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Ministry of Defence JSP 392 Radiation Safety Handbook January 2008

Radiation Safety Handbook

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Ministry of Defence

JSP 392 Radiation Safety HandbookJanuary 2008

JSP 392

Radiation Safety Handbook

Intentionally Blank

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Radiation Safety Handbook

JSP 392

PRELIMINARY PAGES Contents Para 1 2 4 4 5 6 Authority Maintenance Record of Changes Channels for Comment File Reference Disclaimer Forward Glossary Volume 1 Chapter Contents Volume 2 Leaflet Contents Comments Form Page

v vii xix xxi xxiii

AUTHORITY 1 JSP 392 is sponsored by the Director of Safety and Claims as Chairman of the Occupational Health and Safety Board (OHSB) and produced and maintained by the Directorate of Safety and Claims (DS&C). It is issued under the authority of the Chairman OHSB. MAINTENANCE 2 This Joint Service Publication (JSP) will be maintained on the Defence Intranet and Internet, and will be revised on an annual basis. Where amendment is necessary, these amendments will be announced by DCI GEN and any changes or additions also published on the Defence Intranet and Internet. All paper copies of JSP 392 material are uncontrolled. 3 Amendments will be developed on behalf of the Directorate of Safety and Claims (DS&C) and staffed through the JSP 392 Review Committee and Functional Safety Boards (FSBs). Major amendments and new inclusions will be submitted for endorsement at the appropriate level. These will be announced by Defence Instructions and Notices under Channel 7 Safety, Health, Environment and Fire. RECORD OF CHANGES

Amendment No 1

Amendment Record DS&C

Affected Pages See table below

Date January 2008

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Amendment No 1

Date Jan 2008

Text Affected Glossary Chapter 1 (paragraph 3) Chapter 2 (3) Chapter 3 (18) Chapter 4 (11, 26) Chapter 5 (3.2,15) Chapter 7 (1) Chapter 8 (8) Chapter 9 (5, 6) Chapter 11 (Annex A) Leaflet 3 (paragraph 14, 40, 43, 46) Leaflet 4 (14-15, 49, Annex B, Annex C) Leaflet 6 (Annex A (24, 40.12)) Leaflet 9 (36, 37, Annex C) Leaflet 10 (14.4) Leaflet 11 (34) Leaflet 13 (2, 3, 5, 6, 22) Leaflet 14 (26, Annex A, Annex B) Leaflet 17 (9) Leaflet 21 (Table 2, Annex B) Leaflet 25 (Annex A (12)) Leaflet 28 (Table 3) Leaflet 30 (All) Leaflet 31 (17) Leaflet 32 (3, 9, 10, 11, 20) Leaflet 39 (13, Annex E) Leaflet 40 (Annex B, Annex C)

NOTE: Minor changes such as typographical errors are not listed. CHANNELS FOR COMMENT 4 Enquiries or proposed changes should be addressed to DS&C at the address below using the comments form or, if considered appropriate, through the Deputy Chief Environment and Safety Officer (Ministry of Defence). [email protected] DSC-OHS5 Directorate of Safety and Claims Occupational Health & Safety and Radiation Protection Team Floor 6, Zone D MOD Main Building Whitehall London, SW1A 2HB FILE REFERENCE 5 File reference DSC-06-10-01 relates to this JSP.

DISCLAIMER 6 Nothing contained within this JSP removes the responsibility of any duty holder to comply with the law and MOD requirements.

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FOREWORD

The purpose of this publication is to enable Ministry of Defence (MOD) units (including Defence Agencies) to comply with legislation relating to radiation protection including environmental protection associated with sources of ionising and non-ionising radiation and the Secretary of States Policy Statement on Safety, Health and Environmental Protection. In overseas commands this publication applies to all personnel, service and civilian. This JSP is divided into two major parts comprising: Volume 1, Radiation Policy, contains both ionising and non-ionising radiation and radioactive substances policy that applies across the MOD. Volume 2, Radiation Instructions and Advice, provides instructions and advice on individual aspects of radiation protection for specific uses. Issues associated with the interpretation or application of the policy in Volume 1 should be brought to the attention of the Directorate of Safety and Claims (DS&C). The contact details are: DSC-OHS5 Directorate of Safety and Claims Occupational Health & Safety and Radiation Protection Team Floor 6, Zone D MOD Main Building Whitehall London, SW1A 2HB email: [email protected] Tel: +44 (0)20 7218 3720 or Military 9621 83720 Requests for advice on the interpretation of the information contained within Volume 2 of this handbook or amendments to Volume 2 of this publication should be addressed to: Head of Dstl Environmental Sciences Department c/o Institute of Naval Medicine Crescent Road Alverstoke Gosport Hants PO12 2DL Tel: +44 (0)2392 768130 or Military 9380 68130

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GLOSSARY Acceptance Test An examination of newly installed medical and dental X-ray equipment to check the specifications and fitness of the equipment for the optimisation of radiation doses to patients. Tuition leading to competence in radiation protection and appropriate instruction, including practical experience, in diagnostic or therapeutic techniques involving ionising radiation as specified in Schedule 2 of the Ionising Radiation (Medical Exposure) Regulations (IRMER) 2000. The largest value of annual intake of a radionuclide by a specific route into the body that will not exceed the annual dose limits either to the whole body or individual organs as given in Schedule 4 of IRR99 for a classified person. A registered medical practitioner who is appointed by the Health and Safety Executive (HSE) under Ionising Radiations Regulations 1999 (IRR99) to carry out the duties described in IRR99. Document issued by the appropriate Regulatory Authority authorising an establishment to accumulate, discharge or dispose of quantities of radioactive material as specified in the approval document. A dosimetry service approved, by certificate in writing, by the HSE

Adequate training (Medical and Dental)

Annual limit of intake (ALI)

Appointed Doctor

Approval Document

Approved Dosimetry Service (ADS) Approved Dosimetry Record Keeping System (ADRKS) Becquerel (Bq) Calendar quarter

The system used by an Approved Dosimetry Service (ADS) for maintaining dosimetry records. The unit of activity, defined as one disintegration per second. Any consecutive 3-month period commencing 1 January, 1 April, 1 July, 1 October. A 12-month period commencing 1 January. Any person or organization undertaking the conveyance of radioactive materials by any means of transport. Chemical, biological, radiological and nuclear. This is a Centralised Index system containing details of dose information for each classified person and identifying them to their Approved Dosimetry Laboratory. It is operated by the Health Protection Agency (HPA) for the HSE. A person designated in accordance with Regulation 20 of IRR99 or in the case of an outside worker employed by an undertaking in Northern Ireland of in another member state, a person who has been designated as a Category A exposed person within the meaning of article 21 of the European Council Directive 96/29/Euratom.

Calendar year Carrier

CBRN Central Index of Dose Information (CIDI)

Classified person

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Closed source

Comforter and carer

A radioactive source from which the dispersal of the radioactive material is minimised by sealing, bonding or other means. This term includes bonded sources, homogeneous sources, laminated sources and sealed sources. An individual who, other than as part of their occupation, knowingly and willingly incurs an exposure to ionising radiation resulting from the support and comfort of another person who is undergoing a medical exposure from an internal or external source. The most senior officer of a ship, unit or establishment. Commanding Officer includes the Commandant, Officer Commanding, Captain, Master, Director, Head of Establishment and Medical Officer-in-Charge. The effective or equivalent dose that will be accrued by the body or a tissue over a 50-year period following the intake of radioactive material. The recipient of transported radioactive material. Any person who sends radioactive materials in any form from a ship, unit or establishment. A document certifying that the contents of a consignment of radioactive materials are properly described by name, are properly packaged, marked and labelled and are in a proper condition for transport according to the applicable transport regulations. The unintended presence of radioactive material on surfaces, areas, personnel (including any surface of the body or clothing) or objects or in gases or liquids. A plan designed to protect persons who may be affected by ionising radiation arising from any foreseeable accident or incident to which the plan relates. An area designated in accordance with Regulation 16 of the IRR99, or in the case of Northern Ireland or in another member state an area subject to special rules for the purposes of protection against ionising radiation and to which access is controlled. An examination of new or structurally modified medical X-ray rooms and dental surgeries to ensure that the installation and any associated safety features and warning devices satisfy the original design criteria and statutory requirements relevant to the restriction of exposure. This is the non-SI unit of activity. One Curie is equal to 3.7 x 1010 becquerels (Bq). This term is officially obsolete, but may still be used in older publications or on some equipment. For any radionuclide, the DAC is that concentration in air which if breathed by a person (reference man) for a working year of 2000 hours (40 hours per week for 50 weeks per year) would result in the person receiving the Annual Limit of Intake by inhalation.

Commanding Officer

Committed dose

Consignee Consignor

Consignor's Certificate

Contamination

Contingency plan

Controlled area

Critical examination

Curie

Derived air concentration (DAC)

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Derived limit

A limit derived from a dose limit or a secondary limit that is intended to prevent the dose limit being exceeded. Such limits include doserates in a work place, airborne contamination limits and surface contamination limits. Defence Nuclear Safety Regulator. A restriction on the prospective dose to individuals, which may result from a defined radiation source. Dose constraints are to be used in the planning stage of radiation protection. Limits of radiation dose to the whole body or individual tissues or organs or extremities of the body in a specified period. These limits are given Schedule 4 of IRR99. The rate at which a person or part of a person would receive a given dose of ionising radiation. A device used for measuring absorbed radiation doses. The measurement of radiation doses. It applies to both the devices used and to the technique. Defence Science and Technology Laboratorys Environmental Sciences Department. An exposure of an employee engaged in an activity associated with the response to a radiation emergency, or potential radiation emergency in order to bring help to endangered persons, prevent exposure of a large number of persons or save a valuable installation of goods, whereby one of the dose limits for a classified person could be exceeded. An employer is whoever employs an employee In the IRMER 2000, an employer is any natural or legal person who has the legal responsibility for a given installation, usually the Chief Executive of the National Health Service (NHS) Trust governing a Ministry of Defence Hospital Unit (MDHU) or single-Service Medical Director General (MDG) for other medical establishments. Includes all Naval, Army, Air Force, and MOD civilian (including Defence Agency) establishments and attachments. An order exempting radioactive substances from all or part of the Radioactive Substances Act. The Order may specify other requirements for those radioactive substances. Ionising radiation originating from outside the body of the person. The appropriate single-Service authority responsible for the oversight of advice and dissemination of radiation protection information. The focal point authority is to be notified of any new sources of ionising and non-ionising radiation. A check carried out using a radioactive source to demonstrate the consistency of response of an instrument before and/or during use.

DNSR Dose constraint

Dose limits

Dose rate

Dosemeter Dosimetry

Dstl ESD

Emergency Exposure

Employer Employer (For Medical/Dental Purposes.) (See Radiation Employer)

Establishments

Exemption Order

External radiation Focal point authority

Functional check

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Gaseous tritium light device (GTLD) Gaseous tritium light source (GTLS) Gray (Gy)

An instrument, piece of equipment, article or sub-assembly containing one or more GTLSs. A sealed glass container filled with gaseous tritium and coated internally with a phosphor. The SI unit of absorbed dose; defined as an energy deposition of 1 J.kg-1 of irradiated material. The senior officer at an establishment. The record of medical surveillance of a classified person kept by the ship or establishment maintained by the employer in accordance with regulation 24(3) of the IRR99 A sealed source (as defined by Directive 96/29/Euratom) containing a radionuclide whose activity at the time of manufacture is equal to or exceeds the activity levels specified in Annex I of EC Directive 2003/122/Euratom i.e. that the activity equals or exceeds 0.01 of the corresponding A1 value given in the IAEA Regulations for the safe transport of radioactive material. The following types of source/radioactive material do not fall within the scope of HASS: a) Any component of a nuclear weapon; b) Any nuclear fuel element; c) Any radioactive substance inside a nuclear reactor; and d) Containers of radioactive material where the radioactive material would not constitute a sealed source in the absence of the container, and the container is for the purpose of storage or transport rather than to ensure the integrity of the source as in ISO 2919:1999. e) Radioactive waste, f) GTLSs and GTLDs A record of radiation protection instrument maintenance, repair and calibration. Ionising radiation coming from inside the body of a person. This is the transfer of energy in the form of particles or electromagnetic waves of the wavelength of 100 nanometres or less or a frequency of 3 x 1015 hertz or more capable or producing ions directly or indirectly. This includes Gamma () rays, X-rays (either from radionuclides, X-ray equipment or produced as a by-product of some other apparatus), alpha () particles, beta () particles and neutrons. The lead equivalent of a shielding material is the thickness of lead affording that same protection as the material in question under the same conditions of irradiation. Ionising radiation that has passed through the protective housing of an X-ray tube, but not through the radiation aperture. Orders adequate to enable the work with ionising radiations at a particular ship, unit or establishment or to be carried out in accordance with statutory and MOD requirements. Rules made in accordance with regulation 17 of IRR99

Head of establishment Health record

High Activity Sealed Source (HASS)

Instrument log

Internal radiation Ionising radiation

Lead equivalent

Leakage radiation

Local orders

Local rules

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Low Specific Activity (LSA)

Low Specific Activity material is defined as radioactive material, which by its nature has a limited specific activity, or a radioactive material for which limits of estimated average specific activity apply. Advice may be sought from the RPA. The exposure of a person to ionising radiation for the purpose of a medical or dental examination or clinical research under the direction of a suitably qualified person. The transfer of radioactive materials within a ship, unit or establishment. This is any electromagnetic radiation that is not ionising radiation. This includes laser radiation, electromagnetic fields and ultra-violet radiation. Values given in Schedule 8 of the IRR99. A notification issued by the appropriate Regulatory Authority specifying the maximum holdings of radioactive material that may be used or stored at an establishment. Nuclear programmes are those to deliver and support the nuclear weapons and nuclear propulsion programmes The radiation exposure received as a result of work undertaken with ionising radiations. Any person who carries out any practical aspect associated with the procedure of a medical or dental exposure including those to whom practical aspects have been delegated, medical physics experts and, except where they do so under the supervision of a person who is adequately trained, persons participating in practical aspects as part of practical training (IRMER 2000) i.e. usually a radiographer or a medical physicist, but may be a medical or dental officer or other adequately trained medical or dental assistant or nurse. In the use of ionising radiation associated with veterinary examinations it is the person controlling the veterinary examination. Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) 2001, defines an operator as the person in control of the operation of premises.

Medical exposure

Movement

Non-ionising radiation

Notifiable quantities Notification (EA)

Nuclear programmes

Occupational Exposure

Operator

Outside worker

A classified person who carries out services in the controlled area of any employer, other than the controlled area of his own employer. The exposure of any person to ionising radiations to an extent that a dose limit is exceeded. An overpack is an enclosure, such as a bag or box, used by a single consignor to consolidate into one unit a consignment of two or more packages for the convenience of handling stowage and carriage. A document giving formal approval for and stating conditions under which persons specified in the document may work in a controlled area. An Individuals record of their exposure.

Overexposure

Overpack

Permit-to-work

Personal dose records

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Personal dosimetry number (PD)

A unique identifying number allocated by the Dstl Environmental Sciences Department (Dstl ESD) Approved Dosimetry Record Keeping Service to each person entered on the Approved Dosimetry Record Keeping System (ADRKS). The term that includes both protective clothing and breathing apparatus. A registered medical or dental practitioner, or other health professional who is entitled to take responsibility for an individual medical exposure (IRMER 2000) i.e. usually a radiologist, but may be the senior medical or dental officer. Before the commencement of a new activity involving work with ionising radiation a suitable and sufficient assessment of the risk to the employee or other person should be made. This assessment should identify the measures required to restrict the exposure of the employee or other person. Where the risk exists from a reasonably foreseeable accident, the employer, should prevent, or with the use of a contingency plan, limit the consequences of such an accident, and provide employees with appropriate information, instruction and training to restrict any exposure. Clothing provided to prevent the contamination of the person or the person's clothing or the lead rubber apparel worn when required during X-ray diagnostic procedures. A location not controlled by the employer (Commanding Offier) i.e. on the outside of the site boundary, or on a public right of way through the site. A person appointed by the employer having the necessary expertise, training and experience in instrumentation theory and practice to undertake or to supervise the examination and testing of radiation monitoring instruments to meet the requirements of the IRR99. An accident where immediate action is required to prevent or reduce the exposure to ionising radiation of employees or any other persons and includes a radiation emergency. A card issued to persons working away from their parent establishment containing relevant personal details and a summary of their radiation dose. Any event which is likely to result in any member of the public being exposed to ionising radiation arising from that event in excess of 5mSv effective dose in the one year period immediately following the radiation emergency. Any dose averted by any health protection measure taken during the 24 hours immediately following the event shall be disregarded. An employer who in the course of a trade, business or other undertaking carries out work with ionising radiation. Any apparatus that accelerates charged particles using a potential greater than 5 kV. Cathode-ray tubes and visual display units that do not produce a dose-rate of more than 5 Sv h-1 at a distance of more than 50 mm from any accessible surface are excluded.

Personal protective equipment

Practitioner

Prior risk assessment

Protective clothing

Public places

Qualified person

Radiation accident

Radiation dose summary card

Radiation emergency

Radiation employer

Radiation generator

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Radiation passbook

Radiation Protection Adviser (RPA)

Document issued by an ADS to record the estimated dose information for an outside worker working in a controlled area of another employer. A person or corporate body appointed by the employer to advise him on the observance of the IRR99 and on other health and safety matters in connection with ionising radiations. The individual or body must meet such criteria of competence as may from time to time be specified in writing by the HSE. A person appointed in writing by the Commanding Officer in respect of a particular process or processes to ensure that work is carried out in compliance with IRR99. An assessment prior to the introduction of new equipment, Installations or working practices, to identify the nature and magnitude of the radiation hazard likely to arise during normal operating conditions and in the event of any foreseeable accident or incident. An officer appointed by the Commanding Officer for the purpose of administering his responsibilities under these instructions. Orders produced by the ship, unit or establishment containing the information for the management of radiological protection. A measure of the risk of late effects, principally cancer, caused by the type of radiation under consideration relative to X or gamma irradiation of a specified energy. Includes closed sources, articles containing radioactive substances, unsealed radioactive substances and non-radioactive articles contaminated with radioactive substances.

Radiation Protection Supervisor (RPS)

Radiation Safety Assessment

Radiation Safety Officer (RSO)

Radiation Safety Standing Orders (RSSOs) Radiation weighting factor

Radioactive material

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Radioactive Substance

There are three definitions for a substance that must be regarded as Radioactive for the purposes of radiation protection, dependent upon which regulations are applicable: a. IRR99: Any substance which contains one or more radionuclides whose activity cannot be disregarded for the purposes of radiation protection. b. The Radioactive Substances Act 1993 (RSA93): i) a beta and/or gamma emitting solid radioactive material, whose activity exceeds 0.4 Bq g-1. ii) a substance that has become radioactive through bombardment by neutrons or ionising radiations. For other materials seek the advice of the Radiation Protection Adviser. c. The Transport Regulations. Radioactive material shall mean any radioactive material containing radionuclides where both the activity concentration and the total activity in the consignment exceed the values in columns 4 and 5 of Table 1 of the IAEA Safety Standards Regulations for the Safe Transport of Radioactive Material, 1996 Edition, Revised. (TS-R-1) (Units and establishments should seek advice from their Radiation Protection Adviser or their Dangerous Goods Safety Adviser.)

Radioactive waste

This is defined in RSA93 as waste which consists wholly or partly of: a. a substance or article which, if it were not waste would be radioactive material, or b. a substance or article which has been contaminated in the course of the production, keeping or use of radioactive material, or by contact with or proximity to other waste falling within paragraph a. Radioactive material will be considered to be waste when designated by a ship, unit or establishment

Radionuclide

A radioactive species of atom characterised by its mass number, atomic number and nuclear energy state. A registered dental or medical practitioner, or other health professional who is entitled to refer individuals for medical exposure to a practitioner (Ionising Radiation (Medical Exposure) Regulations 2000) i.e. usually a General Practitioner (GP) or General Dental Practioner (GDP), hospital doctor or dental surgeon or nurse practitioner.

Referrer

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Regulatory Authority

Authority responsible for the issue of Notifications for keeping and using radioactive materials and the issue of Approval documents for disposal of radioactive material. The Regulatory Authorities are as follows: a. Environment Agency (EA) in England and Wales. b. Scottish Environmental Protection Agency (SEPA) in Scotland. c. Environment and Heritage Service (EHS) in Northern Ireland.

Respiratory Protective Equipment (RPE) Risk Assessment

Equipment designed for protection of the individual against the hazards of airborne contamination. Carried out to identify risks to health and safety to any person arising out of, or in connection with, work or the conduct of their undertaking. It should identify how the risks arise and how they impact those affected. This information is then used to aid decisions on how to manage those risks. A source containing any radioactive substance whose structure is such to prevent, under normal conditions of use, any dispersion of radioactive substances into the environment. Note. For the purposes of IRR 99 only, this definition is qualified to specifically exclude any radioactive substance inside a nuclear reactor or any nuclear fuel element. The SI unit of equivalent dose; defined as the product of the absorbed dose (in Gy) and the radiation weighting factor. It provides an indication of risk to health, principally of cancer, in humans. Any industrial radiography undertaken outside an enclosure. Radioactive material that is in the form of an indispersible solid or in a sealed capsule so constructed that it can only be opened by destroying the capsule. An area designated by the employer in accordance with regulation 16 of IRR99. Procedures designed to restrict the radiation dose to workers and other persons to as low as reasonably practicable. A record of the personal radiation dose of a previously classified person which is produced by the ADS when they cease to work for the Ministry of Defence or its Agencies. A device containing thermoluminescent material used to measure dose from ionising radiations. Persons aged 16 years and over (including students) who are undergoing training or instruction which involves operations which would, in the case of an employee, be work with ionising radiation. The transfer of radioactive materials from a ship, unit or establishment

Sealed source

Sievert (Sv)

Site radiography Special form

Supervised area

Systems of work Termination record

Thermoluminescent dosemeter (TLD) Trainees

Transport

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TREMCARD

Transport Emergency Card (TREMCARD) containing instructions for drivers carrying radioactive material abroad between European countries, the instructions for drivers are required in the language of the driver of the vehicle and the languages of the countries of transit and destination. Transport Emergency Cards (TREMCARD) detailing the required instructions are available in different languages. TREMCARDS can also be used for movements within the UK. A package that is permitted to contain up to the relevant A1 or A2 activity limit for any given isotope. Type A packages are designed to prevent the loss or dispersal of the radioactive package contents and prevent any increase in the maximum radiation level recorded at the external surface of the package during normal conditions of transport. A radiation worker who is unlikely to exceed three-tenths of the annual dose limits for classified persons Any radioactive substance that is not a closed source. It includes non-radioactive objects contaminated with radioactive substances. Depleted uranium: Uranium containing less than 0.72% U-235 by weight. Natural uranium: Uranium containing the naturally occurring distribution of uranium isotopes (approximately 99.28% uranium-238 and 0.72% uranium-235 by weight). The X-rays that come from the target and emerge through the aperture of an X-ray tube. Persons who enter radiation areas other than for purposes of undertaking work. Units used to indicate the level of exposure to radon daughters in air. One working level (1WL) = 2.08 x 10-5 J m-3. An exposure of one working level month (WLM) would be received by working in a radon daughter concentration of one working level for 170 hours (i.e. a typical working month). Any task entailing the production, processing, handling, use, holding, storage, moving, transport or disposal of any radioactive substance, or entailing the operation or use of any radiation emitting machine or apparatus, including instruction or training in which a person is engaged in as a trainee. This also includes work carried out in an atmosphere containing radon 222 gas at a concentration in air, averaged over any 24 hour period, exceeding 400 Bqm-3 , except where the concentration of short-lived daughter products does not exceed 6.24 x 10-7 Jm-3. A measure of the amount of use of X-ray equipment in a specific period, expressed in units of milli-amp minutes (mA min).

Type A package

Unclassified radiation worker

Unsealed radioactive substance Uranium

Useful beam

Visitors

Working Level (WL)

Working Level Month (WLM)

Work with ionising radiations

Workload

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Workplace Supervisor (WPS)

Workplace supervisors are appointed where it is unnecessary to appoint an RPS, to undertake duties to ensure that work with sources of ionising radiation is carried out in accordance with legislation, the requirements of this publication and local orders for radiation safety. WPSs may be appointed to supervise radioactive materials, X-ray equipments or radon that do not require the setting up of designated areas, or a combination of these activities.

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VOLUME 1 CHAPTER CONTENTS

Chapter 1 Chapter 2 Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11

Scope, application and availability Radiological protection and MOD policy Ionising radiation protection policy Radioactive substances control policy Radioactive waste Non-ionising radiation protection policy Radiation protection committees Radiation protection appointments Training and qualifications in radiological protection Radiation dose control Record keeping

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VOLUME 2 LEAFLET CONTENTS

Leaflet 1 Leaflet 2 Leaflet 3

Acquisition of sources of ionising radiation by IPTs Risk assessments Notification, approval and assessment of the introduction and use of sources of ionising radiation including radioactive substances Restriction of exposure to radiation Written arrangements for unclassified persons entering controlled areas Dosimetry and personal dose records including medical surveillance of classified persons Radiation protection adviser consultation and advisory visits Radiation detection and monitoring equipment Storage, accounting and leak testing of radioactive material Movement and transport of radioactive materials Requirements for the transfer (including the return to stores) sale, loan and gifting of radioactive materials and radioactively contaminated items Accumulation and disposal of radioactive waste Assessment and management of radioactively contaminated land Investigation, notification and reporting of unusual radiation events Training requirements and courses Local orders for radiation safety Radioactive electronic valves Smoke detectors containing Americium 241 Gaseous tritium light sources (GTLSs) and gaseous tritium light devices (GTLDs) Instruments containing Ni-63 Instrument check sources Luminised equipment High voltage electrical equipment Postal and baggage fluoroscopes Dental x-ray machines Medical diagnostic X-ray machines

Leaflet 4 Leaflet 5 Leaflet 6 Leaflet 7 Leaflet 8 Leaflet 9 Leaflet 10 Leaflet 11

Leaflet 12 Leaflet 13 Leaflet 14 Leaflet 15 Leaflet 16 Leaflet 17 Leaflet 18 Leaflet 19 Leaflet 20 Leaflet 21 Leaflet 22 Leaflet 23 Leaflet 24 Leaflet 25 Leaflet 26

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Leaflet 27 Leaflet 28 Leaflet 29 Leaflet 30 Leaflet 31 Leaflet 32 Leaflet 33 Leaflet 34 Leaflet 35 Leaflet 36 Leaflet 37 Leaflet 38 Leaflet 39 Leaflet 40

Veterinary diagnostic X-ray machines Industrial radiography including enclosures, site and underwater radiography Items and components containing thorium Depleted uranium Museums Protection against radon Exposure to cosmic radiation Laser safety Radiofrequency radiations Microwave ovens Ultraviolet radiation Classified persons and outside workers Radiation safety duties of MOD employees Contingency plans

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COMMENTS FORM DSC-OHS5 Directorate of Safety and Claims Occupational Health & Safety and Radiation Protection Team Floor 6, Zone D MOD Main Building MOD Main Building Whitehall London SW1A 2HB Email: [email protected] File: D/DSC-06-10-01 Senders Reference: To: From:

UIN:

Date:

Chapter/Annex

Page/Paragraph:

Comment:

Name: email Address: Signed:

Telephone No. Rank/Grade: Date:

Thank you for commenting on JSP 392

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CHAPTER 1 SCOPE, APPLICATION AND AVAILABILITY Contents Para 1 4 9 Scope Structure and Application Availability

SCOPE 1 This publication sets down the policy, instructions and guidance for peacetime ionising and nonionising radiation protection. It applies to MOD ships, units and establishments both in the United Kingdom and overseas. In times of war other standards may apply. In situations other than peace or war i.e. transitions between the two, the provisions in this publication should be applied as far as is reasonable practicable, or as defined in operational guidance. 2 Regulation of the Naval Nuclear Propulsion Programme is described in JSP 518 and the regulation of the Nuclear Weapons Programme is described in JSP 538. Similarly the policy for nuclear accident response is laid down in JSP 471, MOD Nuclear Accident Response. JSP 392 is called up by these publications. 3 The Transport of Dangerous Goods by Road, Rail and Sea including radioactive materials (Class 7) is contained in JSP 800 part 4b and Dangerous Air Cargo Regulations are contained in JSP 800 Part 4a. STRUCTURE AND APPLICATION 4 The policy, instruction and guidance for radiation protection are part of MODs arrangements for the management of health, safety, and environment matters. The overarching health and safety document is JSP 815 Defence Environment and Safety Management. 5 JSP 375, the Ministry of Defence Health and Safety Handbook provides instruction and guidance on health and safety matters. JSP 418 The MOD Sustainable Development and Environment Manual sets out MOD policy and provides some practical guidance on the protection of the environment in the Ministry of Defence. JSP 392 complements these publications. 6 JSP 392 is divided into two distinct volumes. Volume 1 contains radiation protection policy, which is applicable throughout the MOD and to its agencies. Reference is made in this volume to the Ionising Radiations Regulations 1999 (IRR99) which is available on the World Wide Web at http://www.opsi.gov.uk/si/si1999/19993232.htm and the Approved Code of Practice (ACOP) which may need to be purchased, See http://www.hse.gov.uk/radiation/ 7 Volume 2 of the publication contains instructions and guidance for units (including ships) and establishments throughout the MOD. This is directed at employers, Radiation Safety Officers (RSO), Radiation Protection Supervisors (RPS) and users of radioactive material. This volume of the publication has been written primarily for the small user. 8 This JSP in its entirety should not be referenced in contracts documents. However, specific requirements in this document may be detailed in a contract specification. Commercial Officers should discuss with the subject matter expert in the appropriate TLB the information that they intend to include.

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AVAILABILITY 9 This JSP must be made readily accessible to line managers, radiation protection appointees and employees who wish to see it. 10 The document is available on the Defence Intranet and World Wide Web.

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CHAPTER 2 RADIOLOGICAL PROTECTION AND MOD POLICY Contents Para 1 3 5 Introduction MOD Policy Roles and Responsibilities

INTRODUCTION 1 Radiological protection is a broad term that is generally taken to encompass the protection of man and the environment from the effects of both ionising and non-ionising radiation. Those effects may arise from work activity, natural sources, redundant material, waste or legacy material. 2 In radiological protection, a distinct division can be made between radiological protection for ionising and non-ionising radiations. The two main aspects of radiological protection are health and safety matters and environmental protection; they are interrelated and both are relevant to nuclear safety. MOD POLICY 3 Both the health and safety and the environmental protection, including assurance, aspects of radiological protection must be considered and managed within the overall framework of MODs policy for those areas. This is set out in detail (together with guidance material) in: JSP 815 the Defence Environment and Safety Management, where you can find: 4 The Policy Statement by the Secretary of State for Defence. Descriptions of MODs Boards etc dealing with environment, safety and health. Interface arrangements between MOD and other organisations. Information on the high-level structures for safety, health, environment and fire matters with Service and defence organisations.

JSP 375 the MOD Health and Safety Handbook. JSP 418 the MOD Sustainable Development and Environment Manual. Briefly, it is the policy of the Secretary of State for Defence that: Within the United Kingdom, MOD will comply with all relevant applicable legislation (including legislation giving effect to the UK's international obligations). Overseas, MOD will apply UK standards where reasonably practicable, and in addition comply with relevant host nations' standards. Where MOD has been granted specific exemptions, disapplications or derogations from legislation, international treaties or protocols, we will introduce standards and management arrangements that are, so far as reasonably practicable, at least as good as those required by legislation.

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The Secretary of State for Defence will invoke the powers to disapply legislation only on the grounds of national security and only when such action is essential to maintain operational capability. Where there is no relevant legislation, internal standards MOD will aim to optimise the balance between risks and benefits.

ROLES AND RESPONSIBILITIES 5 The Secretary of State for Defence has overall responsibility for all safety and environmental matters within MOD. In the policy statement the Secretary of State delegates the task of discharging the Secretary of States personal responsibilities through the line management chain to the heads of management areas at all levels, down to Heads of Establishments, Directors and Commanding Officers. Line managers at lower levels will also have duties under legislation, as will individuals (see JSP 375 and JSP 418 for the full explanations). 6 It is therefore often the case that Heads of Establishments, Directors and Commanding Officers discharge the duties of the employer under the Health and Safety at Work Act 1974 or other similar roles. However, their ability to do so must necessarily be influenced by the resources allocated to them by those higher in the chain of delegation and their options may be limited by the instructions or policy of higher management.

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CHAPTER 3 IONISING RADIATION PROTECTION POLICY Contents Para 1 2 10 11 12 13 14 16 17 18 Principles of Radiological Protection Legislation Nuclear Safety Compensation Scheme for Radiation Linked Diseases Radiation Worker Counselling Dosimetry Radiation Dose Information Radiation Monitoring Equipment Radon Monitoring Radiation Warning Label

PRINCIPLES OF RADIOLOGICAL PROTECTION 1 For ionising radiation, the main principles of radiation protection are formulated by the International Commission on Radiation Protection (ICRP) who publish recommendations. ICRP also produce a great deal of practical information. Other aspects of radiation protection derive from other bodies, e.g. the International Atomic Energy Agency (IAEA) and environmental forums. Governmental bodies etc may act upon the ICRPs recommendations, IAEA Conventions etc to produce legislation and other means of implementing a regime of radiological protection. Where appropriate, this could form the basis of MOD policy, e.g. in the absence of applicable legislation. LEGISLATION 2 The main UK statutes and subordinate legislation of interest to MOD in radiological protection for ionising radiation are: Health and Safety at Work Act 1974 Ionising Radiations Regulations 1999 Radiation (Emergency Preparedness and Public Information) Regulations 2001 Ionising Radiations (Medical Exposures) Regulations 2000 Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2007

Radioactive Substances Act 1993 (RSA93) Exemption Orders

European Communities Act 1972 High Activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 that amend RSA93 Justification of Practices Involving Ionising Radiation Regulations 2004

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3 Equivalent legislation may exist for the Devolved Administrations and UK overseas territories and dependencies. 4 The legislation varies in its application to MOD and defence activities and there are many other regulations etc on radiological protection. 5 Legislation is supported by a variety of publications, from statutory guidance and Approved Codes of Practice through Government, non departmental public bodies and agency advisory material to material from industry groups, e.g. Good practice guidance for the management of contaminated land on nuclear and defence sites, published by Safegrounds (an industry group), and Clearance and Exemption Principles, Processes and Practices for Use by the Nuclear Industry. 6 Given MODs peculiar position under legislation as opposed to operators in the civil sector it should be borne in mind that it is S of Ss policy to comply with legislation or to introduce standards and management arrangements that are, so far as reasonably practicable, at least as good. 7 The Health and Safety at Work Act 1974 and its subordinate legislation generally applies to MOD.

8 The Radioactive Substances Act 1993 (RSA93) contains a disapplication in respect of certain defence sites. However, it is MODs policy for the enforcing agencies to be provided with information as if the law applied and for them to issue approvals similar to those in the civil sector and to levy the same charges. MOD has negotiated MoUs with the agencies that enforce RSA93 that define how those agencies will fulfil their national responsibility to oversee the safe keeping and disposal of radioactive material in the MOD. 9 The Justification of Practices Involving Ionising Radiation Regulations 2004 do not apply to defence activities. If they did, they would have little impact until an entirely new practice was conceived. At present, most of MODs practices appear in the list of existing practices that was issued at the same time as the regulations and is updated as new civil practices are authorised. There are some practices that are particular to MOD, such as the nuclear weapon and propulsion programmes. NUCLEAR SAFETY 10 Nuclear safety is closely related to radiological protection and the latter can have a major impact. The Nuclear Installations Act 1965 (NIA65) does not bind the Crown (other than a single provision on damage and liability) and so the Secretary of State for Defence has appointed an internal regulator (DNSR, the Defence Nuclear Safety Regulator) in this area. DNSR sponsors JSP 518 Regulation of the Naval Nuclear Propulsion Programme and JSP 538 Regulation of the Nuclear Weapon Programme. However, the major defence nuclear contractors are covered by NIA65 which is enforced by the Nuclear Installations Inspectorate (NII) of the Health and Safety Executive (HSE). COMPENSATION SCHEME FOR RADIATION LINKED DISEASES 11 MOD is a member of the Compensation Scheme for Radiation Linked Diseases (the Scheme). Using the Scheme, it is less arduous for the claimant, than going to law, to determine whether compensation should be paid in relation to MOD radiation workers (or their surviving dependants) who develop certain types of cancer or cataracts (which may be linked with exposure to ionising radiation at work). However, an application to the Scheme, whether or not a payment is made, does not prevent those persons seeking redress in law. Detailed information about the Compensation Scheme is in Volume 2. RADIATION WORKER COUNSELLING 12 In response to a recommendation of the House of Commons Defence Committee (HCDC 12th report Radiological Protection of Service and Civilian Personnel), MOD offers counselling to radiation workers, former radiation workers and their families. The counselling provides an opportunity to discuss concerns with someone medically qualified to give advice. It does not involve any medical examination, or any form of medical surveillance or screening. Detailed information about the counselling scheme is in Volume 2.

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DOSIMETRY 13 There are statutory requirements for employees to be subject to radiation dose monitoring (dosimetry). A service for this is generally available from Approved Dosimetry Service (ADS) run by Dstl EDS at Alverstoke. Should any user wish to cease using the Dstl ADS then this must be agreed by the appropriate TLB and the Chief Environment and Safety Officer (MOD). Some sites may already be using their own or other dosimetry services. RADIATION DOSE INFORMATION 14 MOD contributes anonomised radiation worker radiation dose statistics to the Health Protection Agencys for their periodic review of the ionising radiation exposure of the UK population. 15 The National Registry of Radiation Workers (NRRW) is a database containing data on radiation workers and their associated radiation exposure. Its purpose is to allow rates of cancer and other causes of death of radiation workers to be compared with those within the UK for each disease and tested against the level of radiation exposure to see if any relationship exists. The Ministry of Defence has been a major contributor since 1980. RADIATION MONITORING EQUIPMENT 16 The Marine Environment, Survivability & Habitability IPT (MESH IPT) in DE&S has a MOD-wide responsibility for chemical, biological, radiological and nuclear equipment (particularly monitoring equipment). They sponsor JSP 425 Examination and Testing of Ionising Radiation Monitoring (Including Protection) Instruments that gives the MOD policy for the calibration of MOD radiation monitoring (including protection) instruments. RADON MONITORING 17 Top Level Budget holders (TLBs), in conjunction with the RPA, are periodically to review the need for radon monitoring at sites and married quarters within their area of responsibility. National surveys have identified Radon Affected Areas (RAAs) where naturally occurring radon concentrations are highest. So far, RAAs are in Cornwall, Devon, Derbyshire, Northamptonshire, Somerset, parts of Grampian and the Highlands of Scotland, together with the southern parts of County Armagh and County Down in Northern Ireland, but the identification process continues. RADIATION WARNING LABEL 18 Within MOD there are a small number of radioactive sources, which if removed from their shielded containers, have the potential, from a short exposure, to cause serious injury, or even death. Such sources are those used in industrial radiography, radiation hardening examinations and in high exposure radiation instrument testing. The International Atomic Energy Agency has developed a universal radiation warning symbol with the message of "Danger-Stay Away" that anyone anywhere will understand. This is shown in Leaflet 4 Annex B. The new radiation warning symbol will supplement, not replace, the existing trefoil symbol. 19 In MOD establishments using such radioactive sources the warning symbol is to be placed on the device housing the source, as a warning not to dismantle the device or to get any closer. Where practical, it should be placed under the device cover such that it is not visible under normal use but would be visible if anyone attempts to disassemble the device. The symbol is not intended for doors, walls or shipping containers. 20 For new equipments the label should be included as part of the purchasing process. At establishments holding these sources the radiation warning symbol should be added during the maintenance period. Such small radiation warning labels would need to procured from a supplier of signs or manufactured by units in their local workshops.

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CHAPTER 4 RADIOACTIVE SUBSTANCES CONTROL POLICY Contents Para 1 7 8 9 11 14 15 16 17 18 19 23 25 27 28 29 30 31 34 General Parallel Arrangements in MOD RSA93 Parallel Arrangements in England and Wales Keeping and Use of Radioactive Substances EA Inspections MOD Database of Radioactive Materials Audits and RPA Advisory Visits MOD Safety and Environment Boards, Committees and Working Group Structure RSA93 Parallel Arrangements in Scotland RSA93 Parallel Arrangements in Northern Ireland Application of RSA93 to Contractors and Museums HASSR 2005 Parallel Arrangements Procurement and Use of Radioactive Materials Use of Radioactive Material Consultation with an RPA Prior to the Introduction of New Equipment Disposal of Redundant or Surplus Radioactive Materials Accounting and Transfer of Radioactive Material Records and Accountancy Transfer of Radioactive Articles Disposal of Radioactive Items by Sale or Donation Disposal of Ships

GENERAL 1 The Radioactive Substances Act 1993 (RSA93) is the main legislation covering the control of radioactive substances in the United Kingdom. The Act does not apply to premises occupied on behalf of the Crown for Naval, Military or Air Force purposes. However, MOD policy is to implement parallel arrangements to those required by the Act. 2 Practices involving certain high level sealed radioactive sources are subject to additional control measures under the High Activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASSR 05). MOD policy is to implement parallel arrangements, as these Regulations do not apply to MOD premises. 3 Certain aspects of the control of radioactive substances on nuclear licensed sites are regulated under the Nuclear Installations Act 1965 (NIA 65). Licensing under this Act is not applicable to the Crown and, on MOD nuclear sites, parallel standards are applied through authorisation conditions by the Defence Nuclear Safety Regulator (DNSR) internal nuclear regulators as described in JSP 518. 4 NIA 65, RSA 93 and HASSR 05, as appropriate, are applied at MOD contractor operated sites such as the nuclear licensed site at Devonport. 5 A number of arrangements for the control and accounting for radioactive substances, articles and equipment are embodied in the Ionising Radiation Regulations 1999 (IRR99) which are made under the Health and Safety at Work Act 1974 (HASAWA 74) and apply directly to the MOD in Great Britain. Application of the HSWA and its regulation by the HSE is described in JSP 375. In Northern Ireland, the applicable legislation is the Ionising Radiations Regulations (Northern Ireland) 2000.

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6 As stated in JSP 375, standards adopted in overseas Commands should, as far as is reasonably practicable, be no less stringent than those applying in the United Kingdom, subject to the discretion of local commanders and taking cognisance of local statutory requirements. PARALLEL ARRANGEMENTS IN MOD 7 The policy on the application of parallel arrangements under RSA93 and HASS 05 with respect to radioactive substance control is described below. The parallel arrangements apply across MOD with the exception of MODs nuclear authorised sites where the control of non-mobile radioactive substances is regulated by DNSR. Detailed instructions on the arrangements are contained in Volume 2. RSA93 Parallel Arrangements in England and Wales 8 A Memorandum of Understanding between MOD and the EA formalises an agreement whereby the EA carry out a number of quasi regulatory functions which together with additional measures within MOD are intended to satisfy the Secretary of States requirement that standards are, as far as is reasonably practicable, at least as good as those required by legislation. The main features administered by the EA are summarised below: Keeping and Use of Radioactive Substances 9 To parallel the registration requirements of Sections 7 and 10 of RSA93, EA issues a Certificate of Notification to MOD users, which is equivalent to the Certificate of Registration required by civil users. 10 The Certificate of Notification carries terms and conditions for that certificate. The standard terms and conditions for MOD sites have been agreed centrally and compliance is a MOD mandatory requirement. EA Inspections 11 EA are authorised by MOD to carry out inspections of premises where radioactive materials are held. These inspections will be carried out by arrangement with CO/HE. EA will bring to the attention of CO/HEs any areas of non-compliance. The CO/HE should inform DS&C of the outcome of any EA inspection. 12 Inspections carried out by EA do not include any remit to review MODs security arrangements.

13 A number of measures carried out and administered internally within the MOD are necessary to complete the parallel arrangements to satisfy SoS policy. They are: MOD Database of Radioactive Materials 14 A database of MOD radioactive materials is maintained to support the notification process.

Audits and RPA Advisory Visits 15 Audits are carried out at every level in MOD. Appropriate audits at each level are to include the control of radioactive substances. Dstl carry out RPA advisory visits across the MOD other than nuclear weapons and nuclear propulsion programmes areas. The advice provided is extended to include advice on RSA93 matters. Generic findings of the RPA are forwarded to the policy branch of MOD for scrutiny and development of policy where appropriate. MOD Safety and Environment Boards, Committees and Working Group Structure 16 Compliance with the parallel arrangements laid down in JSP 392 is monitored through the Defence Environment and Safety Board structure.

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RSA93 Parallel Arrangements in Scotland 17 [A Memorandum of Understanding between MOD and the SEPA yet to be agreed summary here as for EA depending on any differences.] RSA93 Parallel Arrangements in Northern Ireland 18 [Summary as above when MOU in place.]

Application of RSA93 to Contractors and Museums 19 Where contractors and museums operate on premises within MOD managed sites, disapplication of RSA93 is appropriate provided that: 19.1 The premises are occupied on behalf of the Crown for MOD purposes and

19.2 MOD arrangements for equivalent/parallel standards and management arrangements are applied through contractual or written agreements 20 Disapplication of RSA93 should be considered on a case by case basis and involve, as a minimum, consultation with the RPA and the external environmental regulator. Reference should also be made to the relevant Memorandum of Understanding with the external environment agency. 21 In cases where there is doubt as to whether the conditions of Para 12 are met, DS&C should also be consulted. Where contractor or museum premises are not on an MOD managed site, then, the case for disapplication is to include a detailed statement as to how the conditions of Para 12 are to be met. 22 General guidance on the management of contractors is contained in JSP 375 Volume 2.

HASSR 2005 Parallel Arrangements 23 For non-nuclear MOD sites, arrangements for Notification of the Environment Agencies described under RSA93 above have been extended to encompass the additional requirements for HASS. The main features which extend or differ from the RSA93 parallel arrangements are: 23.1 An application for a HASS Notification is to be made by the prospective holder direct to the relevant environment agency. The practice, which utilises the HASS, may not commence until the Certificate of Notification has been received from the relevant environment agency. 23.2 Arrangements for the physical security of HASS are, so far as reasonably practicable, to parallel those operative on civil sites. Advice on physical security should be sought through the Principal Security Adviser of the TLB concerned. 24 The regime for the control of HASS held by MOD nuclear authorisees mirrors that appertaining to civil nuclear licensees and is administered by the DNSR. This regime does not extend to mobile HASS held by authorisees, where the standard parallel arrangements for HASS apply. PROCUREMENT AND USE OF RADIOACTIVE MATERIALS Use of Radioactive Material 25 Radioactive material is not to be used in MOD equipment where use of alternative materials is reasonably practicable and consistent with meeting operational requirements. Under no circumstances is Radium 226 to be used for luminous items.

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26 Where the use of radioactive material is essential, the prior risk assessment carried out in accordance with IRR 99 is to address the use of possible alternative radionuclides. This is to enable the selection of radionuclide(s) which carry the lowest reasonably practicable overall risk, consistent with meeting operational requirements. The cost and manner of disposal of radioactive materials used will also need to be considered by IPTLs at an early stage of the assessment. Consultation with an RPA prior to the introduction of new equipment 27 In projects for which they have responsibility, the DLO/DPA Integrated Project Team Leader (IPTL) must include in contracts a requirement to consult with an RPA prior to the introduction of any new radioactive material or equipment capable of producing ionising radiation. Disposal of Redundant or Surplus Radioactive Materials 28 Accumulation of surplus or redundant radioactive material is to be avoided. It should normally be disposed of within 3 months, usually via the stores system. Where items cannot be returned through the stores system, the RPA is to be consulted for advice. ACCOUNTING AND TRANSFER OF RADIOACTIVE MATERIAL Records and Accountancy 29 All radioactive materials including those exempt from the need for a Notification are to be recorded and accounted for. Transfer of Radioactive Articles 30 When radioactive articles are transferred / consigned from one site to another, a full audit trail of the supply and receipt is to be maintained. The consignor must ensure that the consignee has the appropriate regulatory permits (e.g. Notification, Registration, etc) in place before commencing the transfer. Disposal of Radioactive Items by Sale or Donation 31 The disposal of radioactive items by sale or donation does not constitute disposal as radioactive waste and therefore does not require regulatory approval. However, the relevant environment agency conditions prohibiting the sale or supply of materials, unless it is suitably marked and/or described, are to be met. Furthermore, with the exception of exempt articles, no radioactive items are to be disposed of by sale or donation unless it is first ascertained that the proposed recipient has appropriate registration under RSA93. Proof that this was carried out should be retained for audit. 32 Sales of radioactive articles to overseas customers may be subject to special rules or conditions. In all such cases, advice is to be sought from the appropriate RPA before sale arrangements commence. 33 No items containing radium-226 are to be offered for sale to or donated to the general public.

Disposal of Ships 34 It is MOD policy that all major platforms, including ships and aircraft are monitored for radioactive items prior to disposal.

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CHAPTER 5 RADIOACTIVE WASTE Contents Para 1 5 6 7 10 12 Introduction UK Radioactive Waste Inventory Radioactive Waste Ownership Radioactive Substances Act 1993 and Defence Related Activities Discharges to the Environment UK Strategy for Radioactive Discharges

INTRODUCTION 1 The MOD is committed to complying, with legislation and so far as is reasonably practicable, with national policies relating to the management of radioactive waste and decommissioning. Details of national policy on the management of radioactive waste can be found on the DEFRA website: http://www.defra.gov.uk/environment/radioactivity/index.htm 2 MOD in managing radioactive waste is committed to delivering the commitments in the Secretary of States Policy Statement on Safety Health and Environmental Protection. In particular radioactive waste management practices must be framed in the context of the MODs policies and management arrangements on sustainable development and the environment. These are detailed in JSP 418 Sustainable Development and Environment Manual available on the Defence Intranet and on the World Wide Web. 3 As a general policy, managers and waste owners must: 3.1 Ensure through the use of best practical means1, that due consideration is given to not creating waste; or where this is not reasonably practical, minimising the generation of radioactive waste at every stage of any activity involving radioactive materials; 3.2 Carefully consider decay storage, recycling and/or reuse of materials2 and incineration as an alternative to declaring them as waste;

The BPM principle has most recently been defined by a statement of the UK Government and the devolved administrations' policy on the decommissioning of nuclear facilities http://www.scotland.gov.uk/Publications/2004/09/19915/42728 Essentially, it requires operators to take all reasonably practicable measures in the design and operational management of their facilities to minimise discharges and disposals of radioactive waste, so as to achieve a high standard of protection for the public and the environment. BPM is applied to such aspects as minimising waste creation, abating discharges and monitoring plant, discharges and the environment. It takes account of such factors as the availability and cost of relevant measures, operator safety and the benefits of reduced discharges and disposals. If the operator is using BPM, radiation risks to the public and the environment will be as low as reasonably achievable (ALARA).2

1

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3.3 Ensure through the use of best practical means, that risks and doses to people now and in the future are kept as low as reasonably practical; 3.4 Ensure through the use of best practical means, that harm to the environment now and in the future so far as is practical is minimised; 3.5 Ensure from the conceptual stage, that for all activities involving radioactive substances, the method of eventual disposal has been considered and resources provided, this includes where required, the provision of decommissioning plans; 3.6 Establish performance indicators to demonstrate the extent to which these policy requirements are being achieved; and 3.7 Conform, where reasonably practicable, to the Environment Agencies risk screening and appraisal methodologies. 4 At the direction of the Sustainable Development and Environment Board, DS&C may carry out top level audits to determine compliance with these policy requirements and where necessary, functional audits of specific areas and activities. UK RADIOACTIVE WASTE INVENTORY 5 Waste owners are required to provide timely and accurate information about the radioactive waste they hold and projected future radioactive waste arisings to the organisation contracted by DEFRA/NIREX to produce the UK Radioactive Waste Inventory. DGSM (NW-SI2) coordinates the collation of this information across MOD and ensures that the required information is provided in the required form and by the due date. RADIOACTIVE WASTE OWNERSHIP 6 Because the Secretary of State (S of S) is accountable for and responsible for the safe management of defence related radioactive wastes it is generally MOD policy to retain title of defence related radioactive waste. Advice should be sought from DS&C where the transfer of title of radioactive waste to another party is being considered, in order that advice on the legal implications can be sought (Euratom, IAEA treaty obligations etc). RADIOACTIVE SUBSTANCES ACT 1993 AND DEFENCE RELATED ACTIVITIES 7 The Radioactive Substances Act 1993 is disapplied by virtue of subsection 2 of section 42 of the Radioactive Substances Act 1993 in respect of premises occupied on behalf of the Crown for Royal Naval, Military or Royal Air Force purposes Advice on the interpretation of the extent of this disapplication in a particular circumstance should be sought, in the first instance, from the Radiation Protection Advisor. Where they are unable to resolve the issue, DS&C should be consulted. 8 To fulfil the requirements of S of Ss policy, MOD has established formal arrangements (including a Radioactive Substances and Nuclear Annex on RSA93 matters to the MOD/EA MOU) with the environmental regulators that describe the arrangements to establish a degree of control equivalent to that in the civil sector. These Annexes can be found at [to be inserted]. 9 Unless items can be disposed of under local regulations overseas with agreement of the countries relevant bodies radioactive waste is to be returned to the UK and disposed of in accordance with UK legislation and the agreement of the UK regulators. DISCHARGES TO THE ENVIRONMENT 10 Waste owners and managers are to ensure the proactive publication of information about discharges to the environment of radioactive substances as required by the Environmental Information Regulations.

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11 It is MOD policy to provide information about radioactive discharges to the environment for inclusion in the Environment Agencys National Pollution Inventory; DGSM provides data to the Environment Agency. DS&C currently coordinates the inclusion of data for inclusion in the Radioactivity in Food and the Environment Reports (RIFE Reports) produced by the Food Standards Agency. These reports can be found at http://www.food.gov.uk/science/surveillance/radiosurv/ UK STRATEGY FOR RADIOACTIVE DISCHARGES 12 The MOD is bound by the national commitments in the UK Strategy for Radioactive Discharges 2001-2020, which sets out how the UK will implement the OSPAR radioactive discharge strategy. http://www.defra.gov.uk/environment/radioactivity/government/discharges/pdf/rad_dischargestrat1.pdf is the website address for this document. 13 The strategy requires: 13.1 progressive and substantial reduction of radioactive discharges and discharge limits, to achieve the strategy targets for each; 13.2 progressive reduction of human exposure to ionising radiation arising from radioactive discharges, as a consequence of reductions in discharges, such that a representative member of a critical group of the general public will be exposed to an estimated mean dose of no more than 0.02 millisieverts (mSv) a year from liquid radioactive discharges to the marine environment made from 2020 onwards; 13.3 progressive reduction of concentrations of radionuclides in the marine environment resulting from radioactive discharges, such that by 2020 they add close to zero to historic levels. (The terms "close to zero" and "historic levels" are not defined in the OSPAR Strategy and the OSPAR Commission is continuing to work on establishing agreed definitions). 14 This strategy recognises that, within the policy of progressive reduction, some flexibility will need to be maintained to safeguard other key Government objectives including the operational capabilities of the armed forces. 15 The Defence sector targets in the national strategy are: 15.1 By 2020, tritium discharges from the defence sector are expected to be reduced from 0.7 TBq to 0.4 TBq a year; and 15.2 year. 16 Other beta/gamma discharges are expected to be reduced from 0.005 to 0.003 TBq a

DS&C is the focal point for the collation of data for submission to DEFRA for the national strategy.

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CHAPTER 6 NON-IONISING RADIATION PROTECTION POLICY Contents Para 1 3 4 7 Table 1 Introduction Principles of Radiological Protection Legislation MOD Policy Page Nomenclature for Non-ionising Radiation........................................................................................3

INTRODUCTION 1 Non-ionising (NIR) radiation covers a range of the electromagnetic spectrum from the ultraviolet through visible light and radiofrequencies to static fields. The common designations for the division of non-ionising radiation into named regions are shown in Table 1. 2 This chapter is not intended to be applied to the exposure of patients undergoing exposure to NIR for therapeutic or diagnostic reasons. PRINCIPLES OF RADIOLOGICAL PROTECTION 3 There have been formal guidelines for the protection of personnel from non-ionising radiation for decades (certainly 1960 for radio frequencies and 1965 for lasers). The International Radiation Protection Association (IRPA), the international body representing radiation protection professionals world-wide, has chartered the International Commission on Non Ionizing Radiation Protection (ICNIRP) as an independent Commission for the purpose of advancing Non Ionizing Radiation Protection for the benefit of people and the environment and in particular to provide guidance and recommendations on protection from NIR exposure. There are also numerous professional and national bodies that make recommendation, give guidance or may legislate. Examples of these are the American Conference of Governmental Hygienists (USA), the Institute of Electrical and Electronics Engineers (USA), the Health Protection Agency (UK), IEC/CENELEC/BSI (international/Europe/UK lasers). LEGISLATION 4 There is no UK legislation specific to non-ionising radiation protection. Therefore, the following legislation is most relevant: the Health and Safety at Work etc Act 1974; the Management of Health and Safety at Work Regulations 1999 and the Health and Safety (Safety Signs and Signals) Regulations 1996. 5 The agencies enforcing UK legislation refer to the advice given to government by the Radiation Protection Division of the Health Protection Agency (formerly the National Radiological Protection Board). That advice is to conform to the ICNIRP guidelines.

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6 The European Union has adopted Directive (2004/40/EC) 29 April 2004 on the minimum health and safety requirements regarding the exposure of workers to the risks arising from physical agents (electromagnetic fields) that lays down the basis for controlling occupational exposure. This will be transposed into UK legislation, no later than 24 May 2008. It uses a scheme of basic restrictions and reference levels drawn from the ICNIRP guidelines. There also exists Council Recommendation (1999/519/EC) of 12 July 1999 on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz). Being a Recommendation, it is not binding on EU Member States, hence the lack of UK legislation, but the UK has moved towards its implementation. MOD POLICY 7 The Secretary of States Policy is discussed under ionising radiation protection policy and exactly the same principles apply to non-ionising radiation protection. 8 It is MOD policy that exposure of personnel to EMF will conform to the guidance from the Health Protection Agency's Radiological Protection Division, wherever reasonably practicable. Such exposure should, in addition, be kept to as low a level as is reasonably practicable. There is more information in Leaflet 22 of JSP 375 the MOD Health & Safety Handbook for electromagnetic fields and waves (0 Hz to 300 GHz) and JSP 390 Military Laser Safety.

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Table 1 Nomenclature for Non-ionising Radiation EM Spectrum Designations Static fields 0 Hz > 0 Hz Sub ELF 30 Hz ELF 300 Hz VF 3 kHz VLF 30 kHz LF 300 kHz MF 3 MHz HF 30 MHz VHF 300 MHz UHF 3 GHz SHF 30 GHz EHF 300 GHz or 1 mm IRC 3 m IRB 14 m IRA 760 nm Visible 400 nm UVA 315 nm UVB 280 nm UVC 100 nm continuation of ultraviolet 10 nm X & rays < 10 nm

Non-ionising

Infrared

Microwaves Electromagnetic

Radiofrequency (RF)

Ionising

X & rays

Ultraviolet

optical radiations

Vis

electromagnetic fields

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CHAPTER 7 RADIATION PROTECTION COMMITTEES Contents Para 1 2 4 Introduction Radiation Protection Policy Development Committee and the Radioactive Waste Working Group Radiation Protection Instrumentation Committee

INTRODUCTION 1 The roles and responsibilities for the overall management health safety and environment are described in JSP 815 Defence Environment and Safety Management. Broadly, there is a separation between functional safety boards that deal with policy, MOD parallel arrangements where legislation does not apply to MOD and assurance issues, and management boards and appointees that implement and assure compliance with legislation, MOD and local policy in health safety and environment. RADIATION PROTECTION POLICY DEVELOPMENT COMMITTEE AND THE RADIOACTIVE WASTE WORKING GROUP 2 The Defence Environment and Safety Board, Occupational Health and Safety Board (OHSB), Sustainable Development and Environment Board (SDEB) and Defence Nuclear Environment and Safety Board all have a functional interest in radiological protection. Their individual roles and interrelationships are described in JSP 815. 3 The Radiation Protection Policy Development Committee (RPPDC) reports to the OHSB and the Radioactive Waste Working Group (RWWG) to the RPPDC. The terms of reference (TORs) of both these Committees are contained in JSP 375. These committees may set up working groups as they deem necessary to develop policy on specific topics. RADIATION PROTECTION INSTRUMENTATION COMMITTEE 4 The Radiation Protection Instrumentation Committee (RPIC) reports to the RPPDC. Its TORs are given in JSP 425.

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CHAPTER 8 RADIATION PROTECTION APPOINTMENTS Contents Para 1 2 Aim Introduction Appointments by the Commanding Officer / Head Of Establishment Statutory Appointments Appointed Doctor Radiation Protection Adviser Radiation Protection Supervisor Dosimetry and Dosimetry Record Keeping Services MOD Appointments Radiation Safety Officer Workplace Supervisor Qualified Person Employees

3 4 5 6 7 8 9 11 AIM

1 This chapter outlines the duties and the responsibilities for radiological protection of personnel within establishments and units. INTRODUCTION 2 The Policy Statement on safety health and environmental protection in the Ministry of Defence by the Secretary of State for Defence devolves duties through the line management chain, such that the Commanding Officer/Head of Establishment is a duty holder for environmental and health and safety matters, including radiation protection (see JSP 815 Chapter 3 paragraph 28 etc). CO/HE is required to make a statement detailing their organisation and arrangements in these areas, the appointments detailed below will be part of this. APPOINTMENTS BY THE COMMANDING OFFICER / HEAD OF ESTABLISHMENT Statutory Appointments Appointed Doctor 3 In general, where classified persons are employed, the Commanding Officer/Head of Establishment is to ensure that a registered medical practitioner is available to carry out the duties of the Appointed Doctor (AD) under the Ionising Radiations Regulations 1999 (IRR99) The role of the AD and his appointment are described in Leaflet 6. Radiation Protection Adviser 4 A Radiation Protection Adviser (RPA) will advise the Commanding Officer/Head of Establishment on compliance with national legislation and MOD standards etc. The Commanding Officer/Head of Establishment has a duty to consult the Radiation Protection Adviser on matters which are set out in schedule 5 of IRR99. Sites working within MODs nuclear weapons and nuclear propulsion programmes will have appointed local RPAs. Otherwise, TLBs will have made arrangements for RPA advice to be available. The RPA for most units and establishment outside the nuclear programmes is Dstl Environmental Sciences Department.

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Radiation Protection Supervisor 5 Radiation Protection Supervisors (RPS) are to be appointed by the employer to enable work with ionising radiation to be carried out in accordance with legislation. Appointments are to be made in writing. Dosimetry and Dosimetry Record Keeping Services 6 Where IRR99 requires it, a HSE Approved Dosimetry Service must be used to undertake dose assessments using suitable monitors. It is a requirement of IRR99 that the records of such assessments are kept by a HSE Approved Dosimetry Record Keeping Service (ADRKS). Generally, arrangements for this will be made through the TLB. MOD Appointments Radiation Safety Officer 7 The role of the Radiation Safety Officer (RSO) is analogous to that of the Safety Adviser described in JSP 375. Depending upon workload, competence etc one or more individuals may be appointed to these roles. Appointments are to be made in writing. Workplace Supervisor 8 Workplace Supervisor (WPSs) are appointed where it is unnecessary to appoint an RPS, to undertake duties to ensure that work with sources of ionising radiation is carried out in accordance with legislation, the requirements of this publication and local orders for radiation safety. WPSs may be appointed to supervise radioactive materials, X-ray equipments or radon that does not require the setting up of designated areas or a combination of these activities. Appointments are to be made in writing. Qualified Person 9 The employer of an establishment which has its own ionising radiation protection instrument test house, is to appoint in writing one or more qualified persons to carry out or to supervise the testing of ionising radiation protection instruments in accordance with JSP 425 and IRR99. Qualified persons appointees are to receive the qualification and training specified in JSP 425. 10 Persons appointed to carry out or supervise the examination and testing of radiation detection and monitoring equipment are to, as a minimum, complete the training specified in JSP 425. Job specific training requirements are to be specified in local orders. EMPLOYEES 11 Employees also have the duties with regard to radiation protection described in regulation 24 of IRR99 and paragraph 560 of the ACOP.

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CHAPTER 9 TRAINING AND QUALIFICATIONS IN RADIATION PROTECTION Contents Para 1 3 5 6 Introduction Provision of Suitable Training Training and Qualifications for Specific Radiation Protection Posts and Appointments Training Records

INTRODUCTION 1 The Management of Health and Safety at Work Regulations 1999 (MHSWR 99) requires every employer to ensure that their employees are provided with adequate health and safety training on being first recruited and on being exposed to new risks this training is to be repeated periodically where appropriate. The Ionising Radiations Regulations 1999 (IRR 99) require employers to ensure that employees engaged in work with ionising radiation are given appropriate training in the field of radiation protection. 2 The particular, appointments specified by IRR 99 are the Radiation Protection Adviser (RPA), Radiation Protection Supervisor (RPS) and Appointed Doctor. The requirement for these appointments and other radiation protection appointments required within MOD are detailed in Chapter 8, which also identifies the duties of Commanding Officers and Heads of Establishment to make sufficient appointments and to ensure that appointees and other personnel are adequately supervised and have been given information, instruction and training in the tasks they are to undertake. PROVISION OF SUITABLE TRAINING 3 Commanding Officers and Heads of Establishment are to ensure that the training requirements, including refresher training, for all radiation protection appointments and employees engaged in work with ionising radiation are specified in local orders. It is also to be ensured that visitors who are provided access to ionising radiations are given suitable information, instruction and training. 4 The training specifications may draw directly from the requirements of this publication, from guidance issued by the regulators and from the advice of a suitable RPA. Training may often include generic training courses delivered by an MOD or external provider but it should also include elements specific to the task or job to be carried out and to the hazards and risks concerned. TRAINING AND QUALIFICATIONS FOR SPECIFIC RADIATION PROTECTION POSTS AND APPOINTMENTS 5 Training and qualifications for specific posts and appointments is detailed in Volume 2, leaflet 15.

TRAINING RECORDS 6 A record is to be kept of the training undertaken for two years following termination of the appointment.

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CHAPTER 10 RADIATION DOSE CONTROL Contents Para 1 3 5 Introduction Formal Investigation Level Non-human Species

INTRODUCTION 1 This chapter describes the MOD policy that is additional to the requirements of legislation. Detailed requirements can be found in Volume 2 of this publication. 2 Radiation doses are controlled by two regimes, overall management control and physical arrangements. Any practice involving exposure to ionising radiation must be planned and risk assessed. An element of this will be to ensure that doses are kept as low as reasonably practicable (ALARP). This will make it apparent whether or not the provisions of IRR99 relating to the designation of areas, classification of workers etc need to be applied. Out of this process, management should be able to establish targets that will assist them in assessing their success in achieving high standards of radiological protection including keeping exposures ALARP. An example of this is the dose constraint, which is set at a level consistent with the successful operation of the practice but lower than statutory limits and reporting points. FORMAL INVESTIGATION LEVEL 3 A formal investigation level is to be prescribed by Commanding Officers for occupationally exposed workers. This investigation level is set at a maximum of 6 mSv effective dose in any calendar year, although local circumstances will often justify the setting of a lower level. The RPA must be consulted as to the setting of an appropriate investigation level. 4 Where the effective dose to any MOD employee exceeds the investigation level, a locally conducted investigation is to be carried out by the Commanding Officer to determine whether all steps are being taken to keep radiation exposure ALARP. Detailed instructions are contained in Volume 2 Leaflet 14. The RPA must be consulted as to the conduct of this investigation. NON-HUMAN SPECIES 5 MOD follows the recommendations of the International Commission on Radiological Protection (ICRP) who believes that the standards of environmental control needed to protect man to the degree currently thought desirable will ensure that other species are not put at risk. Occasionally, individual members of non-human species might be harmed, but not to the extent of endangering whole species or creating imbalance between species. However, the ICRP are revisiting this position and are developing criteria for reference animals and plants. MOD will follow developments, both internationally and nationally, and will keep this policy under review.

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CHAPTER 11 RECORD KEEPING Contents Para 1 2 4 7 8 11 Annex A Records of Interest Primary and Secondary (Supporting) Records Introduction Dosimetry Records Record Retention MOD Agencies Closure of Sites Privatised Companies

INTRODUCTION 1 The keeping of many radiation records is a statutory requirement and within legislation the timescales for which records have to be kept are also specified