Transport Radiation Risk Assessments … what you need to know
Nicola Jaynes has worked in the nuclear industry for over 30 years. She is an accredited Radiation Protection Adviser and a Fellow of SRP. She is currently the lead radiation protection inspector within the Office for Nuclear Regulation ' s Transport Competent Authority.
When thinking about radiation risk assessments( RRAs), don ' t forget transport. Also, don ' t forget that transport isn ' t only ' physical carriage ', but also comprises packing, loading, in-transit storage and unloading at the final destination.
The legal stuff Schedule 2, Part 1, Paragraph 2 of the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009( as amended)( CDG09) requires transport dutyholders to comply with the requirements of Regulation 8 of the Ionising Radiations Regulations 2017( IRR17), thereby clarifying that those dutyholders undertaking transport operations have the same risk assessment responsibilities as any other employer working with ionising radiation. This means that transport dutyholders must make suitable and sufficient transport RRAs.
These RRAs should identify all reasonably foreseeable( less than likely but reasonably possible) radiation accidents( where immediate action would be required to prevent or reduce the exposure to ionising radiation of employees or any other persons).
Schedule 2, Part 1, Paragraph 3( 1) of CDG09 requires transport dutyholders to make an adequate emergency plan for any radiation
emergencies identified in transport RRAs. It should be noted that CDG09 emergency plans must also meet the requirements of IRR17 Regulation 13, Contingency plans.
The definition of a radiation emergency includes serious consequences arising from exposure to radioactive material including consequences to human life, health and safety, quality of life, property and the environment. In most cases there are no serious radiological consequences at or below a threshold of an effective radiation dose of 1 mSv to any individual over a period of one year following the radiation emergency. Therefore, any radiation accident that could result in effective doses in excess of 1 mSv should be considered to be a radiation emergency.
Schedule 2, Part 1, Paragraph 3( 2) of CDG09 removes the requirements for transport dutyholders whose transport RRAs conclude that no radiation emergencies are possible to make an emergency plan under CDG09. However, transport dutyholders must still meet the requirements of IRR17 Regulation 13 and prepare contingency plans for other radiation accidents.
The practical stuff The Office for Nuclear Regulation( ONR) has produced guidance on transport RRAs and emergency planning:
• Ionising Radiations Regulations 2017( IRR17) Regulation 8 Radiation Risk Assessment Guidance in Relation to the Civil Transport of Radioactive Material by Road, Rail and Inland Waterway( TD-TCA-GD-003)
• Five Steps to Transport Emergency Planning
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