this may involve an inspection. A fee will be charged for such a reassessment whether or not an inspection is involved.

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Guidance

on

paragraph 17

Purpose of notification to the Approval Body This should not be seen as a discouragement to innovation. Its purpose is to: (a) help the Approval Body ensure that modifications to the

operation of an approved service do no result in the service failing to conform to the criteria for approval;

(b) help ensure that the operation of the service is still covered

by the existing certificate of approval (which will refer to the Statement of Service current at the time of approval or at the time of the last reassessment).

If an ADS provides a service that is not covered by the current approval certificate then it may be acting as an unapproved service. Its clients would therefore be in contravention of regulation 22 IRR17. Similarly, any relocation of the service to different premises could invalidate an existing certificate of approval. In many cases the Approval body may agree to a variation via a brief letter to the ADS accepting the change.

18. Approvals are given to a specific dosimetry service and cannot be transferred in part or whole to any other dosimetry service. Therefore, it is imperative that the ADS notifies the Approval Body if a change of name is planned as the existing certificate of approval might not be valid for the new organisation.

19. At the request of HSE, an assessor may arrange for a visit to the ADS, at a reasonable time, to make enquiries about any significant problem that has come to HSE's attention and to carry out an interim reassessment of the service. The ADS should co-operate with the assessor in these circumstances. No fee will be charged - HSE will normally pay for this work. However, the approval of a service may be revoked in any of the circumstances set out in paragraph 20.

Revocation of an approval

20. HSE may revoke in writing any approval given to a dosimetry service. An approval for co-ordination and record-keeping may be revoked if an ADS:

a) does not send the required annual dose summaries to CIDI within three months of the end of the calendar year, or such longer period as may be agreed (criterion 17);

b) fails to correct errors or inconsistencies in the annual dose summaries identified by CIDI Office within three months or such longer period as may be agreed (criterion 17);

c) does not conform to the current criteria for approval and fails to provide the Approval Body with an action plan which is sufficient to enable the deficiencies to be rectified within three months.

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d) persistently fails to send suitable summaries of dose records to employers within the required timescales (criterion 16);

e) fails to apply for reassessment of its approval and provide a copy of the current Statement of Service within three months of receipt of a written request from the Approval Body (see paragraph 9), or such longer period as may be agreed;

f) fails to provide the required fees for reassessment (see paragraph 15) within three months of receipt of a written request from the Approval Body or such longer period as may be agreed; or

g) fails to co-operate with the Approval Body during attempts to carry out an interim reassessment (see paragraph 19).

Approval will also be revoked if a dosimetry service requests revocation of its approval or is issued with a new certificate of approval that supersedes the previous certificate.

Guidance

on

paragraph 20

Monitoring performance The ADS should be monitoring its own performance against the targets set out in this document. Therefore, an ADS should be aware of any failure to meet these timescales and should take appropriate action to rectify the problem well before any reassessment. The Approval Body may well regard the failure as 'persistent' if, for example, more than 20% of dose summaries in a representative period are reported late to employers.

Failure to notify significant changes It is advisable for all ADS to try, where possible, to time important changes to the service to coincide with the next reassessment. If an ADS fails to notify the Approval Body of significant changes (paragraph 17) likely to affect the Statement of Service this would not, in itself, justify revocation of its approval. However, if the Approval Body discovers that significant changes have been made which have adversely affected the performance of the service it may consider revocation of the approval, as explained in paragraph 21 below.

Action plans If the Approval Body's assessor finds, during a reassessment, that the ADS is not conforming to the criteria in this document the ADS will be asked to prepare an urgent action plan. The plan should normally show what steps the service will take, with milestones, to restore the level of its performance to that required for a service approved to co-ordinate dose information and keep dose records, as appropriate. If the ADS does not produce an action plan within a reasonable period set by the Approval Body, or the plan is unrealistic or inadequate, the Approval Body may consider revocation of that service's approval.

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21. If the Approval Body concludes that revocation of the approval should be considered, it will warn the ADS in writing, outlining the key requirements which are not being satisfied. The ADS will be asked to take action to meet the requirements within three months. If the ADS satisfies the Approval Body that it does conform to the requirements in this document, or that it would be unreasonable to require more to be done, no further steps will be taken to revoke the approval. In any other case, the assessor will recommend revocation of the approval. The Approval Body will immediately notify the ADS in writing seeking comments. Subsequently, the Approval Body will consider the recommendation of the assessor together with any written representations from the ADS and decide whether the approval should be revoked. The ADS will be notified of the decision immediately. If the decision is to revoke the approval this will take effect six weeks after the ADS is notified. This period should be sufficient to enable the clients of the service to make alternative arrangements.

Guidance

on

paragraph 21

Responsibility for identifying improvements Although the Approval Body will identify the main failings of the service whenever it considers revocation, it remains the responsibility of the ADS, not the Approval Body, to determine what steps need to be taken to improve its performance.

Action after receipt of a warning letter If an ADS receives a letter warning that revocation of its approval is being considered the ADS would be unwise to take on any new customers until the problems identified by the Approval Body have been resolved. Furthermore, it may be necessary for the ADS to prepare existing customers for the possibility that arrangements may have to be made with an alternative ADS.

Disputes procedure HSE has a disputes procedure whereby anyone who is aggrieved by the actions or decisions of HSE staff may make representations to have the matter resolved at a higher level within HSE. The arrangements are set out in the current HSE Statement. If the Approval Body is not HSE, that body will have similar disputes procedures. If the Approval Body recommends that approval should be withheld or revoked, or granted subject to certain conditions, it will write to the dosimetry service to warn them. Two weeks will be allowed to enable the dosimetry service to make representations, which will be considered on a fair and fresh basis before a decision is taken.

Meeting with the Approval Body In appropriate circumstances, and where time can be saved in so doing, a representative of the Approval Body may arrange a meeting with the ADS, at the office of the Approved Body, to explain why it is considering revocation of the approval.

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Yes

Figure 1 - Application for Initial Approval (Co-ordination and Record-Keeping)

APPLICANT Study

RADS3

Prepare Statement of Service (SoS)

Apply in writing for approval sending

SoS and admin fee to

Approval Body

Assessment of dosimetry service (incl. inspection)

Further details/ amended SoS

Queries by Assessor

Assessor reports to Approval Body

Applicant invoiced for assessment fee

Fee paid?

Approval Body decision on application

CERTIFICATE OF APPROVAL

Representations by ADS

Application rejected (with reasons)

Approval Body passes case to

Assessor

Approval Body Review

No Yes

HSE Disputes Procedure (Optional)

Within 2 months

Within ~4 months

Decision to reject upheld

No

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Figure 2 –Reassessment of Approved Dosimetry Service (Co-ordination and Record-Keeping)

APPLICANT receives formal notice that a reassessment will take place

Study current RADS3

Prepare updated Statement

of Service (SoS)

Send SoS and admin fee to

Approval Body

Assessment of Approved Dosimetry Service (incl.

inspection)

Further details/ amended SoS

Queries by Assessor

Assessor reports to Approval Body

Applicant invoiced for re-assessment fee

Fee paid?

Approval Body decision on

reassessment

NEW CERTIFICATE OF APPROVAL

Representations by ADS

Recommendation to revoke approval (with reasons)

Approval Body passes case to

Assessor

Approval Body Review

No Yes

HSE Disputes Procedure (Optional)

Within 2 months

Within ~4 months

Decision to revoke upheld

No

Yes

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SECTION THREE

Criteria for Approval

General

Criterion 1. The service shall be able to demonstrate that it has the necessary staff, expertise, resources and facilities to be able to provide and maintain a service which:

a) produces and maintains accurate records for classified persons which contain at least the minimum personal and dosimetric information required;

b) is highly reliable;

c) gives long term security for such records; and

d) sends accurate information from the records to the employer and HSE's Central Index of Dose Information (CIDI), when required, within a reasonable time.

Criterion 2. The service shall take all reasonable steps to ensure that facilities and general arrangements provided for dose record-keeping and the calibre of staff engaged in this work conform to the standards set out in the HSE publication 'General guidance for laboratories providing personal dosimetry services'6.

Guidance

on

criterion 2

Experience and independence of staff 2.1 Current staff should have relevant dosimetry experience. Adequate training programmes for new staff and refresher/update training for existing staff should be available. The head of the service should possess qualifications and experience appropriate to a dosimetry service approved for co-ordination and record-keeping. The responsibilities of staff should be clear and appropriate, for example, if the head of the service also fulfils another function for a client employer, such as a radiation protection adviser, the two roles should be clearly distinguished; and the latter role should not be allowed to interfere with the former.

Standard of facilities 2.2 No dosimetry service is likely to gain approval if its facilities for carrying out the work are:

• very cramped;

• insecure (for example sensitive areas of the facility are readily accessible to staff from another part of the organisation);

• not under the direct control of that service.

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2.3 In deciding whether or not a dosimetry service satisfies this criterion the Approval Body may take account of the scope of the dosimetry service concerned. However, it is for the dosimetry service to show, in particular circumstances, why it is not reasonable or necessary to meet the standards in the general guidance document6.

Quality Assurance

Criterion 3. The service shall have written quality assurance procedures for monitoring its overall performance. As part of these procedures all documents relating to the operation of the service, including copies of the current Statement of Service, and associated written laboratory instructions, shall have appropriate quality assurance control and be formally approved by the service.

Guidance

on

criterion 3

3.1 The objective of any quality assurance (QA) programme should be to implement a systematic process which will provide confidence that the records are accurate, conform to the criteria for approval and are retrievable. QA procedures should typically cover such matters as:

• selection and training of staff

• clear descriptions of working methods

• tests for corruption of reported doses and/or transcription errors (whether from written data or transfer by computer from ADS (Assessment)

• the validity of computer software used by the ADS for record-keeping

• the means of preventing dose data from degrading

• interface with employers

• inspections, checks and reviews to verify that the work is performed in an acceptable manner

• an audit of specific performance measures such as meeting the reporting requirements to employers and CIDI

• procedures for reporting internally and remedying all 'non-conformances', taking corrective action (including 'disaster recovery', eg. corruption of data) and preventing repetition.

3.2 HSE will accept that a service conforms to some, or all, of the above procedures if it has accreditation against relevant established standards (e.g. ISO17025 ‘General Requirements for the competence of testing and calibration laboratories’). Otherwise the service should be able to demonstrate equivalence.

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Design and definition of the dose record

Criterion 4. The service shall ensure that:

a) the database1 and its contents (or other system of records) that constitute the formal dose record required by regulation 22 IRR175, is clearly defined and identifiable;

b) the design and layout of the dose records is clear enough to make data comprehensible and input errors unlikely; and

c) a clear explanation of any codes or abbreviations is included in the dose records.

Guidance

on

criterion 4

Design of dose records 4.1 Only in exceptional circumstances should dose records be hand written, eg. small scale services with less than 10 classified workers. Hand written records are prone to error and misinterpretation; any service proposing to use these as the basis for the dose records should be able to demonstrate that each of the fields in the records is clearly separate from all the others and that entries will be in capitals or otherwise made in a clear fashion. 4.2 The design of forms and reports for computer-based systems should be clear. The layout of forms for the input of data should minimise the possibility of mistakes being made for data entry (there should not be undue reliance on codes). Also, the design of any database should permit all of the required information for dose records to be displayed, perhaps using menus (even if a series of screens has to be used). The Approval Body should be able to identify clearly all the elements listed in Annex 1 to verify that the criterion for approval can be met.

Contents of dose records

Criterion 5. The service shall ensure that dose records make provision for the items of information specified in Annex 1 to be separately recorded.

___________________________________________________________________

1 Information may be kept in more than one database but any such databases should be linked unequivocally with the composite record.

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Guidance

on

criterion 5

Recording special assessments of dose 5.1 Normally, the ADS would be expected to make provisions for recording all the components of dose set out in Annex 1 because dose assessments might be made from time to time for extremity dose, dose from internal emitters, etc. In special cases, the dosimetry service may be able to show it is highly unlikely that assessments of for example, internal dose will be made for the classified persons for whom records will be kept - the persons may only work with X-ray equipment. In these cases, and where it would be difficult for the dosimetry service to include that component of dose in the dose record, approval may still be given. However, the service should be able to show that this component of dose would be recorded, retained with the record for the relevant period and included in dose summaries in the event that an assessment of such a component was reported.

Receipt and recording of dose information

Criterion 6. The service shall ensure that the system for recording and storing data prevents corruption or degradation of the data and that it provides for the accurate recording of dose information in dose records for correctly identified individual classified persons.

Criterion 7. The service shall have adequate arrangements for obtaining from HSE's Central Index of Dose Information (CIDI) or the previous ADS (Records), or elsewhere, a summary of dose information relating to the previous exposure to ionising radiation of any classified person for whom a record is opened or re-opened.

Criterion 8. The service shall have adequate arrangements for receiving dose information from ADS (Assessment), validating it and transferring it accurately and in a clear and legible manner into the dose record. In normal circumstances, the transfer should be completed within 10 working days of receipt of the information from ADS (Assessment). The arrangements shall be sufficient to ensure that:

a) each of the items of personal information listed in Annex 1; and

b) all relevant dose assessments, assessment periods, dose summations and dose limits referred to in Annex 1 are entered into each dose record.

Guidance

on

criterion 8

System for receipt and recording of data 8.1 The system for receiving information from ADS (Assessment) may depend on the system of dosimetry concerned and on whether the same organisation carries out both functions, ie. the organisation operates as an ADS (Assessment) and as an ADS (Records). Automatic transfer of data from ADS (Assessment) to ADS (Records) is permissible provided that both ADS have arrangements for

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Guidance

on

criterion 8

(continued)

validating the transfer of data between each other before the data is recorded in the dose records. These arrangements should be sufficient to prevent the transmission of incorrect data and the incorporation of corrupt or incomplete data into dose records. 8.2 ADS (Records) will need to make sure that the service contributing data is an approved service (but see 'other assessed or estimated doses' below).

Period for recording 8.3 The 10 working days target for transferring assessed doses to dose records does not apply to dose information received late from ADS (Assessment), eg. because an employer returns dosemeters late.

Dose entries required 8.4 The dose entries made in records should be assessments of components of dose determined by an ADS (Assessment) acting on behalf of the employer in accordance with the IRR17. Where dose components come from one or more ADS (Assessment) ADS (Records) should make arrangements, on behalf of the employer, to co-ordinate the supply of these dose assessments.

Other assessed or estimated doses 8.5 Information received from site operators or their RPAs, rather than an ADS, should normally be used by the individual's employer for making estimates of dose when no other information is available (eg. a dosemeter has been lost). Assessments of dose for classified persons who are 'outside workers' may relate to work in controlled areas outside Great Britain but within Northern Ireland or a Member State of the European Union (EU). These assessments, whether by a dosimetry service approved in Great Britain or by a service approved in another Member State, should normally be treated as routine assessments in compliance with regulation 22(3)(i) IRR17 for outside workers, in the absence of routine assessments for the relevant period by an ADS in Great Britain. 8.6 In addition, the employer might inform the ADS (Records) of an estimated dose as provided by regulation 23(1) IRR17 where: (a) a dosemeter has been lost or cannot be read (see Criterion

10); or (b) an estimate of dose resulting from fixed skin contamination

or from contamination of clothing is provided by the employer following an incident; or

(c) a dosimetry service which is not approved by a Member

State of the EU notifies the employer of a dose assessment made as a result of an employee's work.

8.7 The ADS (Records) should have arrangements to incorporate such estimates into the dose record, if appropriate, where no corresponding dose assessment was made by ADS (Assessment). If a dose assessment was reported by an ADS and the employer's estimate of dose is much greater than/less than the reported dose the

23

employer may need to consider a special entry in the dose record (see relevant guidance to criterion 12). However, this would not be necessary where the estimated dose to the skin from contamination is for a specific part of the body - both doses (assessed and estimated) could be entered in the record where they relate to different parts of the body. Note that doses to the skin should be averaged over an area no greater than 1cm2.

Multiple employment 8.8 In some cases, a classified person may have two concurrent employments (eg. a contractor might carry out work for one employer during the day and another employer out of normal hours). IRR17 make no specific provision for this situation, except to require that each employer is in a position to compare the total dose received by an employee with relevant dose limits and investigation levels. Clearly, it is desirable that both employers co-operate to ensure there is a single dose record for the person, giving the total dose(s) received from both employments. If the ADS is aware that separate dose records are kept for the individual, arrangements should be made, if feasible, to ensure that cumulative doses from both employments are recorded in both records. The problem should not arise if the contractor is self-employed because there will only be one dose record.

Periods for which doses were not assessed 8.9 Periods for which a dose (or component of dose) was not reported, for example because the person did not work with ionising radiations at a particular time of the year, should normally be left as a blank in the relevant field. It is recommended that a flag or note be included in the record to explain the reason for leaving a blank. There is no value in recording zeros where an assessment was not made, as this will distort any statistics about average doses or the number of persons being monitored for a particular component of dose. It may also falsely imply that during a particular period of zero dose had been measured. In fact, an exposure may have occurred but for some reason a measurement was not made. Some employers may ask for the dose to the skin of the hand, or similar component of dose, to be separately assessed and recorded for certain periods of the year when particular operations are carried out. For the remainder of the year no separate assessments would be called for. In appropriate cases, ADS (Records) may, at the employer's request, enter assessments for such components in the record equal to the recorded dose from the whole body dosemeter where it was unnecessary to wear separate dosemeters; the employer may request this to provide a simple comparison with the relevant dose limit.

Cessation of employment 8.10 A dosimetry service approved for co-ordination and record-keeping needs effective arrangements with client employers to ensure that it is notified as soon as a classified person ceases employment with that employer, enabling the ADS to issue a termination record without undue delay. It should also reduce the risk of doses being inadvertently recorded for a particular person after they have left employment; the problem might arise if dosemeters assigned to that individual continued to be returned to ADS

24

(Assessment) at the end of the dose assessment period. In most cases, the recorded dose would be trivial (background); but in some cases the employer might have issued the dosemeter, in error, to another employee.

Criterion 9. The service shall ensure that the dose information is shown in the record in units of millisieverts (mSv), except that dose assessments reported for internal radiation in the form of Compliance Index (CI) may be shown in the record as a numeric value provided that:

a) it is clear that the quantity concerned is Compliance Index not dose; and

b) all summations for dose from internal radiation are shown as the product of CI and the appropriate dose limit (in millisieverts), a quantity that is deemed to be the committed effective dose or committed equivalent dose for that period.

Guidance

on

criterion 9

Compliance Index 9.1 The term 'compliance index' is fully explained in HSE's publication on monitoring for long-lived and long-retained radionuclides.

Late and missing dose assessments

Criterion 10. The service shall have adequate arrangements for alerting the employer to the need for an investigation and for the provision of an estimated dose in circumstances where ADS (Assessment) is unable to report an assessed dose for a classified person in any assessment period.

Guidance

on

criterion 10

Notional doses 10.1 There is no provision in IRR17 for an ADS (Records) to enter a notional dose in the dose record in such an event without the involvement of the employer. Appendix 2 gives further guidance on arrangements which might be used to deal with late dose assessments.

Identification of significant dose levels

Criterion 11. The service shall have routine procedures involving automatic checks or other suitable means to identify any individual whose recorded dose in any calendar year:

a) exceeds any relevant limit on effective dose (from external and internal radiation) or a relevant limit on equivalent dose;

25

b) is approaching any of the levels (specified in (a)) such that they would be exceeded if exposure continued at the same rate for the remainder of the calendar year.

Guidance

on

criterion 11

Approaching a specified level 11.1 The aim of this requirement is to identify individuals whose recorded doses are sufficiently high that it seems very likely they will exceed a dose limit (or other relevant level) before the end of the calendar year. It does not mean, for example, that an assessed dose of 2mSv in each of the first few months of the year must be identified. However, if an individual had a cumulative effective dose of say 18mSv by the October of any calendar year it would be reasonable to expect the ADS to have identified that person.

Methods of providing checks 11.2 One way of providing for these checks might be to include the additional data items, such as dose in a calendar quarter, in dose records then search these records at the end of each recording period to look for individuals whose recorded dose exceeds a specified value. However other methods which can be shown to be effective will be acceptable.

Relevant dose limits 11.3 It will be necessary to identify those whose recorded dose exceeds any special dose limit, for example one established under regulation 27 IRR17. 11.4 There is no obligation on the ADS to separately identify in a dose record any employee who has declared to their employer that they are pregnant or breastfeeding. Employers are expected to take proactive steps to alter the working conditions of such members of staff where appropriate.

Identification and reporting of exceedance of dose limits

Criterion 12. When an ADS has identified an individual whose recorded dose in any calendar year has exceeded any relevant limit on effective dose (from external and internal radiation) or a relevant limit on equivalent dose it must inform the HSE within 10 working days. It should do this via an email to irrnot@hse.gov.uk and include the following information

• The full name and national insurance number of the individual

• The name and address of the individual’s employer

• The nature of the overexposure including dose quantity in mSv

• A copy of the individual’s dose summary for that calendar year

• Any other information the ADS considers relevant.

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Permitted alterations to dose records

Criterion 13. The dosimetry service shall have auditable arrangements for:

a) making special entries in dose records when the employer requests the ADS to make a special entry in a dose record as provided by regulation 23(3) IRR17;

b) re-instating the original entry when directed to do so by HSE in accordance with regulation 23(7) IRR17;

c) modifying the record to indicate a pro-rata dose restriction for the remainder of the calendar year (or other relevant period) when an overexposure is indicated (regulation 27 IRR17);

d) entering in dose records revised dose entries associated with long-retained long-lived radionuclides, where the certificate of approval so provides;

e) modifying incorrect or out-of-date personal data;

f) modifying incorrect data entered into a record as a result of an error by that ADS or an ADS (Assessment); and

a suitable indication that such a change has been made shall be clearly identified in the dose record.

Guidance

on

criterion 13

Guidance

on

criterion 13

(continued)

Altering dose records 13.1 Except for corrections arising from minor errors, alterations which the service is permitted to make should normally be flagged in the record by an appropriate method. In this context minor errors would be seen as those discovered within a few weeks of the dose entry and which result from: (a) a transcription mistake (b) a computer malfunction 13.2 ADS are expected to make every effort to ensure that such errors do not occur. However, ADS should have auditable arrangements in place to ensure the correction of any such errors that do arise is carried out by an 'authorised person' and that a log is kept of all such amendments for future reference. 13.3 If a dose assessment is knowingly entered in the record in the belief that it was correctly reported by ADS (Assessment) it should normally be changed by ADS (Records) only in circumstances where there is clear evidence of a transcription or technical error by that service or by ADS (Assessment) and there is an auditable trail for that change. In other cases, it may be necessary for the employer to undertake an adequate investigation and make arrangements for a special entry, as permitted by regulation 23 IRR17, to be made in the dose record.

27

Special entries in dose records 13.4 The employer, rather than the ADS, is responsible for undertaking an investigation where recorded dose appear to be much greater than or much less than that received by a classified employee and for arranging special entry in the dose record if appropriate (regulation 23(3) IRR17). However, the ADS (Records) and the RPA may be asked to give advice as part of the investigation. Copies of guidance on special entries, including the details that should be considered in the investigation may be obtained from the HSE website. ADSs are encouraged to provide their clients with this guidance if it appears to them that a special entry will need to be considered. Employers should not request special entries without providing to the ADS an adequate summary of the investigation on which the substitute estimate of dose was based. The ADS has to retain that summary in accordance with Regulation 22(3)(g).of the IRR17 The employer is responsible for the quality of that summary.

Amending activities for intakes of long-lived radionuclides 13.5 Certain categories of ADS (Assessment) have conditions of approval which recognise that the final dose assessment is reached after a number of steps. Typically these are ADS assessing dose from long-lived long-retained radionuclides who may need to make assessments which extend over a number of months. The doses reported by such ADS may therefore be interim values. HSE has published guidance on this type of dose assessment6. Where such revisions are reported ADS (Records) may need to amend the dose records and prepare revised dose summaries and termination records. However, this is not meant to infer that ADS (Assessment) must review all historical dose information and report best estimates of dose in each case; the condition is only permissive.

Storage and security of records

Criterion 14. The service shall ensure that the system used for the storage of data in dose records satisfies the following conditions:

a) data are protected against accidental loss, corruption, or destruction at least until classified persons have reached the age of 75 and in any event for 30 years from when they were made;

b) copies of dose records and other relevant data are readily available from the storage system by persons permitted by the service to make such copies;

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c) the system is secure against unauthorised copying of dose records or dose summary information and also against any unauthorised alteration, use or access;

d) there is sufficient back-up within Great Britain of recorded data to guarantee preservation of the information so that records can be regenerated in the event of loss of the originals or failure of the service; and

e) the media used to transfer data to CIDI on annual dose summaries, termination records and registration reports are CIDI-compatible (as set out in Annex 2).

Guidance

on

criterion 14

CIDI-compatible transfer media 14.1 The dose records should be maintained on a computer database. Data transfer to CIDI should be by means of a portable flash drive or similar device or by password protected encrypted email. The format of the data must be compatible with CIDI requirements. 14.2 The role of the CIDI and the help that it can provide ADSs is described in NRPB - M1768.

Guidance

on

criterion 14

Storage of dose records 14.3 Records held by the ADS might include those which have been generated before or since the Ionising Radiations Regulations 1985 or 1999 came into effect as well as records (or summaries of appropriate records) provided by the employer under regulation 22(4) IRR17 in relation to exposure. For records made before 1/1/2000 arrangements must be good enough to ensure that the records can be held securely for the period and in the form specified by the legislation under which they were made (usually 30 years after the last entry for pre-1986 records and 50 years thereafter up until the introduction of IRR17). Any records (or copies of such records) made for the purposes of regulation 22 IRR17 need to be retained until the person has or would have reached the age of 75 and at least 30 years from when they were made. 14.4 There is no need to keep copies of records on the same electronic system for 30 years; indeed it may not be possible to do so because of the replacement of systems over time. It would be acceptable to copy the data to another suitable medium, such as microfiche or portable/standalone electronic storage device or medium for archiving (long term storage). But the service should show how it will obtain archived information about particular individuals and deal with any alterations permitted by HSE (at least by keeping a paper note securely with the record for future reference). A dosimetry service can be approved solely for the purpose of securely storing archived (ie. closed) records, making amendments permitted by HSE (see guidance to criterion 13) and permitting access to those records by persons authorised by the employer. An application for such an approval may need to be made if the service wishes to discontinue maintaining dose records, or the approval of a service for co-ordination and record-keeping is revoked,

29

(continued)

Guidance

on

criterion 14

and an employer wishes to archive dose records held for employees who are no longer classified persons.

Cessation of record-keeping for a particular employer 14.5 The responsibility for ensuring that dose records are created and maintained by an ADS for classified persons rests with the employer. An employer may decide to change from one ADS (Records) to another. If so, the employer must make suitable arrangements for the maintenance and storage of existing records. One arrangement might be for the existing ADS to pass these records to the new ADS for the latter to keep; this is likely to be the best approach since all the records will be kept together. Alternatively, if this is not possible, the existing ADS may continue to hold these records for the employer, and only provide a summary to the new ADS to enable the latter to open new records. An ADS should try to anticipate this situation when they agree to provide a service for an employer.

Data Protection Act 15.6 Although outside the scope of this document, it should be noted that dose records maintained under these Regulations will be subject to the provisions of the Data Protection Act 2018 and the General Data Protection Regulations (GDPR)..

Outside workers 15.7 Employers who have 'outside workers' are obliged to obtain radiation passbooks for these individuals from ADS (Records) and to ensure these are kept up to date. This function of an ADS (Records) is necessary to enable the relevant employer to satisfy the requirements of regulation 22 for those employees who are outside workers. These radiation passbooks are only obtainable through dosimetry services approved for co-ordination and record-keeping (ADS (Records)). ADS (Records) can obtain radiation passbooks from HSE Books. The address is: HSE Books PO Box 1999 Sudbury Suffolk CO10 2WA Tel: 01787 881165 Fax: 01787 313995 Website: www.hsebooks.co.uk

Long term retention of records 14.8 A practice that is growing in importance, not just for matters to do with dosimetry, is the use of specialised facilities for long-term archiving of documents, materials, etc. These facilities are often provided commercially as a service to users and offer a degree of security that may not be available locally. 14.9 ADS may wish to make use of facilities of this nature; they could be useful for the storage of documents that ADS wish to keep for their own purposes or ones that they are obliged to retain under RADS, for example all or parts of 'old' dose records. Such facilities could be appropriate where it is anticipated that the stored items will

30

(continued) only need to be retrieved very occasionally and the Approval Body will be prepared to consider the suitability of the arrangements for long term storage as part of its assessment of a dosimetry service. 14.10 Under some circumstances, separate approval of the facility may be necessary, especially for the long-term storage and retrieval of dose records. The need for separate approval would partly depend on the degree of 'control' the ADS may be able to exert over the operators of the storage facility. If such 'control' is limited, for example the operators of the facility are free to vary the conditions of storage or to restrict access of the ADS to their stored material, the archive facility may not be acceptable as part of the ADS arrangements, and it will require separate approval. 14.11 For example, an ADS may decide to keep some documents in a safety deposit box at its bank. Access to the documents would probably be restricted to a key-holder who would be a member of the ADS staff. In this case, although the ADS would be constrained by the bank's arrangements for access, the documents remain within the 'control' of the ADS to a large extent, and the storage facility would not require separate approval. However, the Approval Body might still wish to visit to satisfy itself that the facility met the requirements of RADS. 14.12 When an ADS intends to use such facilities, details of the arrangements it has made with the archiving facility, including the arrangements for security in transit of items between ADS and the facility, need to be referred to in its Statement of Service. It is the responsibility of the ADS to ensure that any such arrangements provide the necessary long-term security against deterioration, corruption of data, unauthorised access, etc. and that the stored items can be safely retrieved without undue delay when they are needed. ADS are answerable to their client employers for the provision of a satisfactory service overall. The Approval Body will need to be satisfied that the ADS arrangements are suitable before approval will be given.

Tracing basic data

Criterion 15. The service shall have adequate arrangements for tracing the basic data used for an individual's dose record, whether from its own records or otherwise.

Guidance

on

criterion 15

15.1 The most obvious way of meeting this requirement is to ensure an auditable trail from data held by ADS (Records) to the original assessment data retained by ADS (Assessment). The latter has to retain basic data such as readouts from individual dosemeters for at least 2 years (see for example RADS 1 criteria 2 and 11); factors such as quality factor and conversion coefficients from absorbed dose to personal dose equivalent should normally be retained by one of the services (by agreement) for the lifetime of the dose record.

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Provision of information to the employer

Criterion 16. The service shall have adequate arrangements to ensure that clear written or electronic dose summaries containing the following are provided or made available to employers at appropriate intervals not exceeding three months:

a) sufficient personal information to identify each classified person concerned unambiguously;

b) an accurate summary in mSv of the cumulative dose(s) for that person for each component of dose in the calendar year so far;

c) the relevant dose limit(s) for the whole body, lens of the eye, skin or extremity as applicable; and

d) sufficient notes to explain any codes or abbreviations used and any missing assessments for particular components of dose.

Criterion 17. The service shall also have adequate arrangements to ensure that employers are provided with the following information within the specified timescales:

a) as soon as practicable, the details of any employee whose recorded dose(s) in any calendar year:

i) exceeds any relevant limit on effective dose (from external and internal radiation) or a relevant limit on equivalent dose;

ii) is approaching any of the above levels (specified in (i)) where any of the levels would be exceeded if exposure continued at the same rate for the rest of the calendar year;

b) within eight weeks of being required by the employer;

i) termination records (see criterion 19);

ii) copies of the dose record of any classified employee;

iii) a summary record containing similar information to a termination record (end of record-keeping records) when the employer decides to change to a different dose record keeping service for any particular classified person.

Guidance

on

criterion 17

Dose summaries 17.1 Written or electronic/digital dose summaries for employers are important in monitoring the success of efforts to restrict exposure. Therefore, ADS (Records) are encouraged to supply the employer with the results of each separate dose assessment made during the period (for example where more than one dosemeter was worn

32

Guidance

on

criterion 17

(continued)

during the assessment period). 17.2 Usually, ADS (Records) will supply summaries for monthly dose assessment periods, sending these to employers no later than four weeks after the end of the relevant assessment period where ADS (Assessment) reports to the ADS (Records) within 14 days. There may be cases where a slightly longer period can be justified for supplying summaries to employers, eg. ADS (Assessment) has a phased system for issuing dosemeters, so ADS (Records) may have difficulty reporting complete batches of dose summaries within four weeks of the end of the dose assessment period. In such cases, ADS (Records) should aim to send employers brief reports of dose assessments for each four-week assessment period followed, within two weeks, by full dose summaries containing all the required information, including cumulative summaries of dose. For dose assessment periods as short as one week the ADS should show that the interval between its dose summaries is appropriate. 17.3 Where the relevant dose assessment period is three months ADS should send employers dose summaries for all their classified persons within four weeks of the end of the three month period, even if information for some individuals is incomplete. The dose summary should clearly indicate where information is incomplete or missing. 174 It is sensible to give a running total of the whole body dose and (where relevant) the dose to any organ or tissue and HSE believes that it would be helpful to an employer or customer for ADS to provide this total. In practice the employer is seldom comparing total dose with the limit because doses are usually very low. Rather, employers are looking to see if the dose for a period is seriously out of line with expectations, and the summation will assist them. 17.5 The contents of the summaries should be appropriate for the employers concerned and must contain the minimum information specified. The personal details should be sufficient to identify uniquely the person concerned to the employer, for example: (a) Full name; or name and initials plus identifier such as

National Insurance Number or unique number supplied by the employer;

(b) Name and address of employer (except in the circumstances

where the approval restricts the ADS to serving a single employer).

On-line access to dose summary information 17.6 An approved dosimetry service may choose to provide dose summary information electronically to clients with on-line access to its dose record database, with the agreement of the Approval Body. This access should be "read only" so that unauthorised alterations to dose records are prevented. Clients who do not have on-line access should still receive dose summaries in the usual way. 17.7 Clients with on-line access may elect to use this facility but ADS (Records) will still need to ensure that the employer is provided with dose summaries as required by criterion 16; these may be sent electronically or the employer could be alerted to summaries held on a particular part of the database to which there is on-line access.

33

Guidance

on

criterion 17

(continued)

Employers will need to have arrangements for retaining these summaries for at least 2 years (regulation 22(7) IRR17). 17.8 The most significant benefit of on-line access for employers is the improved information presentation and reduced storage requirements. The paper report provides the employer with the essential management data for strategic dose control and the on-line computer facility provides immediate access to the most up to date personal and dosimetry information held on the ADS' database.

Application of the timescales 17.9 The dosimetry service should be able to show that the arrangements are sufficient to ensure the required information will be provided consistently within the periods specified. There will be some special circumstances when, occasionally, these timescales cannot be met. This criterion allows targets to be set for performance. It is not intended to include records where dose assessments are reported late, for example. 17.10 'As soon as practicable' might reasonably be interpreted as forwarding the information by telephone or email as soon as the information becomes available followed up by written confirmation.

Termination records 17.11 The minimum content of these is set out in criterion 20. The agreement with the employer should ensure that the ADS is informed as soon as practicable when an employee ceases classified work with the employer, so that a 'termination record' can be generated without delay. Notification of termination of employment should be taken as a 'request' by the employer for a termination record. 17.12 If the person continues in employment, but is no longer classified and is unlikely to be classified again, it may be appropriate for the ADS to produce a summary of the dose record for that person. 17.13 Normally, employees can only cease being treated as classified persons at the end of the calendar year (regulation 21 IRR17). Therefore, the employer should maintain arrangements for assessing any significant exposure and for medical surveillance for that person until the end of the year. The exceptions to this are where:

• the appointed doctor declares that the person is unfit for such work;

• the employee ceases employment;

• the employee is moved to a different job which does not involve any significant exposure to ionising radiation. Dose assessments in the new job would only be required where the post involves significant exposure to ionising radiation.

17.14 CIDI should be informed at the end of the year, as part of the annual return, that the employee had ceased classified work with the current employer. The ADS should not delay informing CIDI until employment is eventually terminated, possibly some years later. 17.15 The main purpose of a termination record is to convey to a new employer the dose history of a worker that employer intends to

34

Guidance

on

criterion 17

(continued)

designate as a classified person. Regulation 22(3)(d) IRR17 requires the production of a termination record only for "a person who ceases to be an employee of the employer". However, if the termination record is not produced at that time when the employee ceases to be a classified person there is a danger that when the employment is eventually terminated the requirement will be overlooked. 17.16 One simple arrangement would be to produce an interim termination record at the time the employer notifies the ADS that an employee has ceased classified work, even though he or she is still employed. This is acceptable provided that the employee is most unlikely to be designated as a classified person again in that employment. It should not be necessary to send an interim termination record (the short form of the termination record) to CIDI provided the information is included in the annual return as explained above. 17.17 This interim termination record will suffice for the purposes of regulation 22 unless he or she undertakes a further spell of classified work with that employer before ceasing employment. If the employee returns to classified employment before ceasing that employment, or any of the other details mentioned in criterion 20 or Annex 1 have changed, a fresh termination record will be required to replace the ‘interim’ report. 17.18 If the individual starts work for a new employer as a classified person having ceased previous classified work well before changing jobs, the dose history should be available through CIDI.

Change of ADS 17.19 The dose record should show the date of termination of dose record-keeping by the 'old' ADS. At the end of the year the 'old' ADS would normally report the part-year dose for which it was responsible to CIDI. 17.20 The 'new' ADS should send a registration report to CIDI giving relevant details of the individuals for whom dose records are being opened. The date recorded for 'start of classified work in that employment' would normally be the start date shown in the record created by the 'old' ADS. However, if this is unknown the start date will be the date on which the new ADS assumed responsibility for the record. CIDI will open a new record under the new employer code that the ADS has provided. 17.21 Any contractual responsibilities the 'old' ADS has for arrangements made under IRR17 regulation 22 would cease when the contract was terminated. However, the employer needs to make arrangements to ensure that the 'old' dose records are properly preserved. The ADS should co-operate in whatever reasonable arrangements the employer proposes. The best approach is for the 'old' ADS to pass all the records to the 'new' ADS to keep; alternatively the 'old' ADS could keep the existing records and give a summary to the new ADS.

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Provision of information to HSE’s Central Index of Dose Information (CIDI)

Criterion 18. The service shall have adequate arrangements to ensure that the following information is sent to CIDI within the specified timescales:

a) accurate summaries of all current dose records relating to the last year (using the format in Annex 2 of this document), within three months of the end of a calendar year or such later period as may be agreed (regulation 22(3)(e) IRR17); and

b) a ‘CIDI termination report relating to a classified person who has ceased employment with an employer (regulation 22(3)(d) IRR17), within eight weeks of being notified by the employer.

Guidance

on

criterion 18

Guidance

on

criterion 18

(continued)

Application of timescales 18.1 The dosimetry service should make arrangements to ensure that the required information will be supplied within these timescales under most circumstances. Occasionally, this may not be possible, for example where reports by ADS (Assessment) are late. ADS should warn HSE if the information is likely to be delayed significantly, particularly in the case of annual dose summaries, so that a longer period can be agreed, if necessary.

Supply of annual dose summaries (annual returns) 18.2 For annual dose summaries, the ADS should forward to HSE CIDI all the available summaries relating to individuals, if necessary explaining why the remainder have been delayed. In cases of particular difficulty HSE may agree a longer period provided the service has approached HSE before the end of March (regulation 22(3)(e) IRR17). 18.3 The annual summaries should be sent to the HSE CIDI administrator. The dosimetry service should normally state in a covering note the total number of annual summaries being sent, if data are supplied in batches, and the total number of records within each return/batch; this will help to identify any shortfall in the number of records being sent, (an important part of the service's arrangements for quality assurance - see criterion 3). The summaries should be accurate; it is the responsibility of the ADS to check the data before supplying them to CIDI to eliminate any errors. However, as some inconsistencies might still arise, for example in personal details that differ from those previously supplied to CIDI, the arrangements should allow for the timely correction of any data sent to the CIDI office. If mistakes are discovered in the data these will be notified to the ADS who will be expected to correct them and return the revised data to the CIDI office within about six weeks. The ADS should supply the required information on CIDI compatible transfer media (as described in criterion 13).

Change of employer during the year 18.4 ADS have to send annual summaries of current dose records to CIDI on behalf of each employer for whom they have acted during the year (regulation 22(3)(e) IRR17).

36

Guidance

on

criterion 18

(continued)

18.5 For persons who change classified employment during the year the annual dose summary should only show the cumulative dose(s) up to the point where the particular ADS ceased to have responsibility for dose record-keeping for a particular employment. This means that a classified person who changes employer on 1 June would normally be credited with two annual dose summaries: the first will include the dose up until June and the second, which the subsequent ADS should report, will show the total dose(s) for the year. 18.6 This pattern of reporting should be maintained even if the same ADS is responsible for dose record-keeping through both periods i.e. if a classified person changes employer but the ADS continues to maintain that person's dose record for the new employer. In such cases, two dose summaries should be sent to CIDI at the end of the year.

Content of dose summaries to CIDI 18.7 ADS are required to employ the format set out in Annex 2. 18.8 Annual dose summaries sent to CIDI should only relate to employers (and classified persons) already recorded on CIDI. 18.9 If the format of the dose summaries sent to CIDI Office does not match that set out in Annex 2 or non valid numbers are used in substitution for the NIN or employer, the data will be returned to the ADS for amendment.

Dose assessments for intakes of long-lived radionuclides 18.10 In the case of long-retained, long-lived radionuclides, current records may contain interim assessments. ADS (Records) should send the required information to CIDI using the latest available assessments. If these assessments are subsequently revised the ADS should send an amending record to CIDI (see criterion 19). If information is missing, for example no assessment of internal dose is available for the last assessment period, the ADS should send the required information with a note explaining that certain details are missing and will be supplied in due course (in an amendment record). Information for CIDI should not be held up for this reason.

CIDI Termination record 18.11 The arrangements employers are required to make with an ADS include the provision of copy 'termination records' to HSE. As CIDI should already have all the relevant personal details of an individual (see Annex 1), and ADSs use 'termination records' of various designs, a truncated version of a basic termination record (the 'CIDI termination report') is all that is required. The computer- compatible form of this report, which most ADS would be expected to use, is given in Annex 2. The guidance to criterion 19 gives more advice on the meaning of the various fields. Prompt supply of termination reports to CIDI is important because this enables CIDI to supply the new ADS (Records) with an entry report giving the current year's doses. ADS should not delay sending termination reports to

37

CIDI- these can be amended later if necessary. Occasionally, employees cease classified work but continue in employment with the same company for some years afterwards. In these circumstances CIDI should be informed, as part of the annual return, that they have finished classified work; the ADS should not delay informing CIDI until employment is eventually terminated. Without this information CIDI will continue to treat the individuals as classified persons for whom an annual dose summary should be supplied.

Supplementary information to CIDI

Criterion 19. The service shall have arrangements to provide the following supplementary information to CIDI when appropriate:

a) the name, address and reference number of every new employer for whom the dosimetry service intends to maintain records of classified persons); and

b) additional 'registration reports' relating to any persons for whom the dosimetry service takes over responsibility for record-keeping from another ADS;

c) an 'amending record' when new information is received and leads to a significant amendment to information already supplied to CIDI as specified in criterion 17.

Guidance

on

criterion 19

Guidance

on

criterion 19

(continued)

CIDI reference number 19.1 A reference number will be assigned to the employer by ADS (Records) from a block of such numbers allocated to the ADS by CIDI; the ADS will be expected to advise CIDI of the number chosen for each new employer.

Registration reports' and 'entry reports'' 19.2 'Registration reports' have three purposes: (a) to enable CIDI to know when a new record should be opened

for an individual (b) to enable CIDI to carry out its 'index' function to show which

ADS is currently responsible for dose record-keeping in respect of any classified person

(c) to trigger the supply, from CIDI, to the current ADS (Records)

of summarised dose information about an individual's recent dose history so the employer can be made aware of any special need to restrict that person's future exposure.

19.3 On receipt of a 'registration report', CIDI will generate an 'entry report' (see Annex 2). Normally, this will be returned to the ADS within two weeks.

38

19.4 When a classified person begins work with a new employer the ADS might require dose information quickly; particularly where the individual changes employment fairly frequently (eg. some industrial radiographers). If this cannot wait until an entry report has been received from CIDI the ADS should request relevant information (by fax) from the previous ADS; CIDI will provide details of the previous ADS. Alternatively, the employee may provide a copy of his or her termination record to the employer, who can pass it on to the ADS. 19.5 If classified persons transfer quickly to a new employer CIDI will not have relevant information for that person in the current year; only previous years' annual dose summaries will be available. Therefore, the previous ADS will be the only source of up-to-date information for that person. 19.6 Normally, a CIDI 'entry report' can be regarded as a sufficient statement of an individual's dose in the current year (and in the previous four years) since it will reproduce information supplied to CIDI in a 'termination record' by the previous ADS. However, the accuracy of the information is dependent on the previous ADS supplying amending records to reflect any amendments or updating information. If in doubt check with the last ADS.

Amendments 19.7 The ADS should normally establish a system for logging information reported by employers (e.g. special entries, occupational category) which would trigger an amending record to be sent to CIDI. These are important if CIDI is to maintain the level of accurate information ADS (and individual classified persons) may need. Also, it distorts the annual statistics of CIDI if important dose data have not been amended. Dosimetry services specially approved for making changes to dose records in respect of doses from intakes of long-lived radionuclides should notify CIDI of any changes to information already supplied to CIDI, including those made to termination records.

Take-over of business from another ADS 19.8 Where one ADS takes over responsibility for dose record-keeping from another, CIDI requires sufficient information to update the personal information for each record, including the ADS responsible for record-keeping. Usually this will be done by assigning a different employer reference number to the record since these are usually allocated to employers by specific ADS. The minimum information required is the names and NINs of the classified persons involved; this is best provided using a series of registration reports. 'Termination records' are not required because the employer responsible for the classified persons has not changed.

Quality checks 19.9 When ADS forward these records to CIDI it is good practice to state in a covering note the number and type of each record being sent (data quality check - see criterion 3). This will enable the ADS and CIDI to check that the information is complete.

39

Content of termination records

Criterion 20. Termination records provided by the dosimetry service shall contain at least the following information:

a) personal details as specified in Annex 1;

b) effective dose from external radiation for current year;

c) committed effective dose from internal radiation for current year - flag if it includes long-lived radionuclides;

d) the sum of effective dose from external radiation and committed effective dose from internal radiation for each of the previous four calendar years where that individual is subject to a five year dose limit;

e) for the eye lens, any body extremity or any area of skin where separate assessments are undertaken: the equivalent dose from external radiation for the current year (where they exceed 10% of the proportion of the dose limit for the period covered);

f) special dose restrictions established under regulation 27 IRR17 or recorded in the Health Record relating to the individual and notified by the employer under (regulation 22(4) IRR17);

g) cumulative effective dose from external radiation and committed effective dose from internal radiation to date, to the extent that this is known;

h) neutron component of effective dose for the current year, where known; and

i) notional component of dose for the current year (where this is known to exceed 10% of the sum of effective dose).

Guidance

on

criterion 20

Long-lived radionuclides 20.1 Where there are compelling reasons for not providing (b) and (c) separately, the sum of Effective Dose from external radiation Eext and Committed Effective Dose from internal radiation, Eint should be given with a flag if there is an internal component and a further flag if there is a contribution from intake of long-lived radionuclides. 'Termination records' should not, however, be held up for dose information concerning long-lived radionuclides. Whatever records exist should be used to provide part, if not all, of the information required. Where dosimetry services are approved to make changes in dose records relating to the prolonged retention of long-lived radionuclides, they would be expected to notify any changes affecting the termination record information to the former employer (for transmission to the employee).

Cumulative dose 20.2 Cumulative dose should include information on Effective

40

Dose Equivalent from pre-1986 dose records made available by the employer, records of Effective Dose Equivalent and Committed Effective Dose Equivalent for the period after 1985 until the end of 1999 and records of Eext and Eint from the year 2000. These should be treated as additive, albeit that dose quantities have changed over this period of time. Retrospective computation of any dose quantities for years before 1986 need not be carried out in order to provide the requested information. This information is occasionally referred to as 'lifetime dose'. However, that term is incorrect since the data may be incomplete.

CIDI Termination report 20.3 The shorter 'CIDI termination report' sent to CIDI should contain the same information as the 'termination record', except for certain details about the employer and ADS already held by CIDI. Normally, the data should be supplied in CIDI-compatible format described in Annex 2.

Information for the HSE

Criterion 21. On reasonable request, the service shall make available to the HSE a copy of the dose record relating to a classified person.

Information for other Approved Dosimetry Services

Criterion 22. On reasonable request, the service shall make available to other approved dosimetry services in the European Union summaries of dose record data that are necessary in order to:

a) open a new dose record for a classified person (category A) who has changed employer; or

b) verify dose assessments given in the radiation passbook of an outside worker

41

Annex 1 to criteria for approval - content of dose records (see criterion 5)

Table 1, Annex 1 - Type of Information

Requirement

(A1.1) Personal information (a) Full name (b) National insurance number* (c) Gender (Male/Female) (d) Full date of birth (e) Date of commencement as classified person in the current employment (f) Date of termination as classified person in the current employment, if unknown, date of

termination of dose record-keeping by this ADS during work in this employment (with indication as to which date used)

(g) Occupational category for the current year (see Table 2)** (h) Name and address of employer and main place of work of the classified person in the current year

(base location for peripatetic workers) (i) Name and address of all ADS supplying dose assessment information for this record**

Required for inclusion in dose record in every case

(A1.2) Summary of dose information relating to previous work with ionising radiation (where available)

(a) Effective dose from external radiation (Eext) for current year; (b) Committed effective dose from internal radiation (Eint) for current year; (c) Effective dose (E) being the sum of (Eext) and (Eint) for current year; (d) Where the individual is subject to a five year dose limit, the effective dose (E) being the sum of

(Eext) and (Eint) for each of the previous four calendar years together with the summation of those four doses;

(e) The equivalent dose (HT) for the current year of any assessed dose for the lens of the eye, any body extremity and any area of the skin (the area over which the dose is averaged shall not exceed 1 cm2 regardless of the area of skin exposed);

(f) Cumulative effective dose over the working lifetime, from external radiation (Eext) and internal radiation (Eint) (to the extent that this is known); and

(g) Neutron component of effective dose for the current year (where assessed).

Provision should be made for this information in each case but only has to be included where it is made available.

42

Requirement

(A1.3) Dose assessments under Regulation 22 IRR17 (and dose estimates made under regulation 23 IRR17) for external radiations (Eext):

(a) Effective dose from external radiation (Eext) for each dose assessment period to which the entry

relates (for example 01 June 2008 to 30 June 2008) and for each calendar year; (b) Equivalent dose to the lens of the eye (where this may be assessed separately) for each of the

periods specified in (a) above; (c) Equivalent dose to the skin (specifying where on the body the dose assessment was made) for

each of the periods specified in (a) above; (d) Equivalent dose to the hands, forearms, feet and ankles (specifying on which extremity the dose

assessment was made) from external radiation (where these may be assessed separately) for each of the periods specified in (a) above;

(e) Neutron component of effective dose and equivalent dose (where exposure to neutrons may be assessed) for each of the periods specified in (a) above.

Required for inclusion in dose record in every case unless person is unlikely to be exposed to external radiation.

(A1.4) Dose Assessments under Regulation 22 IRR17 (and dose estimates under regulation 23 IRR17) for internal radiations (Eint)

Committed effective dose from internal radiations during each dose assessment period to which the entry relates (for example 01 June 2008 to 30 June 2008) and for each calendar year.

Required for inclusion in dose record in every case unless person is unlikely to be exposed to internal radiation.

(A1.5) Dose assessments for accidents reported by employers under Regulation 26 IRR17 Estimate of effective dose (E) (from external radiation (Eext) and internal radiation (Eint)) for a dose assessment period in any case where the employer reports any accidental dose as a result of an investigation under regulation 26 IRR17.

Provision should be made for this information in each case but it only has to be included where it is made available.

(A1.6) Summation of external dose and internal dose for each calendar year (a) Effective dose - sum of effective dose from external radiations (Eext) and committed effective dose

from internal radiations (Eint) (b) Lens of the eye, skin, and body extremities - equivalent dose (where this may be assessed

separately).

Required in every case

(A1.7) Estimated and notional doses (a) A 'flag' for any estimated or notional dose which is reported; (b) The separate summation of all notional whole body doses; (c) The inclusion of all notional and estimated doses in dose summations.

Required in all records containing such estimates and notional doses.

43

Requirement

(A1.8) Changes to dose record (a) A 'flag' for any special entries made in the dose record on advice from the employer in

accordance with regulation 23 IRR17; (b) Any other change (see criterion 13).

Provision to be made in every case but information only included when received from employer.

(A1.9) Summary of additional information The results of any workplace monitoring used by the employer to estimate individual doses under regulation 23 IRR17.

Required but information included at least in linked database when received from employer.

(A1.10) Dose limits All relevant dose limits for that individual (and further restrictions on dose as provided by regulation 27 IRR17).

Required in every case

(A1.11) Any other relevant information

Optional but see criterion 13.

* In exceptional cases, where a NIN is not available, an alternative unique identifier could be used - see guidance.

** These items need not be kept together in one database but they should all be linked unequivocally with the composite dose record.

44

Table 2, Annex 1 - Occupational categories to be used in dose records

SECTOR MAIN OCCUPATIONAL CATEGORY OF CLASSIFIED PERSON IN YEAR CODE

Nuclear (Including contractors)

1

Nuclear reactor operations Nuclear reactor maintenance

Nuclear Fuel fabrication Nuclear Fuel reprocessing Nuclear decommissioning

Site radiography (without a shielded enclosure) Nuclear industry applications not mentioned elsewhere

103 104 105 106 153 102 150

Dental, Medical and Veterinary

2

Medical applications, doctors Medical Applications, nurses

Medical applications, medical radiographers Medical applications, physicists and physics technicians

Other medical applications Dental applications

Veterinary work

230 231 232 233 234 225 226

Research and teaching 3

Academic research and teaching Industrial research

341 342

Mining/drilling/quarrying 4

Offshore work activities Site radiography (without a shielded enclosure)

Onshore drilling activities Mining coal - underground workers

Mining coal - surface workers Mining minerals other than coal - underground workers

Mining minerals other than coal - surface workers Quarrying

415 402 416 417 418 419 420 440

General Industrial 5

Application and servicing of machines producing ionising radiations (other than those covered elsewhere)

Application and manipulation of radioactive substances (other than those covered elsewhere)

Industrial applications not mentioned elsewhere

510

511

551

Non-Destructive testing 6

Industrial radiography using permanent shielded enclosures Site radiography (without a shielded enclosure)

601 602

Other 7

Radioactive waste treatment Radiological protection

Transport activities Defence related activities not covered elsewhere

Others

707 708 714 749 752

45

Design of dose records

Hand written record cards are prone to error and misinterpretation; any small-scale service (i.e. with dose records for less than 10 classified persons) proposing to use these as the basis for the dose records should be able to demonstrate that each of the fields in the records is clearly separate from all the others and that entries will be printed or otherwise made in a clear fashion.

The design of forms and reports for computer-based systems should be clear. The layout of forms for the input of data should minimise the possibility of mistakes being made for data entry (there should not be undue reliance on codes). Also, the design of any database should permit all of the required information for dose records to be displayed, perhaps using menus (even if a series of screens has to be used). The Approval Body should be able to identify clearly all the elements listed in annex 1 to verify that the criterion for approval can be met.

Required fields/data items

The mandatory fields listed above in Tables 1 and 2 are set out in tabular form in Table 3 below. This is not intended to represent a dose record but simply to illustrate the presentation of the fields in a convenient visual form.

Personal information - NIN and Name

In most cases the record should include the unique national insurance number. In exceptional cases, where the NIN is not available, an alternative unique number may be used provided CIDI is informed in advance. The most obvious exceptions would be service personnel and foreign nationals. In the former case a unique service number may suffice; in the latter case CIDI will provide a suitable alternative. ADS (Assessment) need not report NIN to ADS (Records) provided that an alternative unique personal identifier is acceptable to both parties. However, as stated above, the final record should normally include the NIN. Any personal identification number (PIN) used should be unique to the individual concerned and that person should be readily identifiable from the PIN by a recorded link. Providing the correct NIN should prevent errors in the recording of dose summary information, including data sent to CIDI. However, provision should also be made for the full name of all classified persons to be recorded as part of the record. This is necessary, in addition to the NIN (the key identifier), to help avoid errors at CIDI - experience has shown that data sent to CIDI by dosimetry services might occasionally contain an incorrect NIN (though the ADS should take steps to avoid this). In exceptional cases, it may be acceptable to use the surname and initials, where the dosimetry service cannot obtain the full name, from the employer and can justify this approach by demonstrating that errors cannot occur. Obviously, the surname should be clearly indicated, whatever approach is taken (e.g. John, BARRY).

Dose Quantities

Fields for Eext, Eint etc should be clearly labelled as such unless the ADS can justify the use of a different label. If a different label is used it should be clearly explained in notes accompanying the dose record, or otherwise, that the relevant field is Eext, Ein etc. Normally, dose should be reported to ADS (Records) by ADS (Assessment)

46

as Effective Dose etc regardless of the precise method of assessment. However, some ADS (Assessment) are approved to report 'Compliance Index' (CI) in respect of intakes of long-lived radionuclides. In these cases, the record-keeping service may label the relevant field 'compliance index' and record this quantity, provided that all dose summaries are shown as Eint given as the product of CI and the relevant dose limit.

Dose information

Dosimetry services should note that the date of the actual dose assessment period is required for example 08 April 2008 to 07 May 2008, which would usually coincide with the period of issue. Records that state only the sequential number assigned to that period (e.g. 'period 1') or the calendar month would not normally be sufficient, unless the record contains a note explaining clearly the convention adopted, to remove any ambiguity. Many dose records will include a quarterly dose summation. While this is desirable it is not essential. For each dose quantity recorded in the dose record, the relevant dose limit should be stated. Where appropriate this should include the special dose limits for women of reproductive capacity or women who are declared pregnant.

Occupational categories

Recording both sector and specific category

Both the general sector of work which contributed most to the dose that year and the specific occupational category need to be shown. i.e. ‘102’ means site radiography carried out predominately at a nuclear installation whereas ‘602’ would be used for site radiography carried out at engineering and chemical plants and ‘402’ would be used for site radiography carried out mainly offshore.

Change of category during the year

In the case where more than one of the above categories is appropriate, the one that is believed to attribute the largest proportion to the dose record should be entered. If this belief changes, the new category should be entered on the next return to CIDI.

Nuclear

The first five categories should only be used for those site employees and contractors directly engaged in or directly supporting the work. Site radiography contractors working on licensed sites should generally be assigned to category '102', while construction contractors and others whose exposure is largely related to radiations arising from nuclear operations should be assigned to category '150'.

Medical/dental and veterinary

These categories should be used for those directly involved or supporting medical exposures of patients and intentional exposures of animals for the purpose of diagnosis or therapy. Doctors and vets who undertake medical research in research laboratories should be assigned to category '241'.

47

Mining/drilling/quarrying

Those engaged in well logging or the use of gauges and those exposed to radon decay products in these industries will fall into this category. Contractors engaged in other types of generic work e.g. site radiography should be placed in a more specific category.

Non-Destructive testing

The division between 'permanent' industrial radiography and 'site' radiography will depend on whether the majority of the work is carried out in purpose made shielded enclosures (either on the employer's premises or the client's premises) or under 'site radiography conditions'. Since the latter is far more likely to result in significant exposure, individuals who spend a significant proportion (>10%) of their time carrying out 'site radiography' should be assigned to category '602'. Work with nuclear density moisture gauges, column scanning equipment and other work which does not result in the production of an image is not regarded as 'industrial radiography' and should be assigned to categories '510' or '511' as appropriate.

Industrial applications

Category '510' is intended to cover both radiation generators and machines which incorporate radioactive sources (e.g. thickness, density and moisture gauges). It would include work associated with sterilisation plants (gamma irradiators), Linacs, electron microscopes, and other high voltage equipment for industrial purposes. It also covers those who manufacture or service equipment, including medical X-ray equipment, and calibration (except where category 8 would be more appropriate). It does not cover those who strip down articles containing radioactive substances (e.g. smoke detectors) for re-use or disposal of the source; see category '511'. Categories '601' and '602' should be used for industrial radiography but not work with radioactive gauges. Category '511' covers the production, processing and manipulation of sealed and unsealed sources (including radiopharmaceuticals)

Other

Use of Category '752' should be avoided if at all possible; only use this if there is no other suitable category.

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Table 3, Annex 1 - Content of Dose Records - Illustration of Information Required Full name NIN Male/Female (Surname and forenames)

Date of birth Occupational category Year

Date of commencement as a classified person Date of termination as a classified person (this employment) (this employment)

Employers name/address/main place of work or Name and address of contributing ADS (Assessment) base location

Actual period for which dose assessment made

Total external dose (including neutrons)

Dose from Neutrons

only

Total internal dose (50-year committed

effective dose)

Doses assessed under reg

25 Comments

Eext Whole body

HT Skin

HT Eye/hand

etc

Eext Whole body

Eint Committed whole body

E (Eext + Eint)

(mSv) (mSv) (mSv) (mSv) (mSv) (mSv)

Col 1 Col 2 Col 3 Col 4 Col 5 Col 6 Col 7 Col 8

Summary of doses for previous employment

Day/Month/Year eg 1/6/2008 - 30/6/2008

Total for calendar year so far

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Table 3, Annex 1 - Content of Dose Records - Illustration of Information Required (cont'd) Full name NIN Male/Female (Surname and forenames)

Date of birth Occupational category Year

Employers name/address/main place of work or base location

E (i.e Eext + Eint ) Whole body

HT Skin

HT Tissue/Organ

(mSv) (mSv) (mSv)

Summation of assessed dose for year so far

Summation for previous 4 years (where appropriate)

Sum of all notional doses

Annual dose limit Code - eg ‘RH’ - right hand E - Effective Dose Eext - Effective Dose from external radiation.

‘n’ - notional dose ‘LH’ - left hand HT - Equivalent Dose to named tissue eg skin

‘e’ - estimated dose

‘s’ - special entry to dose record

Need to check that all the requirements for records are illustrated above

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Annex 2 to HSE criteria for approval - CIDI compatible records (see criteria 14 and 18)

Transfer media used for CIDI

A2.1 The acceptable medium is password protected files on removable media with the password sent under separate cover or e-mail.

A2.2 These should have one text file (or two text files if termination records/registration reports accompany annual returns) which contain the records listed below, each terminated by 'carriage return - line feed'. The text file should have a name of the following structure:

(a) for annual returns: AaaaaA08.TXT

where aaaa is the ADS number and the annual returns are for 2008, eg A0030A08.TXT for the 2008 annual returns from ADS number 30; and

(b) for termination records and registration reports: AaaaaTnn.TXT

where aaaa is the ADS number and nn is a sequence number identifying this batch of termination records/registration reports in the year, e.g. A0100T03.TXT for the third batch of records from ADS number 100.

Data formats

A2.3 Data will be transferred as fixed length computer records. All data are in ASCII characters (8 bit bytes). Records should be 120 bytes long. Where data items are shorter than the fields provided they should be padded with blanks (ie numerical data should not be padded with leading zeroes). Character data should be left-justified within a field and numeric data right-justified.

A2.4 The data items included on each record, ie registration report, entry report, annual return and CIDI termination record are specified below.

Record Formats

A2.5 The formats to be used for computer-compatible registration reports, entry reports, annual returns and termination records are described below in table form with appropriate notes (see criteria 17 and 18). The registration report will normally consist of a single computer compatible personal record. The other three each consist of a computer-compatible personal record with one or more computer compatible dose records.

A2.6 Approved dosimetry services should send annual returns, registration reports and termination records on separate files. These files may be on the same transfer medium .

A2.7 Examples are included of annual returns as sent to CIDI, which also serve as examples of the format for other types of record.

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Table 1, Annex 2 - Format of computer compatible personal record

Item Length Columns

1 Record type 1 1 2 Record counter 1 2 3 Record key 1 3 4 Amendment flag 1 4 5 Flag 1 5 6 Spare 1 1 6 7 National insurance number 8 7-14 8 Approved dosimetry service 4 15-18 9 Employer number 6 19-24

10 Date of birth 8 25-32 11 Sex 1 33 12 Occupational category 3 34-36 13 Date of commencement of classified work in this employment 8 37-44 14 Date of termination of classified work in this employment 8 45-52 15 Alternative personal identifier 8 53-60 16 Surname 16 61-76 17 Forenames 24 77-100

18 Spare 3 26 101-120

Notes

1. Record type

R - Registration report.

E - Entry report.

A - Annual return.

T - Termination record.

2. Record counter

Always '1' on this record.

3. Record key

'P' for personal data.

4. Amendment flag

'A', 'R' or blank.

Normally blank. Set to 'A' if the record amends one that was sent to CIDI with erroneous information. Such amendment records should contain full information, not just that which is being corrected. It is expected that amendment records will be very rare. Set to 'R' if there are minor revisions in data items from a previous data transfer. Note the distinction

'A' --> replacement record

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'R' --> warning that minor data item (eg, job category) has been revised.

It is impossible to specify precisely which changes should be notified as amendments. Special entries authorised by HSE should certainly be notified to CIDI as an amendment as should any significant revisions of dose which might affect the radiation management of a person.

5 Flag

Blank or one of the following special values.

'D' on registration report if the approved dosimetry service (ADS) has obtained the dose history from a termination record.

'I' on registration report if the ADS has obtained the dose history from its own internal records (eg, for a person starting a second or subsequent period of radiation work within the same employment).

‘U’ on entry report if CIDI has no previous record for this person.

‘W’ on entry report if CIDI is waiting for a termination record for a previous employment (in any case the entry report provides the code number of the old ADS).

'S' on entry report and termination record if the individual is subject to a special dose limitation (details to be specified in an accompanying letter).

'C' on annual return if the person is continuing to be classified.

'L' on annual return if the person ceased to be classified during the year.

6 Spare-1

7 National insurance number

Two letters followed by six digits, eg, 'AB123456'.

Another letter may have been appended, eg, 'AB123456A'. This should be removed and the eight-character form above used. In very rare cases, classified persons may not have a national insurance number. For such individuals CIDI will issue a surrogate NIN for use in communications between the ADS and CIDI.

8 Approved dosimetry service number

A number allocated to the approved dosimetry service by CIDI.

9 Employer number

A number allocated to the employer by CIDI.

'Employer' here generally refers to the organisation legally responsible for the employment of the person. When a classified person leaves employment a

58

termination record must be sent to CIDI [Regulation 21(3)(d) IRR17]. No termination record should be sent, or change of employer notified, if the individual moves between sites or departments operated by the same employer. However, in some circumstances, where different ADSs provide monitoring for different large sites run by the same employer, then separate employer numbers will be issued to sites by CIDI. There is, of course, no reason why an ADS should not subdivide other employers if it wishes, However, all such subdivisions must be assigned the same CIDI employer code number.

10 Date of birth

Full date of birth in the form, eg, '01021943' for 1 February 1943.

11 Sex

'M' or 'F'

12 Occupational category

A three digit number as shown in Table 2 Annex 1

13 Date of commencement of classified work in this period of employment

In the same format as date of birth. If there is more than one period as a classified person in an employment this date should refer to the current period.

14 Date of termination of classified work in this employment

In the same format as date of birth. Applies only to the last annual return and, if leaving employment, the termination record.

15 Alternative personal identifier

A string of up to eight characters may optionally be provided. Approved dosimetry services may find this identifier more convenient than the national insurance number for their own internal use; however, the latter must always be provided as well.

16 Surname

Omit titles, eg, ‘Mr’, ‘Mrs’ etc. Hyphenated names should be connected by an underscore character (‘ _’) or hyphen. Sixteen characters have been allowed for the surname. In rare cases (estimated to be much less than one in a thousand) this may be insufficient. In these cases the computer record should contain the first 16 characters and CIDI should be notified in writing of the correct surname.

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17 Forenames

Twenty-four characters have been allowed. It is likely that this limit will be exceeded more often than with surnames. In these cases as many as necessary of the later forenames should be abbreviated to initials, eg, ‘GEORGE WILLIAM ARTHUR HENRY’ should be abbreviated to ‘GEORGE WILLIAM ARTHUR H’. Where this may cause problems CIDI should be notified in writing. Some ADSs have obtained the agreement of HSE that full forenames need not be supplied. In these cases the forenames field should contain full initials. However, all ADSs are asked to provide forenames wherever possible.

18 Spare_3

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Table 2, Annex 2 – Format of computer compatible dose record

Item Length Columns

1 Record type 1 1 2 Record counter 1 2 3 Record key 1 3 4 Amendment flag 1 4 5 Period flag 1 5 6 Spare 1 1 6 7 National insurance number 8 7-14 8 Start of dose period 8 15-22 9 End of dose period 8 23-30 10 11 12 13

Dose type 1 Organ or area 1

Dose value 1 Flag 1

4) 4) 6) 4)

31-48

14 15 16 17

Dose type 2 Organ or area 2

Dose value 2 Flag 2

4) 4) 6) 4)

49-66

18 19 20 21

Dose type 3 Organ or area 3

Dose value 3 Flag 3

4) 4) 6) 4)

67-84

22 23 24 25

Dose type 4 Organ or area 4

Dose value 4 Flag 4

4) 4) 6) 4)

85-102

26 27 28 29

Dose type 5 Organ or area 5

Dose value 5 Flag 5

4) 4) 6) 4)

103-120

Notes

1 Record type

E - Entry report.

A - Annual return.

T - Termination record.

2 Record counter

The sequence number for this record in the series. The first dose record will be numbered 2.

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3 Record key

‘D’ for dose.

4 Amendment flag

‘A’, ‘R’ or blank, as on the personal record.

5 Period flag

‘L’ for lifetime doses, ‘Y’ for doses for the current year.

6 Spare_1

7 National insurance number

As on the personal record.

8 Start of dose period

The start of the period over which doses were incurred, eg, 01012000 for 1 January 2000. For lifetime doses, the date of starting work as a classified person or the date on which record keeping started if this is known to be earlier. Note that this date may be earlier, but never later, than that required in the personal record.

9 End of dose period

The end of the period over which doses were incurred, eg, 31122000 for 31 December 2000. On a termination record it is the date of ceasing to be a classified person.

10 Dose type

A number of up to four digits coding the dose type, eg, 1 for penetrating external radiation (see Table 3).

11 Organ or area

A number of up to four digits coding the organ or area of the body irradiated, eg, 1 for the trunk of the body (see Table 4).

12 Dose value

The dose equivalent in millisieverts (rounded to the nearest tenth of a millisievert if the dose estimation was more precise) with a decimal point, e.g. 9999.9. Leading zeros should be omitted. Zero dose should be given as 0.0 and not as a blank. For special entries the dose total including the original entry and excluding the special entry should be shown. If it is not practicable to show this value in the CIDI record details should be specified in an accompanying letter.

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13 Flag

To indicate unusual features of the dose assessment. The following may appear in any order in this field.

‘C’ - dose is, or contains a component of, deemed dose, ie, compliance index multiplied by the dose limit.

‘I’ - dose contains a component of committed dose.

‘L’ - dose contains a component of committed dose from long-lived nuclides.

If ‘L’ is coded, ‘I’ is not needed.

Items 10-13 may be repeated for a further four doses if necessary. If there are more dose types for the same period to be transferred a new CIDI record of exactly the same format should be started. There will usually be at least two sets of dose information, the first containing information about lifetime whole body doses, the second containing information about doses for a year or part of a year. It is requested that, where possible, lifetime doses precede doses for the current year. Note that lifetime doses include the dose in the current year.

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Table 3 Annex 2 – Dose Types

Number Dose Type

1 Effective dose from external radiation plus committed effective dose from internal emitters

2 Notional component of (1) 3 Neutron component of (1) 4 Estimated dose – see Annex 1 Paragraph A 1.7 5 Equivalent dose to an extremity or organ from external radiation plus

committed dose from internal emitters 6 Special entry – see Annex 1 Paragraph A 1.8 7 Not used 8 Not used 20 Committed effective dose from radon

30 Committed effective dose from internal emitters

Table 4 Annex 2 – Organs and Tissues

Number Name

1 Whole body (depth) 2 Whole body (skin) 3 Right hand or forearm 4 Left hand or forearm 5 Head (lens of eye) 6 Thyroid 7 Right foot and ankle 8 Left foot and ankle 9 Lung

10 Bone surfaces 11 Liver 12 Red bone marrow

13 Gonads

Computer compatible annual returns to CIDI

A2.8 An annual return should be produced for everyone who is a classified person for all or part of the year in question. Each annual return normally consists of three computer records, each 120 bytes (characters) long. The first computer record will be a personal record, the second will be a dose record with details of lifetime doses and the third will be a dose record with details of doses for the year in question.

A2.9 The format of computer compatible personal records and dose records given earlier consist entirely of ASCII characters. Fields are not delimited with quotation marks, nor are they separated by commas. A sample set of three annual returns (nine computer records) follows. For clarity a scale has been provided above and below the records to allow the position of fields to be checked.

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A2.10 It can be seen that all records start with a section of the same general form. It consists of 14 characters, as follows.

Record type

One character. ‘A’ on all records for annual returns.

Record counter

One character. ‘1’ on the personal record, ‘2’, ‘3’ on the second and third records.

Record key

One character. ‘P’ for personal records, ‘D’ for dose records.

Amendment flag

One character. Normally blank (see sections above).

Flag

One character (see above).

‘C’ on personal records for individuals continuing as radiation workers.

‘L’ or ‘Y’ on dose records for lifetime or annual dose quantities.

Spare

One character. Blank.

National insurance number

Eight characters. As ‘AB123456’.

A2.11 ADSs which cannot generate the records in the order needed by CIDI can sort their records into the correct order by sorting on record type, national insurance, number and record counter.

A2.12 Note that notional components of dose need only be given if they exceed 10% of the total of the effective dose plus committed effective dose.

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Annual dose summaries

ANNUAL RETURNS

1 1 1

1 2 3 4 5 6 7 8 9 0 1 2

123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890

A1P AA999999 900 9999903061956M10303042000 BROWN ALFRED JOHN

A2D L AA9999990304200031122000 1 1 10.2

A3D Y AA9999990304200031122000 1 1 4.1 4 1 4.1

A1P BB999999 900 9999924061965F23001042000 SMITH JANE MARY

A2D L BB9999990104200031122000 1 1 8.3

A3D Y BB9999990104200031122000 1 1 5.0 5 2 3.2 5 4 3.2 5 3 3.2

A1P CC999999 900 9999903061964M60227032000 WHITE IAN DAVID

A2D L CC9999992703200031122000 1 1 10.4

A3D Y CC9999992703200031122000 1 1 0.5 3 1 0.0 6 1 17.5

The dosimetry service should make sure that annual dose summaries:

(a) are clearly separated and formatted e.g. character data are left justified within a field and numeric data are right justified

(b) show all the information required. This includes flags where classified employment started or ceased in the year, and also start and stop dates for classified work in this employment which are consistent with the corresponding dates used in the registration/termination records

(c) do not include data for persons who ceased classified employment with the present employer in the previous year nor data for others who are not classified; CIDI is intended to be for classified persons only.

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CIDI Termination records

1 1 1

1 2 3 4 5 6 7 8 9 0 1 2

123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890

T1P DD999999 900 9999931051955M1040304199014082000 WILLIAMS DONALD ERIC

T2D L DD9999990304199014082000 1 1 18.8

T3D Y DD9999990101199731121997 1 1 2.1

T4D Y DD9999990101199831121998 1 1 1.0

T5D Y DD9999990101199931121999 1 1 1.1

T6D Y DD9999990101200014082000 1 1 1.4 3 1 0.0 5 5 0.0 5 7 0.0 5 3 0.4

T7D Y DD9999990101200014082000 5 2 1.2 5 4 0.4 5 8 0.0

T1P EE999999 900 9999906061964F1030306198922072000 KENT CATHERINE

T2D L EE9999990306198922072000 1 1 110.0

T3D Y EE9999990101199631121996 1 1 0.9

T4D Y EE9999990101199731121997 1 1 1.0

T5D Y EE9999990101199831121998 1 1 1.2

T6D Y EE9999990101199931121999 1 1 0.0

T7D Y EE9999990101200022072000 1 1 0.2 3 1 0.1 5 2 0.1

T1P FF999999 900 9999907041967M6010304199904082000 WILLIAMS JOHN

T2D L FF9999990304199904082000 1 1 5.0

T3D Y FF9999990304199931121999 1 1 0.0

T4D Y FF9999990101200004082000 1 1 0.2 3 1 0.1 5 2 0.1

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CIDI Registration reports

REGISTRATIONS

1 1 1

1 2 3 4 5 6 7 8 9 0 1 2

123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890

R1P AA999999 900 9999903051956M10303042000 BROWN ALFRED JOHN

R1P BB999999 900 9999924061965F23001042000 SMITH JANE MARY

R1P CC999999 900 9999903061964M60227032000 WHITE IAN DAVID

CIDI Entry reports

ENTRY REPORTS

1 1 1

1 2 3 4 5 6 7 8 9 0 1 2

123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890123456789012345678901234567890

E1P AA999999 800 9999903051956M10303041994 BROWN ALFRED JOHN

E2D L AA9999990310819901032000 1 1 10.0

E3D Y AA9999990101199631121996 1 1 0.1

E4D Y AA9999990101199731121997 1 1 0.2

E5D Y AA9999990101199831121998 1 1 0.3

E6D Y AA9999990101199931121999 1 1 0.4

E7D Y AA9999990101200001032000 1 1 0.0 3 1 0.0 5 2 0.0

E1P BB999999 800 9999924061965F23001042000 SMITH JANE MARY

E2D L BB9999992701199228032000 1 1 3.3

E5D Y BB9999992701199831121998 1 1 0.3

E6D Y BB9999990101199931121999 1 1 1.0

E7D Y BB9999990101200028032000 1 1 0.3 3 1 0.0 5 2 0.0

E1P U CC999999 0 9999903061964M60227032000 WHITE IAN DAVID

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Example of entry report sent to ADS illustrating contents of central index of dose information - entry report record of registration for

ADS xxxx received 14/03/2008

Personal data for the current employment

Customer Number: 99999 National Insurance Number: AA999999 Full Name: BROWN ALFRED JOHN Sex: MALE Date of Birth: 03/06/1956 Date Commenced Classified Work: 03/04/1995 Occupational Category: 03

Details of previous monitoring

Cumulative dose data (mSv)

Previous Ads: 800 Date Monitoring Began: 03/10/1989 Cumulative ED + CED to Date: 10.0

Dose data (mSv) from 4 previous years on CIDI*

ED + CED for 1996: 0.1 ED + CED for 1997: 0.2 ED + CED for 1998: 0.3 ED + CED for 1999: 0.4

Data for current year of dose on CIDI (mSv)

Year: 1995 Date Ceased Classified Work: 01/03/1995 Sum of ED + CED: 0.0 Neutron component of ED: 0.0 Body Skin Dose: 0.0 Address of Previous Ads

*Information provided for purposes of checking and to help ADS where employee is subject to 5-year dose limit (effective from 1/1/2000 or later). Note that summaries of effective dose equivalent for doses assessed prior to 1/1/2000 should be treated as if they were summaries of effective dose.

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References

1. Requirements for the Approval of Dosimetry Services under the Ionising Radiations Regulations 2017: Part 1 External Radiations. RADS 1 HSE. (Revised 2019)

2. Requirements for the Approval of Dosimetry Services under the Ionising Radiations Regulations 2017: Part 2 Internal Radiations. RADS 2 (revised 2019) HSE.

3. Requirements for the Approval of Dosimetry Services under the Ionising Radiations Regulations 1999: Supplement for the Approval for Emergency Exposures during Intervention – The Radiation (Emergency Preparedness and Public Information) regulations 2001

4. Ionising Radiation Protection Series No 2 (IRIS2(rev)) 'Radiation doses - assessment and recording'. HSE.

5. The Ionising Radiations Regulations 2017. Statutory Instrument 2017 No. 1075

6. General Guidance for Laboratories providing personal dosimetry services. RADS/G. HSE.

7. Guidance for Approved Dosimetry Services. Individual monitoring of internal radiation from the prolonged retention of long-lived radionuclides. HSE

8. NRPB-M176 - Reference Manual for Data Transfer to the Central Index of Dose Information, published by the National Radiological Protection Board.

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Appendix 1

Statement of service for co-ordination of dose information and record-keeping

The statement of service submitted on application for approval or at the time of reassessment should contain the following information. References to published information and supporting documents which are not part of this statement will be acceptable provided those references etc contain the necessary information, but dosimetry services should be prepared to provide copies if requested by the Approval Body. Details are not required about aspects of the service which only concern persons who have not been classified under regulation 21 IRR17

General

1. Name and address of the service.

2. An overview of the service showing how it satisfies Criterion 1, including:

a) a brief description of the facilities;

b) the approximate number of personal dose records likely to be held;

c) details of the management systems for ensuring that the administrative arrangements for co-ordination and record-keeping are followed so that the service produces accurate and complete records, is highly reliable, ensures long term security of these records and communicates accurate information as required;

d) the name, qualifications and relevant experience of the person in charge of the service and of their deputy or deputies;

e) details of the training given to new staff about the procedures used for dose recording etc;

f) a description of the types of Approved Dosimetry Services expected to provide dose assessments for inclusion in dose records and the type of data to be supplied with details of names and addresses in referenced supporting documents.

3. A brief explanation of the steps taken to meet the standards in HSE publication ‘General guidance for laboratories providing personal dosimetry services’ (Criterion 2)

Quality assurance (Criterion 3)

4. An overview of the quality assurance procedures for monitoring performance with reference to detailed supporting documents which are not part of this statement. The overview should include information on the standards to which any software has been designed and the procedures for making changes to that software.

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Design and definition of the dose records

5. A clear description of the database, with dummy outputs, that constitutes the formal dose record, showing how the layout of the records makes data comprehensible and input errors unlikely (Criterion 4)

6. How provision is made in the dose records for all of the information in Annex 1 of the criteria (Criterion 5)

7. Details of arrangements for obtaining previous exposure data for classified persons for whom a record is opened (Criteria 6 and 7)

8. Arrangements for receiving, validating and entering dose assessments within 14 days as required by Criterion 8

9. Arrangements for showing dose information in dose records as required by Criterion 9

Late and missing dose assessments

10. Arrangements for dealing with late and missing dose assessments (Criterion 10)

Identification of significant dose levels

11 Routine procedures for identifying individuals specified in Criterion 11

Identification and reporting of exceedance of dose limits

12 Procedures for identifying and notification of exceeding of dose limits in Criterion 12.

Permitted alterations to dose records

13. Procedures for making alterations to dose records permitted by Criterion 13

Storage and security of records

14. Arrangements for ensuring that the conditions in Criterion 14 are satisfied:

a) method of protecting data against accidental loss, destruction, corruption, until age 75 years or at least for 30 years from when made

b) system for ensuring copies of dose records etc are readily available to authorised persons?

c) system secure against unauthorised copying

d) means for ensuring sufficient back-up of recorded data.

e) the method of transferring data to CIDI uses CIDI compatible media

Tracing basic data

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15. The means of identifying basic dose assessment data from contributing ADS (Criterion 15)

Provision of information to the employer

16. Procedures for supplying information to the employer within specified timescales (Criteria 16 and 17)

Provision of information to HSE

17. Procedures for sending annual dose summaries and other information to HSE CIDI Office within the specified timescale under reg 22 IRR17 (Criteria 18 and 19 and Annex 2)

Examples of records

17. Completed examples of the dose record (Criteria 4 and 5), an employer's summary (Criteria 16), and a termination record (Criterion 20) should be included. Dummy data can be used but the intention should be to show how the record will be completed accurately. It is also helpful if the submitted examples include, where appropriate, ‘screenshots’ to illustrate how data is presented to ADS staff.

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Appendix 2

Notional and estimated doses

1. The following advice only relates to classified persons for whom the ADS (Records) is maintaining dose records under the Ionising Radiations Regulations 2017 (IRR17).

2. It is the duty of the employer to ensure that assessments are made of all significant doses. Therefore, it is the employer who must ensure that all dosemeters issued during a dose assessment period are returned to the ADS (Assessment) promptly at the end of that period.

3. Statutory dose records should be compiled using systematic measurements and assessments of doses made by the ADS (Assessment) under Regulation 22 IRR17. The only exceptions to this are provided by Regulation 23(1) of IRR17 in cases where a dosemeter or sample is lost or destroyed, or where the ADS (Assessment) cannot assess the dose received, for example, because the dosemeter has been damaged or a sample has been contaminated. In such cases it is the duty of the employer to make an investigation in conjunction with the Radiation Protection Adviser where appropriate, and either:

(a) estimate the dose and arrange for the ADS (Records) to enter the "estimated dose" in the relevant dose record supplying the ADS with of summary of the information used to estimate that dose; or

(b) exceptionally, where this is not possible, arrange for the ADS (Records) to enter a "notional dose" in the relevant dose record; and

(c) as part of an investigation the employer may ask the ADS (assessment) to measure the dose recorded on a damaged dosemeter or a dosemeter worn for only part of the assessment period. In such a situation the results should be reported to the employer for the purposes of the investigation only; the measurements should not be entered into dose records.

4. If assessments of dose equivalent are required for one hand and the individual wears the dosemeter on the wrong hand for the relevant period the employer must estimate the dose for the correct hand and inform the ADS.

5. In most cases an investigation should not be necessary for routine assessment of dose from intakes provided that the employer can arrange for the individual concerned to provide another sample or present themselves for in-vivo counting (as appropriate). If this cannot be done, or is inappropriate for the type of dose assessment required, the employer will need to take action under Regulation 23 of IRR17.

6. In the past some ADS adopted a practice whereby a "notional dose" was automatically entered into the dose record:

(i) as soon as an individual was issued with a dosemeter; or

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(ii) when an ADS (Assessment) was unable to report a dose for the period because the dosemeter was not returned or a sample was lost.

In both cases the intention was to replace the "notional dose" with an assessed dose if and when this became available. However, there is no provision for either approach in the Regulations.

7. It is recognised that where employers fail repeatedly to return dosemeters or samples, gaps will appear in dose records and this will lead to problems with dose summations; it may cause difficulties for the employer in the effective exercise of dose control. Therefore it is in the employer's interest to resolve this problem.

8. Advice has been given to ADS (Assessment) in Part 1(1) and Part 2(2) about the need for a default procedure for dealing with late, lost, damaged or contaminated dosemeters or samples and the failure of classified persons to present themselves for in-vivo counting when necessary. ADS (Records) needs to have a complementary procedure to deal with entries in dose records in these circumstances. It is recommended that this procedure takes the following form:

(a) Ensure that the procedure for responding to the non-return of dosemeter or the receipt of damaged dosemeters is written into the general terms of the contract between the ADS (Records) and the employer. Charges may need to reflect the cost of dealing with missing dose assessments.

(b) Enter a specific code letter (e.g. "M") rather than a 'dose' in the statutory dose record if the ADS (Assessment) is unable to report an individual's dose for the period concerned. The same code could be added to any dose summation (for example, 2.1 mSv (M) would indicate that in the period, there were measured doses totalling 2.1 mSv, but also at least one dose assessment is missing). This would further alert the employer to the need for action.

(c) As a last resort, write to the employer formally to request an "estimated dose" or to inform him that a "notional dose" will be entered in the record under the general terms of the contract. An example of a suitable letter, appropriate for a non-returned dosemeter or damaged dosemeter, is attached.

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Annex to Appendix 2

Draft Letter

Address of employer ......................................

and Date ..................................

Dear

NON-RETURNED/DAMAGED DOSEMETER (NAME OF CLASSIFIED PERSON)

The Approved Dosimetry Service (ADS) responsible for the assessment of dose for ...................................... (National Insurance No ) has been unable to report a dose assessment for the period ........ to ......... Consequently, we are unable to enter a dose in the dose record for this period.

If the relevant dosemeter is lost, destroyed or so badly damaged that it cannot be read, you should make an investigation of the circumstances under Regulation 22(1) of the Ionising Radiations Regulations 2017 to estimate the dose received by the above-named person and advise us forthwith. Exceptionally, if it is not possible to estimate the dose, you can authorise a "notional dose" to be entered into the record.

Please confirm to us within 10 working days either the estimated dose you wish to be entered into the dose record or that you agree to a notional dose of …. mSv being entered in the dose record.

Yours sincerely

Head of Dosimetry Service