Radiation Protection Today Autumn 2024 Issue 7 | Page 9

SOAPBOX

Radiation Risk Assessments are getting too long !
Deputy Editor Maureen McQueen shares her frustration at the level of information some people include in their RRAs .
A Radiation Risk Assessment ( RRA ) is required by Regulation 8 of the Ionising Radiations Regulations 2017 :
“ An employer , before commencing a new activity involving work with ionising radiation in respect of which no risk assessment has been made by that employer , must make a suitable and sufficient assessment of the risk to any employee and other person for the purpose of identifying the measures the employer needs to take to restrict the exposure of that employee or other person to ionising radiation .”
The Approved Code of Practice ( ACoP ) identifies that the RRA has to be documented , kept up to date and discussed with workers . It is this latter part that makes me so annoyed when RRAs become excessively long . In order to be discussed with workers ( and to be of any practical use ), an RRA must get to the point and be clear about the risks involved , and the steps to be taken to minimise exposure . Paragraph 70 of the ACoP says that the following matters should be “ considered ” when making the RRA “ where they are relevant ”. Some people interpret this as meaning that everything must be documented . What really matters is that everything is considered and the items documented are those that are relevant and required .
The radiation protection programme and procedures of an organisation or technical assessments can address many of the issues which are required to be considered in an RRA , such as designation of areas , local rules ,
Radiation Protection Today Autumn 2024 dosimetry requirements , arrangements for classification of workers or for pregnant workers , instructions on use of equipment , training requirements , etc . In such cases , it should not be necessary to reiterate all of these arrangements on an RRA – in fact , doing so is likely to detract from those issues which are unique to the RRA , and need to be addressed and discussed with the workers . It is only necessary to consider them and make sure that the arrangements in place are appropriate .
The most important pieces of information that both the RPA and workers will need to know , and which therefore need to be documented , are : the likely sources of radiation ; assessments of potential dose rates , contamination levels and airborne contamination ; previous doses for similar work ; and how work will be controlled to minimise radiation exposure and risk , as well as foreseeable events . The RRA should really address what the specific hazards associated with that work are ; consider whether the radiation protection programme and procedures are adequate for the work ; and document the additional measures , such as engineering controls , dosimetry or mock-up training , which are required .
So , let ' s not make the RRA so long that it becomes an impossible document to read and digest , and states the obvious which is documented and communicated elsewhere . Let ' s make sure we focus the RRA on what really matters and what it is that the worker needs to know . If we keep it succinct , but full of real content that is relevant , then there is more chance that it will be understood and most importantly , followed . It seems to me that sometimes we try so hard to prove that the RRA is suitable and sufficient by documenting everything in the ACoP that we have lost the real meaning of what the RRA is trying to do - identify the risk and protect the worker .
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