Radiation Protection in School Science: Guidance for Employers
Information for local authorities (PS46A)
Note: this leaflet is intended for those employers which are local authorities (LAs). There is a separate version, PS46B, for those
employers in independent schools (including foundation and voluntary-aided establishments) and colleges.
1.
Introduction and legal requirements
Low-level radioactive sources are used in most secondary school science departments to teach parts of the National
Curriculum in Science and/or GCE A-level Physics. This means that most, probably all, local authorities responsible
for education are regarded as radiation employers. The Ionising Radiations Regulations 1999 (IRR99), made under the
Health and Safety at Work etc Act 1974, came into force on 1 st January 20001 . They require a radiation employer to ensure
that radioactive substances are accounted for, stored properly, handled safely and monitored regularly. The employer
must provide employees with appropriate information and instruction in radiation protection to ensure their health
and safety2 . The Health and Safety Executive (HSE)3 , and CLEAPSS4 are able to assist in this process. Previous
guidance from the former DfES was withdrawn for schools in England in September 2008 as the DCSF now endorses
CLEAPSS guidance.
Since the previous Ionising Radiations Regulations 1985 (IRR85), the employer has had a duty to appoint a Radiation
Protection Adviser (RPA). However, there are now much more stringent requirements for the qualifications and
experience of an RPA5. The HSE has confirmed that the type of work carried out with radioactive substances in school
science means that the employer must consult and then, in nearly all cases, appoint (in writing) an RPA.
2.
Competence, knowledge and experience of the RPA
Although there were some transition arrangements, IRR99 now stipulates two equally important requirements for an
RPA, given below. The employer must ensure that the RPA satisfies these requirements.
A. The individual or body wishing to act as an RPA must demonstrate that the HSE Criteria of Competence
have been met.
These are contained in the HSE Statement on Radiation Protection Advisers. The employer must ensure that the RPA
conforms to the criteria. This means that:
•
an individual RPA (ie, a single person) must:
either hold a current certificate from an ‘Assessing Body’ recognised by the HSE6,
have a National Vocational Qualification at level 4 in radiation protection 7, awarded within the
previous five years;
an RPA body (ie, an organisation) must provide evidence of formal recognition by the HSE.
or
•
1
In Northern Ireland, the equivalent legislation is the Health and Safety at Work Order (Northern Ireland) 1978 and the Ionising Radiations
Regulations (Northern Ireland) 2000.
2
The Ionising Radiations Regulations 1999, Regulation 14.
3
Working With Ionising Radiation, HSE Books, 2000, ISBN 0717617467 (includes The Ionising Radiations Regulations 1999, an Approved
Code of Practice and Guidance).
4
Managing Ionising Radiations and Radioactive Substances in Schools, etc, CLEAPSS guide L93.
5
The Ionising Radiations Regulations 1999, Regulation 13 and the HSE statement on Radiation Protection Advisers, currently dated 29th
November 2004, available from the HSE web site www.hse.gov.uk/radiation/ionising/rpa/statementrpa.htm.
6
This will normally be a certificate issued by RPA 2000 (76 Portland Place, London W1B 1NT).
7
A free-standing 9-module NVQ in Radiation Protection (at level 4 only) was approved in January 2002. This replaces the optional radiation
protection modules at all levels of the Occupational Health and Safety NVQs. Details of the new NVQ are available from the Employment
National Training Organisation; www.ento.co.uk/standards/index.php?catalogue=hs_radpro.
PS46A, JRE/TPB, 05/13
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B. The employer must select an RPA who has suitable knowledge and experience of the employer’s type
of work.
This means that the RPA must demonstrate an understanding of procedures in school science departments.
3.
Choice of RPA
An RPA can be a part-time or full-time employee, consultant or organisation. A letter of appointment must formalise
the terms of the arrangement between the RPA and the employer, in particular by specifying the scope of the advice the
RPA is required to give.
In the past, RPAs for schools were mainly Science Advisers/Inspectors or Health & Safety Advisers but few could now
satisfy the HSE Criteria of Competence. To do so would require extensive and time-consuming training and
recertification every five years. The RPA would also need to spend a relatively high proportion of time in radiation
protection work, which is usually not the case for LA employees.
However, even if he or she does not meet the HSE Criteria, an LA officer may be able to oversee and monitor radiation
protection in the employer’s schools as a ‘Radiation Protection Officer’. In this situation, in order to comply with the law,
the employer will need to consult and usually appoint an RPA who satisfies the current HSE Criteria and advises the Radiation
Protection Officer.
Rather than appointing an RPA, it might be tempting to consider disposal of radioactive sources from schools. This
would be detrimental to science education, because it would limit the courses that a school could offer at a time when
there is concern over the supply of physics teachers and of students studying physics after leaving school. It would
also be very expensive, as disposal of some sources can cost thousands of pounds, and detrimental to the
environment.
4.
The CLEAPSS RPA Service for local authorities
CLEAPSS offers an RPA Service to LA members and currently over 60% of LAs avail themselves of the service.
Participation in the CLEAPSS scheme is optional and there is a supplementary annual charge, based on the number of
schools holding sources. This does NOT entitle the LA to any visits by the RPA – if necessary, these would be charged
extra. The service is only available as long as an LA remains in CLEAPSS membership and, if an LA decides to leave
the RPA service, this can only take place at the end of the financial year, with a minimum notice of one year. The
subscription is paid centrally, although some local authorities then recover it from schools, sometimes as part of a
package of health and safety services. Although mainly intended to cover schools for which the local authority is the
employer (ie, community and voluntary controlled schools) the local authority can, if it wishes, include foundation
and voluntary aided schools – or indeed colleges and academies.
In order to keep costs as low as possible, the essence of the CLEAPSS RPA Service is that it is an RPA-at-a-distance.
The LA needs to appoint a contact person, who is designated as the LA Radiation Protection Officer (RPO). This
might, for example, be a science adviser or inspector, or a health & safety adviser; ie, people who regularly visit schools
to monitor and advise on either the science curriculum or health & safety matters. However, we do NOT think this is a
role for a pure administrator. CLEAPSS normally requires RPOs to attend a 1-day training course. In essence the
RPO’s role involves keeping records and visiting schools to monitor the use, storage and management of radioactive
sources, in line with the general guidance from the former DfES on monitoring health and safety in Health and Safety:
Responsibilities and Powers1. A more detailed description of the role of the RPO can be supplied if required (ask for RPA
6). It may be that in some LAs there is no suitable officer who could take on the whole of this role. In such cases, the LA
might buy in expertise, eg, from an experienced physics teacher or from an educational consultant (or possibly even
from the RPA, but that would be at the RPA’s discretion, it is not an entitlement). CLEAPSS may be able to suggest
suitable contacts in some areas but generally we feel an officer of the LA is preferable. If an LA decides to split the role
in this way, CLEAPSS would continue to deal with the designated contact person and regard him or her as the RPO.
If an LA wishes to join the CLEAPSS RPA Service, please contact us and ask for RPA7, which includes more details
and an application form. Note that CLEAPSS is not currently classed as an ‘RPA Body’ (see section 2). Any agreement
for RPA services will be made between the LA and an individual RPA, within the framework of the CLEAPSS service.
1
Health and Safety: Responsibilities and Powers, DfES, 2001, DfES Publications (DfES/8303/2001).
PS46A, JRE/TPB, 05/13
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5.
Alternative sources of RPAs
We recognise that the CLEAPSS RPA Service may not suit all LAs, for example, if there is difficulty in identifying a
suitable person to be RPO. Some LAs may wish to explore the economics of alternative providers. We believe the
CLEAPSS model is likely to be much the cheapest for LAs with small numbers of schools but it may not be so clear-cut
for large LAs. The following table shows the alternative providers of which we are currently aware.
Contractor
Address
Contact details
Comments
Aurora Health Physics
Services Ltd
4 Station Yard
Ashburton
Newton Abbott
Devon TQ13 7EF
Tel:
Fax:
E-mail:
Web site:
01491 681366
01491 684126
allan.may@aurorahp.co.uk
www.aurorahp.co.uk
Contact: Allan May
Integrated Radiological
Services Ltd
Unit 188, Century
Building, Tower Street
Brunswick Business
Park
Liverpool L3 4BJ
Tel:
Fax:
E-mail:
Web site:
0151 709 6296
0151 709 8772
admin@irs.u -net.com
www. irs.u-net.com
Contact: Melvin Lewis
Radman Associates
Harvey House
Bollington
Macclesfield
Cheshire SK10 5JR
Tel:
Fax:
E-mail:
Web site:
01625 576000
01625 576001
admin@radman.co.uk
www.radman.co.uk
Contact: Robert Collins
Health Protection Agency,
Centre for Radiation,
Chemical and
Environmental Hazards,
Radiation Protection
Division
Occupational Services
Department
Hospital Lane
Cookridge
Leeds LS16 6RW
Tel:
Fax:
E-mail:
Web site:
0113 267 9041
0113 261 3190
leeds@hpa-rp.org.uk
www.hpa.org.uk/radiation/
Contact: Richard Paynter
The Radiation Physics
Department
Queen’s Centre for
Oncology &
Haematology
Castle Hill Hospital
Castle Road
Cottingham
East Yorkshire
HU16 5JQ
Tel:
Fax:
E-mail:
Web site:
01482 461329
01482 461379
office@hullrad.org.uk
www.hullrad.org.uk/contact
s
Contact: Andrew Davis
(Formerly National Radiological Protection Board)
HULLRAD
Hull & East Yorkshire
Hospitals (NHS) Trust
Radiation Protection
Service
6.
The employer’s day-to-day responsibilities
IRR85 required one or more members of staff at each place of work to be appointed as Radiation Protection Supervisor
(RPS). The requirement has been reiterated in much guidance to educational establishments since then. IRR99 no
longer requires the majority of schools to have an RPS because the annual doses received by staff and students are very
low. However, someone, whatever his or her title, must have responsibility for the safe storage, use and monitoring of
radioactive sources. For this reason, and because the term is now very familiar, we strongly recommend that each
science department has a named RPS (Schools).
Many LAs and their RPAs have decided to use CLEAPSS guide L93, Managing Ionising Radiations and Radioactive
Substances in Schools, etc, as a reference document for use in their schools. This publication is freely available on the
CLEAPSS web site (courtesy of funding from the DCSF) and paper copies are free to members on request. It includes
model risk assessments and a checklist for the management of radioactive sources in schools. Some employers have
now chosen to use the checklist as part of their monitoring procedure. The latest version is reproduced overleaf and
may be copied freely by CLEAPSS members.
PS46A, JRE/TPB, 05/13
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Tel: 01895 251496; Fax: 01895 814372; E-mail: science@cleapss.org.uk; Web site: www.cleapss.org.uk
Checklist for management of radioactive sources in schools (September 2008)
Item
Section in
CLEAPSS
guide L93
(Sept 2008)
The employer has notified the HSE of the intention to use radioactive sources.
2.1
The employer has appointed a Radiation Protection Adviser (RPA).
2.2
A Radiation Protection Supervisor (Schools) has been appointed.
2.3
Maintained (state) schools in Wales and Northern Ireland:
An approval letter is on file from the appropriate government education department.
The standard operating procedures and contingency plans have been agreed with
the RPA.
3.2 & 9.1.3
3.1
The name and contact details of the RPS (Schools), and RPA have been included
in the Standard Operating Procedures and/or in the science department health and
safety policy.
6
A check has been made that all radioactive substances kept are suitable for use in
education establishments.
3.2 & 7
A check has been made that the Standard School Holding is not exceeded.
3.2
Appropriate, working, monitoring equipment is available.
3.5
Satisfactory storage arrangements have been made for radioactive substances.
3.6
The fire authorities (probably via the site manager) have been told where the
radioactive substances are kept.
Documentation
is in place and
kept up to date.
Tick
3.6.2
A radioactive source history, for each source, including the
results of regular inspections and leak tests.
4.1.1 & 5.2
The use log, completed whenever sources are used.
4.1.2 & 5.3
The audit record, completed annually.
4.1.3 & 5.4
The RPS (Schools) is satisfied that staff authorised to handle or use radioactive
substances are appropriately qualified.
2.4.1, 2.4.2
& 5.5
For each member of
staff who handles or
uses radioactive
substances:
The RPS (Schools) is satisfied that they are familiar with
and understand the Standard Operating Procedures.
2.4.3 & 5.5
The RPS (Schools) has provided appropriate instruction and
training.
2.4.3 & 5.5
The RPS (Schools) has ensured that appropriate instruction and training is given to
all students, particularly those aged 16 and above who handle sealed sources.
2.4.5
The RPS (Schools) regularly checks to ensure that sources have been returned to
the store.
4.1.3 & 5.4
Name of RPS (Schools) completing this form:
Signature:
Date:
© CLEAPSS 2008
PS46A, JRE/TPB, 05/13
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Tel: 01895 251496; Fax: 01895 814372; E-mail: science@cleapss.org.uk; Web site: www.cleapss.org.uk