James Taylor , Principal Specialist Inspector ( Radiation ) in the Health and Safety Executive ’ s Radiation Team , discusses HSE ’ s proposed changes to the RPA Statement and implementation of recommendations arising from the IAEA IRRS mission to the UK in 2019 .
Amendments to the RPA Statement HSE ’ s RPA Statement specifies HSE ' s Criteria of Core Competence for radiation protection advisers ( RPAs ). The criteria cover both individuals and bodies that wish to give advice as RPAs . The Statement also includes the specific requirements that Assessing Bodies have to meet to be recognised by HSE for the purpose of assessing the competence of individuals to act as RPAs .
This Statement had not been revised for some time and included references to legislation that was no longer in force . It therefore needed updating and , in light of some concerns about the quality of RPA advice and the burdens placed upon those seeking or renewing a Certificate of Competence to act as an RPA , some revisions to the Statement have been proposed . These revisions include refocussing on the true nature of RPA competence i . e . to give advice on compliance with the Ionising Radiations Regulations 2017 ( IRR17 ) and the Radiation ( Emergency Preparedness and Public Information ) Regulations 2019 ( REPPIR19 ). This means that advice on compliance with IRR17 should form most of the evidence required for the recognition or review of competence to act as an RPA . Additionally , in order to reduce duplication and burdens , changes in the weight any Assessing Body should give to professional membership / qualifications when assessing competence is included in the revision .
Following agreement with the Office for Nuclear Regulation ( ONR ) the revised Statement was issued for consultation .
Responses to the survey have been analysed and show that 75 % of respondents are in favour of the changes made in the revision and the emphasis placed upon advice given on IRR17 . There was , however , some concern expressed about the need for a detailed understanding ( DU ) of REPPIR and the competence requirement is likely to be downgraded to basic understanding ( BU ) in the final published revised Statement .
HSE will be undertaking further consultation with ONR and , once HSE senior management approval has been given , the revised Statement is likely to be published in summer 2021 .
IAEA Recommendations At the request of the UK Government , the International Atomic Energy Agency ( IAEA ) carried out an Integrated Regulatory Review Mission to the UK in October 2019 to assess the entirety of the UK ’ s regulatory structure for nuclear and radiological safety against IAEA standards . Following that mission , the IAEA made a number of recommendations , some of which fall to HSE . Principal amongst these was the need to require those seeking consent under IRR17 to submit a Safety Assessment ( SA ) to HSE , which would be reviewed and the practice inspected prior to consent being granted .
HSE is looking into how the recommendations can be implemented but at present it is likely that those seeking consent will be required to submit an SA for review . It is also likely that those already granted consent will be required to submit an SA for review to enable their consent to continue . Timescales and fees for these changes have yet to be determined , but if the recommendation is followed , the new system will commence in 2022 ( subject to formal consultation ) and the fees for consent will be substantially more than the £ 25 currently charged . Of course , whatever system is adopted , HSE will issue comprehensive guidance for those seeking consent .
32 Radiation Protection Today www . srp-rpt . uk