Experience of implementing the new RADAN consents regime in the veterinary sector
Sarah Dorling is an RPA , RWA and MPE with Stephen Green & Associates . This article gives an overview of requirements of the new IRR17 consents regime introduced by HSE in October 2023 , and discusses practical implications for the veterinary sector .
Following recommendations by the International Atomic Energy Agency ( IAEA ), the Health and Safety Executive ( HSE ) changed some of the processes associated with the Ionising Radiations Regulations 2017 ( IRR17 ). In October 2023 , HSE launched RADAN , the new regulatory on-line portal . For IRR17 registrations or consents granted before 1 October 2023 , HSE requires additional information . If you had previously registered for the use of X-rays , you should transfer your registration onto the RADAN system . Until such time as HSE contacts you , existing consent ( s ) will continue to apply . previous system . The primary purposes are to enable the employer to determine if an adequate level of safety has been achieved , as defined in IRR17 , and to give assurance to the regulator that compliance with IRR17 is , or can be , achieved and maintained . All those requiring consent will have to submit a Safety Assessment ( SA ) for review and inspection prior to consent being granted . A fee will be charged , based upon the time taken by a Radiation Specialist Inspector to review the SA and inspect the practice . Consents , if granted , will be valid for five years and most HSE enforcement will be based on the ' permissioning document '. The practice must be carried out in accordance with the SA and the conditions of consent . If it is not , HSE may revoke the consent . The consent application requires submission of the completed appropriate SA template ( examples of which can be found on the HSE website ), the site ' s local rules and contingency plans . The SA template is divided into 14 sections , each requiring a detailed response .
The consent categories are based on ' specified practices ' of which there are currently eight , most of which do not apply to the veterinary sector . There are three consents that in general do apply ( in order of likelihood ):
( i ) the deliberate administration of radioactive substances to people or animals for medical or veterinary diagnosis , treatment or research
( ii ) operation of an accelerator , except an electron microscope
( iii ) the deliberate addition of radioactive substances in the production or manufacture of consumer products or other products , including medicinal products
The consent process , whether initial application or reapplication , requires significantly more detail than under the
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