Health Surveillance for Ionising Radiation

Work with ionising radiation that is risk assessed to require formal classification of the individual as a “Classified Person”, as confirmed by the University Radiation Protection Officer (URPO) (and Radiation Protection Adviser (RPA)).

Radiation medical by an HSE appointed doctor as per requirements set out in Regulation 25 Ionising Radiations Regulations 2017:

An employer must ensure that –

(a) each of its employees to whom this regulation relates is under adequate medical surveillance by a relevant doctor for the purpose of determining the fitness of each employee for the work with ionising radiation which that employee is to carry out;

(b) a health record containing the particulars referred to in Schedule 6 is made and maintained in respect of such employees; and

(c) the record or a copy of the record is kept until the person to whom the record relates has or would have attained the age of 75 years but in any event for at least 30 years from the date of the last entry made in it.

The Senior Radiation Protection Advisor (SRPS) will liaise with the URPO to assess the work being undertaken and confirm if the risk or possible dose warrant classification. The URPO will liaise with Occupation Health if required.

If classification is required, University Occupational Health and Safety Office are required to provide a radiation medical. The URPO will liaise with an approved dosimetry service (e.g. UK Health Security Agency (UKHSA) and action the following to comply with Regulation 25(2)(b) Ionising Radiations Regulations 2017:

The following particulars must be contained in a health record made for the purposes of regulation 25(3) (a) the employee’s

(i) full name;

(ii) sex;

(iii) date of birth;

(iv) permanent address; and

(v) National Insurance number;

(b) the date of the employee’s commencement as a classified person in present employment;

(c) the nature of the employee’s employment;

(d) the date and type of the last medical examination or health review carried out in respect of the employee;

(e) a statement by the relevant doctor made as a result of the last medical examination or health review carried out in respect of the employee classifying the employee as fit, fit subject to conditions (which should be specified) or unfit;

(f) in relation to each medical examination and health review, the name and signature of the relevant doctor; (g) the name and address of the approved dosimetry service with whom arrangements have been made for maintaining the dose record in accordance with regulation 22.

After being notified by the URPO or individual concerned, UOHS will consider an appropriate time for a medical examination of the individual.

If confirmed, as a classified person the person will be enrolled into the radiation “Classified Person” Medical surveillance programme.

A periodic review will be conducted on an annual basis at least. The relevant doctor (or employment medical adviser) may specify a shorter period between reviews.

Periodic reviews may also involve an interview with the individual and occasionally a medical examination and test, depending on the nature the work and the individuals state of health.

Ionising radiation | Safety Office (ox.ac.uk)

“Guidance for appointed doctors on the Ionising Radiations Regulations 2017” -MS33(rev1).

The example health record can be found here: HSE f2067 .

A female employee working with ionising radiation should inform their employer (e.g. line manager or RPS) of their pregnancy.

Information concerning the work the individual will do over the remaining term of the pregnancy will form the basis of a review of the radiation risk assessment as required by regulation 9(6) of the Ionising Radiations Regulations 2017, by the University Radiation Protection Officer (URPO) (and Radiation Protection Adviser (RPA)).

The Senior Radiation Protection Advisor (SRPS) will liaise with the URPO to assess the work being undertaken. The URPO will undertake a risk assessment to comply with Regulation 9(6) IRR17, paragraphs 173 - 177ACoP.

If the assessment shows some action is necessary, this may be limited to avoiding work:

(a) with large sources of external radiation where there is a reasonably foreseeable risk that pregnant employees may receive a significant accidental exposure; or

(b) where there is a significant risk from intakes of radionuclides.

If such risks cannot be avoided in line with regulation 9(6) of IRR17, regulation 16 of the Management Regulations requires the employer to:

(a) alter the hours of work of the employee or, where this would not be reasonable;

(b) identify and offer the employee suitable alternative work that is available, or where this is not feasible;

(c) suspend the employee from work on full pay.

The Employment Rights Act

If the individual is not content with their risk assessment outcome with the URPO they may wish to speak to Occupational Health.

UOHS will liaise with the URPO to confirm your activity, if appropriate.

The employer’s action [led by URPO] will include giving advice about the possible risks (i.e. information, instruction and training: regulation 15, IRR17) and altering the employee’s working conditions. The relevant doctor or occupational health service may direct the person to external counselling resources, if appropriate.

Ionising radiation | Safety Office (ox.ac.uk)

“New and expectant mothers who work” INDG373(rev2),

“Working Safely with ionising radiation - guidelines for expectant mothers or breastfeeding mothers” INDG334(rev1),

When an employee returns from maternity leave to work involving unsealed ionising radiation sources and the employer’s assessment shows that bodily contamination is reasonably foreseeable, it is advisable to assume that an employee may be breastfeeding and to take appropriate action, notwithstanding the provision in regulation 9(6) of the Ionising Radiations Regulations 2017.

A further review of the radiation risk assessment may be required by regulation 9(6) of the Ionising Radiations Regulations 2017, by the University Radiation Protection Officer (URPO) (and Radiation Protection Adviser (RPA)).

The Senior Radiation Protection Advisor (SRPS) will liaise with the URPO to assess the work being undertaken. If required, the URPO will undertake a risk assessment to comply with Regulation 9(6) IRR17, paragraphs 173 – 177 ACoP.

If the assessment shows some action is necessary, this may be limited to avoiding work:

(a) [not relevant]

(b) where there is a significant risk from intakes of radionuclides.

If such risks cannot be avoided in line with regulation 9(6) of IRR17, regulation 16 of the Management Regulations requires the employer to:

(a) alter the hours of work of the employee or, where this would not be reasonable;

(b) identify and offer the employee suitable alternative work that is available, or where this is not feasible;

(c) suspend the employee from work on full pay.

The Employment Rights Act 1996 requires that this suspension should be on full pay. Employment rights are enforced through the employment tribunals.

If the individual is not content with their risk assessment outcome with the URPO they may wish to speak to Occupational Health.

UOHS will liaise with the radiation protection officer to confirm your activity.

The employer’s action should include giving advice about the possible risks (i.e. information, instruction and training: regulation 15, IRR17) and altering the employee’s working conditions. The relevant doctor or occupational health service may direct the person to external counselling resources, if appropriate.

Ionising radiation | Safety Office (ox.ac.uk)

“New and expectant mothers who work” INDG373(rev2),

“Working Safely with ionising radiation - guidelines for expectant mothers or breastfeeding mothers” INDG334(rev1),