Control of radon in
the workplace
Policy and local rules
Version 1.0
Environment, Planning and Economy
Directorate
Control of radon in the workplace
Policy and local rules
Policy
3
Introduction
4
Legislation
4
Responsible persons
4
Monitoring
7
Control of exposure
8
Mitigation
8
Test protocols
9
Detector management
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2
POLICY
Policy
1.
It is the policy of Cornwall Council to comply with the requirements of
the Ionising Radiation Regulations (1999) (IRR) and assume the role of
radiation employer, in accordance with regulation 2(1), where it has
been identified that workplace atmosphere’s containing radon 222
exceed those concentrations given in regulation 3(1)(b).
2.
In accordance with the legislation the Council takes upon itself to:
• Appoint a radiation protection advisor
• Assess and monitor the risks
• Protect and inform employees
• Reduce or manage doses
3.
Implementation of this policy is established through the Council’s local
rules (regulation 17(1)) and operational procedures.
4.
Those parties fulfilling the statutory duties in accordance with the
interpretation provided in the IRR (regulation 2(1)) are:
• Radiation employer: Chief Executive, Cornwall Council, County
Hall, Truro, Cornwall, TR1 3AY
• Radiation protection supervisor (RPS): Soils and Materials
Engineer, Engineering Services Laboratory, Radnor Road, Scorrier,
Redruth, TR16 5EH
• Radiation protection advisor (RPA): Radiation Protection Division,
Health Protection Agency, Chilton, Didcot, OX11 0RQ
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LOCAL RULES
Introduction
5.
This document forms the local rules, in accordance with regulation
17(1) of the IRR (1999), describing the Council’s protocols and
procedures for complying with its policy for controlling the levels of
radon within its properties.
Legislation
Current legislation
6.
Exposure to radon will be controlled within council properties in order to
conform to the Health and Safety at Work Act and the IRR.
7.
The regulations shall apply to any workplace which exceeds those levels
cited in the IRR 3(1) (b), which states that “any work (other than a
practice) carried out in an atmosphere containing radon 222 gas at a
concentration in air, averaged over any 24 hour period, exceeding 400
Bq m-3 except where the concentration of the short-lived daughters of
radon 222 in air averaged over any 8 hour working period does not
exceed 6.24 x 10-7J m-3”.
Monitoring changes to legislation
8.
Both the health, safety and wellbeing manager and the RPS are
responsible for the continual monitoring of any changes to UK
legislation and current good practice. This will be done through regular
contact with the Health and Safety Executive, the radiation protection
advisor, internet access, purchase of relevant publications/journals and
attendance of training/refresher courses.
Dissemination of information
9.
Relevant council staff will be notified of any changes to the radon
legislation and approved code of practice(s) through the provision of
staff training, articles in council newsletters and intranet site and the
cascading of information from senior council officers to their
subordinates.
Responsible persons
General
10. This document identifies the responsibilities of both individuals and
sections within the Council in compliance with the IRR. It covers the
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duties relating to all aspects of the statutory instrument, with specific
reference to controlling the levels of radon within its properties as a
radiation employer in accordance with regulation 2(1).
Statutory responsibilities
11. RPA; the radiation employer shall employ the Health Protection Agency
– Radiation Protection Division (HPA) as its statutory radiation RPA in
accordance with IRR regulation 13.
12. RPS; in accordance with IRR regulation 17(4) the head of the Council’s
engineering services laboratory (the soils and materials engineer) shall
be appointed as the Council’s RPS, for the purposes of controlling radon
in the workplace by the radiation employer.
Managerial and operational responsibilities
13. Based on the IRR the following managerial and operational
responsibilities are assigned.
14. The head of property is responsible for:
• Ensuring compliance with the requirements of current IRR and the
Council’s radon policy and local rules
• Ensuring adequate steps are taken to identify those areas in
council properties where the IRR apply
• Ensuring risk assessments are carried out wherever stated radon
levels are exceeded.
• Ensuring appropriate mitigation measures are taken to reduce
radon levels below the accepted threshold
• Ensuring that an ongoing monitoring programme is maintained
within all of its susceptible properties
• Ensuring that the Council’s radon database is maintained and
updated
• Ensuring that the private finance initiative (PFI) provider complies
with the IRR where appropriate
• Ensuring that adequate resources are made available for the
implementation of the duty
• Ensuring that any new property procured on behalf of the Council
is surveyed and appropriate actions taken to comply with the IRR
• Ensuring that all new construction(s) complies with the IRR and
relevant sections of the building regulations that relate to radon
mitigation
15. The policy and training manager is responsible for:
• Following IRR and the Council’s radon policy and local rules
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• Appointment of the RPA and RPS
• Implementing an appropriate testing, monitoring and mitigation
regime for all susceptible council properties
• Maintaining the Council’s radon database
• Organising a regular audit of the Council’s radon database and
reporting to the corporate director for resources
• Undertaking a regular review of procedures
16. The construction services manager is responsible for:
• Following IRR and the Council’s radon policy and local rules
• Managing the Council’s financial radon budget
• The design, construction and supervision of radon mitigation
measures in conjunction with the RPS and RPA
• Maintaining, updating and replacing existing radon mitigation
measures as appropriate
17. The health, safety and wellbeing manager is responsible for:
• Following IRR and the Council’s radon policy and local rules
• Ensuring that all aspects of the managing of radon is performed in
a practical and safe manner and that all the current health and
safety legislation is adhered to
• Monitoring the performance of the Council’s radon policy and
procedures
• Liaising with the RPA and Health and Safety Executive on all
matters relating to radon
• Monitoring for changes/amendments to the current legislation and
disseminating the information to all relevant parties
• Auditing the PFI provider(s) to ensure their compliance with the
current IRR
18. The soils and materials engineer is responsible for:
• Following IRR and the Council’s radon policy and local rules
• Acting as RPS on behalf of the radiation employer
• Liaising with the RPA on all matters relating to radon
• Organising the routine radon testing and monitoring programme
• Managing, updating and reporting on the Council’s radon database
• Notifying the corporate maintenance manager of areas requiring
mitigation measures
19. The private finance initiative (PFI) provider is responsible for:
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• Complying with the IRR, approved codes of practice, appropriate
building regulations and implementing the radon monitoring
protocol as described in the project agreement
Provision of information
20. Where employees or visitors may be exposed to workplace
atmosphere’s containing radon 222 that exceed those concentrations
given in regulation 3(1) (b); they shall be informed of the hazard by the
radiation employer who shall provide support and guidance where
appropriate.
21. Information shall be provided either by personal communication,
articles in council newsletters and intranet site and the cascading of
information from senior council officers to their subordinates.
Monitoring
Methodology
22. Monitoring will be conducted on all council properties located within
areas identified as having potentially high radon levels, as presented in
the HPA document ‘Indicative Atlas of Radon in England and Wales
Report No.HPA-RPD-033 (Radon Atlas)’.
23. A prioritised programme of monitoring shall be devised through a series
of risk assessments using an algorithm based on the radon atlas;
evaluating the potential for a property to contain elevated levels of
radon and its level of occupancy.
24. The monitoring for radon shall be achieved by taking passive
measurements using CR-39 etch-track detectors following the protocols
contained in the test protocols.
25. The frequency of testing will be:
Frequency of testing
Test type
Initial
Interim
Mitigation check
Periodic
Radiation area
Purpose
To identify premises with radon
levels >400 Bqm-3
To monitor exposures in
premises with radon levels
>400 Bqm-3
Check that mitigation has
reduced radon below 400 Bqm-3
Check that mitigation remains
effective over the long term
To monitor levels in premises or
locations that are not to be
Protocol
Three month passive
Two month continuous without
interruptions
First full two month period of
interim series after completion of
mitigation works
Three month passive, biennially
Three month passive annually
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mitigated
26. All testing and monitoring will be conducted by the engineering services
laboratory (ESL) under the supervision of the RPS.
Action levels
27. Action levels for mitigation in the workplace are as follows:
Action levels
Occupancy
Action Level
(hours per year)
(Bqm-3)
>2000
≤2000
200
400
28. In residential units, mitigation will be carried out where the 45%/55%
average lounge/master bedroom level exceeds 200 Bqm-3.
29. In premises with a variety of uses, mitigation will be carried out when
the lowest appropriate level has been exceeded.
Control of exposure
30. Where areas have been identified as exceeding the action level through
testing and monitoring the RPS shall assess the situation and determine
the most appropriate action required to restrict personal exposure for
the occupants of the building.
31. Where a mitigation system is in place or its installation appropriate, the
construction services manager will be immediately notified by ESL. In
collaboration with the RPA, he shall design an appropriate remediation
system and oversee its installation.
32. Where it is deemed impractical to reduce radon concentrations through
mitigation methods, the RPS shall place a restriction on the length of
occupancy of the relevant room(s) to ensure that individual personnel
do not exceed a dose limit in excess of 1 millisievert per year.
Mitigation
Mitigation design and installation
33. The choice of mitigation systems will rest primarily on its ability to
reduce radon concentrations to below the appropriate action level.
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34. Within limits of practicability and expense the system shall be designed
to reduce radon concentrations to a level as low as reasonably
achievable.
Records and testing
35. The construction services manager shall arrange for details of the
system to be recorded on the Council’s central property database and a
planned inspection and maintenance regime put in place.
36. Once the installation is complete post mitigation testing will be
conducted to monitor the effectiveness of the system in accordance
with the testing protocol.
Maintenance
37. The contractor’s work associated with all systems will be the subject of
regular inspection by the contract manager.
38. The fans and electrical installations associated with systems will form
part of the regular electrical and mechanical maintenance programme
by the mechanical and electrical section.
39. In all buildings where systems are fitted, written instructions will be
issued to the officer in charge which will set out the following:
• Periodic checks to ensure continued operation of the system
• Periodic checks to ensure no obvious damage to the system
• Contact arrangements/telephone number(s) for repairs, enquiries
etc
Reporting
40. The RPS will provide an annual status report to the head of property
which will include the latest test results, plus an update of the property
history, system maintenance reports and recommendations for
additional mitigation.
Test protocols
General
41. All individual detectors will be placed away from major sources of
heating and ventilation.
42. Testing will be conducted in the winter months with detectors placed no
earlier than the beginning of September and retrieved no later than the
end of April unless the property is on a continuously monitored
programme (interim testing) or post mitigation testing.
43. Detectors will be placed for a nominal period of three months.
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Initial test protocol for occupational premises
44. A minimum of two detectors will be placed in each building (however
small) to avoid the problems associated with unsupported single
measurements.
45. In the case of a number of buildings of similar layout, as far as is
practicable the detectors will be placed in the same corresponding
positions in each building.
46. The major spaces chosen for testing will be those regularly used by the
largest number of people; particular emphasis will be given to areas to
which members of the public have access.
47. Under no circumstances will a single detector cover a floor area greater
than 250m2 (the largest area found by experience capable of being
drained by a single sump mitigation system in the majority of cases).
The preferred maximum area per detector will be 100m2.
48. Additional detectors will be placed in areas of potentially higher
concentration such as basements, stores and boiler rooms; particular
emphasis will be given to areas used by a few individuals for long
periods.
Initial test protocol for residential premises
49. Two detectors will be placed in each residential unit regardless of the
size of the unit.
50. The detectors will be placed in each unit of residential accommodation
as follows:
• One in the main living area
• One in the master bedroom
51. A single average figure for the residential unit as a whole will be
obtained by adding 45% of the main living area value to 55% of the
result from the master bedroom. A seasonal correction factor will be
applied to the single figure to obtain a year long average.
Post mitigation test protocol
52. Post mitigation tests will be arranged to mirror, as far as possible, the
corresponding initial tests.
53. In addition to the original test locations, further test locations may be
included to ensure that all parts of that property are below the
appropriate action level.
54. Tests of less than three months duration or outside the winter months
will only be carried out in exceptional circumstances. Results from
these tests will be treated as indicative only and the tests repeated to
the standard protocol at the earliest opportunity.
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Re-test protocol
55. Repeat tests will be carried out as far as possible in a different season
to the previous test.
56. At least 50% of detectors will be placed in the same positions as in the
previous test (s).
57. The interval between re tests in properties with mitigation systems will
remain fixed.
58. The interval between re tests of borderline properties may be increased
if repeat measurements remain below the appropriate action level.
OPERATIONAL PROCEDURES
Detector management
Handling
59. Orders for detection will be placed preferably three months in advance
of the anticipated delivery date and no later than one month before.
60. Care will be taken to ensure that standing times between delivery and
placement and retrieval and return for processing are kept as short as
possible to minimise errors in results.
61. Care will be taken to ensure that the detectors are kept in areas of
potentially low radon concentration during standing times.
Placement
62. With the exception of individual dwelling units, whose detector
placements positions are fixed, two copies of the appropriate floor
plan(s) will be sent to those placing the detectors.
63. The plans will be annotated by the RPS with the following information:
• A unique reference number for each block
• A unique reference number for each room/space in each block
• A date for the approximate commencement of the round of testing
• The rooms/spaces where detectors are to be placed
market/numbered
64. The officer placing the detectors will annotate the plans as follows:
• The exact position where each detector has been placed marked
with a cross
• The number of the detectors entered in beside the cross
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65. For each premises, two copies of a standard form will be completed by
the officer placing the detectors with the following information:
• Job title and reference
• Block number
• Room number
• Detector number
• Exact location to allow easy retrieval (if required)
• Exact date of placement
• Signature/initials of placing officer
66. The standard forms will be completed by the officer retrieving the
detectors with the following information:
• Exact date of retrieval
• Signature/initials of retrieving officer
• Additional notes such as “detector missing”, as required
67. Both copies of the drawings and the forms will be returned with the
detectors.
68. Both copies of each drawing and one copy of each form will be kept as
hard copy files.
69. A single copy of each form will be sent off with the detectors.
Prepared by:
Richard Hocking
Soils and Materials Engineer
Engineering Services Laboratory
12 February 2016
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If you would like this information
in another format please contact:
Cornwall Council
County Hall
Treyew Road
Truro TR1 3AY
Telephone: 0300 1234 100
Email: enquiries@cornwall.gov.uk
www.cornwall.gov.uk
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