So , are there any issues ?
Where sites have existing consents , you may think that they should have the appropriate working framework in place to ensure legal compliance . However , as with any change , there have been challenges faced by employers :
Awareness – Getting the message to the dutyholder is always a challenge . This includes the additional cost implications of submission and the risk of having a consent revoked if the application is unsuccessful .
Understanding – Employers are often not those directly working with ionising radiation , so comprehension of what is required can be challenging . This includes ensuring the allocation of sufficient time and resources to the submission and , where necessary , seeking relevant and appropriate advice from their RPA to facilitate completion of the SA . When contacted by HSE , employers only have three months to submit their reapplication , and time flies .
Magnitude – Employers are required to submit a single consent application and SA for multiple fixed sites . If one site incurs a material breach , HSE can revoke the consent for all sites
Viability – The new consent programme is required to be cost neutral to HSE . With the increased level of detail submitted in the SA requiring review , and the need for HSE to carry out site inspection , the application fee for consent has increased from £ 25 to between £ 2K and £ 5K . Veterinary sites incur similar costs from the Environment Agency for their radioactive substances regulatory permits . This additional cost has resulted in some sites considering the viability of continuing work with ionising radiation .
Whilst there have been some issues and challenges faced by the veterinary sector following the changes to the consent process , in my opinion a more robust and detailed overview of work undertaken on each and every site that a consent applies to can only be a good thing . The SA poses questions and requires evidence of understanding , justification of practices and oversight at the level of both site and dutyholder . This emphasises the importance of dutyholder engagement and ultimate accountability .
34 Radiation Protection Today www . srp-rpt . uk