MIDLANDS CONSTRUCTION SAFETY GROUP
YOU’LL
(WELL ACTUALLY THE CONTRACTORS)
Presented by Mr David Hortop BA (Hons) MIOSH Safety Advisor
Working in partnership with Lincolnshire County Council
CLIENT MANAGEMENT OF SITE RADIOGRAHY CONTRACTORS
“FROM ZERO MANAGEMENT TO SUCCESSFULL MANAGEMENT
OF SITE RADIOGRAPHERS”
Working in partnership with Lincolnshire County Council
CLIENT MANAGEMENT OF SITE RADIOGRAHY CONTRACTORS
Who am I?
Mr David Hortop
Ex HM Inspector of Health & Safety
Multi Group HSE Nottingham Office
(Proud to have been one of Mike Sparks Inspection Team!)
NOW
H&S Advisor with Mouchel (full time)
Schools and Social Services – and
Ex H&S Advisor with the Air Cadets
(National Regional and Local levels)
Working in partnership with Lincolnshire County Council
CLIENT MANAGEMENT OF SITE RADIOGRAHY CONTRACTORS
Government (David’s) Health Warning !
For those of a nervous disposition
THIS PRESENTATION CONTAINS IMAGES OF –
The Naked Body
Aeroplanes
Site Radiography Contractors
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CLIENT MANAGEMENT OF SITE RADIOGRAHY CONTRACTORS
The Location
A large busy (24 x 7) processing factory
The Problem
No effective management of site
radiography contractors
Work considered ‘too specialist’ and
complex by factory management.
Also fear of process and lack of
confidence/knowledge to effectively
supervise the contractors.
Potentially dangerous working
techniques by contractors
The Solution
A one day training course for factory
managers and supervisors
Working in partnership with Lincolnshire County Council
CLIENT MANAGEMENT OF SITE RADIOGRAHY CONTRACTORS
HOW TO GENERATE CONFIDENCE TO SUCCESSFULLY MANAGE AND
SUPERVISE SITE RADIOGRAPHY CONTRACTORS
1 Treat the management and supervision of this work in exactly the same way
as any other construction subject e.g. CDM, Asbestos Management,
Legionella Management, Steel Erection, Roof work etc.
2 Apply the same basic systematic approach and principles to managing and
supervising site radiography as any other construction subject and do not
be ‘blinded by the science’ and ‘technical terms’ used.
We will now revisit the basic steps to understanding site radiography
Working in partnership with Lincolnshire County Council
Site radiography – ‘Made Simple’
1
The Law - Key Legislation
2
The Problem and Basic Principles
3
The Equipment used
4
The Key ‘Players’ involved
5
The Basic Faults and Failings to look for
6
Other Basic Hazards involved
7
Sources of Information
8
Summary and Any other Questions ?
Working in partnership with Lincolnshire County Council
1 THE LAW - Key Legislation
The Health and Safety at Work etc Act 1974
Section 2. General duties of employers to their employees
Section 3. General duties of employers and self employed
to persons other than their employees
The Management of Health and Safety at Work Regulations
1999
Regulation 3. Risk Assessment
Regulation 11. Co-operation and Co-ordination
The Ionising Radiations Regulations 1999 (IRR99)
Regulation 6 Notification of specified work
Regulation 8 Restriction of exposure
Regulation 11 Dose limitation
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2 The Problem and Basic Principles
What is the problem?
Site radiography uses equipment that generates either X or Gamma rays and are known as
ionising radiations.
Exposure to ionizing radiation causes damage to living tissue, and can result in
mutation, radiation sickness, cancer, and death.
X and Gamma rays cannot be seen, smelt, felt, heard or tasted.
Gamma rays are more damaging and penetrative than X rays.
Gamma rays cannot be switched off – X rays can be switched off.
There are three factors that control the amount, or dose, of radiation received from a
source –
Time - Distance - Shielding
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2 The Problem and Basic Principles
What is the problem?
Industrial radiography usually involves using intense radiation sources which can expose
people at work to significant amounts of radiation.
Site Radiographers have received life shortening exposures and have exposed other
people to unnecessary exposures.
Over the years several serious incidents have been caused by the failure to maintain
equipment, to carry out routine monitoring or to employ proper emergency procedures.
HSE inspectors have also found that a significant number of NDT contractors fail to adopt
routine working practices capable of keeping radiation exposures of employees as low as
reasonably practicable: this is the main requirement of IRR99.
Incidents occur because of poor job planning (most notably with site radiography), failure
to use adequate local source shielding, or inadequate systems of work.
Generally, people working in industrial radiography have received higher doses than those
working in other sectors using ionising radiation.
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2 The Problem and Basic Principles
THE DAMAGE TO A HUMAN BODY
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2 The Problem and Basic Principles
X RAY EQUIPMENT
GAMMA RAY EQUIPMENT
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2 The Problem and Basic Principles
X RAY IMAGES
GAMMA RAY IMAGES
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3 The Equipment used
X RAY EQUIPMENT
x-ray tube
control unit
Key Control
Key ON = X-Rays Generating
a high voltage power supply
Key OFF = NO X-Rays
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3 The Equipment used
GAMMA RAY EQUIPMENT
SOURCE INSIDE CONTAINER
NO Gamma Rays
Once SOURCE wound OUTSIDE
Of CONTAINER
Gamma Rays Radiating
ALL the time
UNTIL SOURCE is BACK INSIDE
CONTAINER
(NO ON/OFF switch)
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3 The Equipment used
SAFETY EQUIPMENT COMMON TO BOTH X and GAMMA WORK
BARRIER
WARNING LIGHTS
WARNING SIGNS
WHOLE PERIMETER
BARRIER LIGHTS
WHOLE PERIMETER
WARNING HORN
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3 The Equipment used
SAFETY EQUIPMENT COMMON TO BOTH X and GAMMA WORK
RADIATION MONITOR
MUST HAVE
ON
SITE !
RADIOGRAPHERS INDIVIDUAL FILM BADGE
RADIOGRAPHERS PERSONAL DOSIMETER (OPTIONAL)
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SAFETY EQUIPMENT SPECIFIC TO GAMMA WORK
WARNING LIGHTS
EMERGENCY KIT
LEAD SHOT
TONGS
VEHICLE WARNING SIGNS
SOURCE ‘POT’
SOURCE ‘POT’
MUST
HAVE
ON
SITE !
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LEAD GLOVES, GAUNTLET, NECK, FOOT AND APRON EQUIPMENT
NEVER USUALLY SEEN AT SITE RADIOGRAPHY WORK
BUT WOULD BE REALLY USEFULL FOR GAMMA SOURCE RETRIEVAL
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A MOMENT OF LIGHT RELIEF
LEAD APRONS YOU WILL NOT SEE ON A SITE RADIOGRAPHY PROJECT !
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SO HOW DO WE REALLY MANAGE AND MONITOR THIS PROCESS ?
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4
The Key ‘Players’ involved
THE CLIENT
Responsible for: Justification, Notification and Management/Supervision of the work
(a) Justifying the need for Site Radiography
(i) Can another NDT technique be used?
(ii) Can the Client use the enclosure procedure on their premises?
(iii)Can the Client send the component to the Site Radiography contractors
premises?
(b) Notifying the work to HSE
(i) At least 7 days before the work commences – therefore the client must plan the
work to comply.
(ii) An exemption can be applied for – but it must be for ‘emergency’ purposes only
e.g. An unplanned component failure.
(iii) Exemptions will not be granted for failure to plan routine work requiring site
radiography
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4
The Key ‘Players’ involved
THE CLIENT
(c) Management/Supervision and Co-ordination/Co-operation of the work and with
the Site Radiography contractor.
(i) Draw up their own client risk assessment for the work.
(ii) Adequately vet and select the contractor.
(iii) Obtain a copy of the contractors ‘prior risk assessment’.
(iv) Obtain full details of the contractors Radiation Protection Advisor (RPA).
(v) Obtain a list of the contractors Radiation Protection Supervisors (RPS)
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4
The Key ‘Players’ involved
THE CLIENT
(c) Management/Supervision and Co-ordination/Co-operation of the work and with
the Site Radiography contractor.
(vi) Obtain a copy of the contractors ‘Local Rules’ for their site.
(vii) Obtain a copy or copies of the specific inspection techniques that will be used.
(viii) Draw up and Agree reporting/security procedures.
(ix) Draw up and Agree ‘emergency’ arrangements between both parties.
(x) Train appropriate staff in basic Radiation Safety principles and procedures.
(xi) Carry out and record regular supervisory checks of the contractors work on site
Working in partnership with Lincolnshire County Council
4
The Key ‘Players’ involved
THE SITE RADIOGRAPHY CONTRACTOR
Responsible for: Management /Supervision and
Co-ordination /Co-operation of the work.
(i) Ensure that their staff have on site their ‘prior risk assessment’ document.
(ii) Ensure that their staff have on site their ‘Local Rules’ document.
(iii) Ensure that their staff have on site the specific inspection techniques
documents.
(iv) Liaise with the Client about any matters on site that could affect their
employees – Clients other processes/activities – reporting and emergency
procedures.
(v) Ensure the Client is fully briefed and aware of the ‘jammed source’ procedure.
Working in partnership with Lincolnshire County Council
5
The Basic Faults and Failings to look for
THE CLIENT –
(i) No effective management/supervision/monitoring of site radiographers.
(ii) No effective planning of the work – continued requests for exemption from 7
day notification requirement.
(iii) No Client risk assessment.
(iv) No trained supervisors to monitor the site radiographers.
(v) No effective Co-ordination or Co-operation between each party.
(vi) Barrier breaches by client staff.
ALL THE ABOVE CAN AND HAVE ATTRACTED HSE ENFORCEMENT ACTION
AGAINST CLIENTS
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5
The Basic Faults and Failings to look for
THE SITE RADIOGRAPHY CONTRACTOR
(i) No adequate documentation taken to site – for reference.
(ii) No or inadequate emergency equipment for Gamma Radiography.
(iii) No or inadequate monitoring equipment.
(iv) No or inadequate individual film badges/dosimeters.
(v) No or inadequate barriers/warning signs/warning lamps.
(vi) No or inadequate Key Control of X – Ray Control Unit.
(vii) Damaged equipment/ No spares for equipment on site (e.g. Spare
batteries/spare warning lamp bulbs).
ALL THE ABOVE HAVE BEEN OBSERVED TIME AFTER TIME AND WILL ATTRACT
HSE ENFORCEMENT ACTION
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A CLIENTS BASIC CHECKING/MONITORING TECHNIQUE
NOTE : YOU DO NOT HAVE TO SEE THE SITE RADIOGRAPHY IN PROGESS
FOR YOU TO JUDGE THE CONTRACTORS COMPETANCE AND WETHER THEY
SHOULD REMAIN ON YOUR SITE.
CHECK OPPORTUNITY ONE
.
On arrival have a member of the security/site staff check the contractors vehicle –
Ask to be shown the documentation, the monitors, personal film badges, spares and
Gamma Emergency equipment . Anything missing then they do not come on site!!
CHECK OPPORTUNITY TWO
Get the contractor to set up their equipment and check it before they start the work.
You can check their monitors, film badges etc – then they can continue only after
your check.
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6
Other Basic Hazards involved
WORK AT HEIGHT
Gamma radiography – 70’ above the
ground
Technique writers were not going to do
the work
No trial run planned
On trial run – source stuck out 7 out of
10 attempts
Re-think / Re-Planning / New Equipment
X-Ray radiography – 15 – 30’ above the
ground
Technique writers were not going to do
the work
Only Safety Equipment – Giraffe steps up
to wing and tail working areas
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Has Work at
Height safety
been
considered in
the
contractors
‘prior risk
assessment’
and ‘local
rules’?
MANUAL HANDLING
Has manual handling been
considered in the
contractors ‘prior risk
assessment’ and ‘local
rules’?
The Problem – heavy x-ray tube
The Solution - Mobile carrier
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EXCAVATION SAFETY
Has excavation safety
been considered in the
contractors ‘prior risk
assessment’ and ‘local
rules’?
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7
Sources of Information
Ionising Radiations
Regulations 1999 Approved
code of practice and
guidance.
Radiation safety for site
radiography Engineering
Construction Industry Association
1996 ISBN 0 903393 86 7
Series Legal Series Code
L121
ISBN 9780717617463
HSE information sheet Industrial radiography
- managing radiation risks Ionising Radiation
Protection Series No. 1(rev 1)
Radiation doses: Assessment and recording
Ionising Radiation Information Sheet
IRIS2(rev) HSE Books 2000
www.hse.gov.uk/radiation/ionising/index.htm
New and expectant mothers at work: A guide
for employers HSG122 (Second edition) HSE
Books 2002 ISBN 978 0 7176 2583 3
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8
Summary and Any other Questions ?
Over the years several serious incidents have been caused by the failure to
maintain equipment, to carry out routine monitoring or
to employ proper emergency procedures.
A significant number of NDT contractors fail to adopt routine working
practices capable of keeping radiation exposures of employees as low as
reasonably practicable: this is the main requirement of IRR99.
Incidents occur because of poor job planning (most notably with site
radiography), failure to use adequate local source shielding, or inadequate
systems of work
Too often, clients (or main contractors) can cause difficulties for their
contractor by not allowing sufficient time or ensuring effective
communication to plan work properly. There is rarely a valid reason for
calling in an NDT contractor at the last minute. This work is normally a vital
part of a quality assurance process and should be carried out in a carefully
planned way.
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8
Summary and Any other Questions ?
The Client must manage this work process.
All they have to do is apply the same management principles as they would
towards any other construction/health and safety process
A Client must Justify, Notify and Manage/Supervise site radiography
A Client can monitor and assess the contractor without the work being in
progress
Client staff can be easily trained to do this.
Effective Client management will vastly improve site radiography standards and
safety.
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THANK YOU FOR YOUR ATTENTION
AND REMEMBER
Working in partnership with Lincolnshire County Council