Rank: Super forum user 
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I have a situation with a powder substance that is mildy alpha particle radioactive. We already have extensive controls over inhalation so users are fully protected. I am considering whether to record this on the COSHH assessment but, as the HSE website says, radiation is not covered under COSHH; it has its own regs. That said, if you look at reg 5.1b it is only exempt due to 'where the substance is hazardous to health solely by virtue of its radioactive...properties' and our substance is hazardous due to other properties.
I want to record this radioactivity so now I need to decide how. I think I need to rename my COSHH assessments 'hazardous material' assessments and include it that way. If I do then I can include lead, asbestos (not applicable to us) explosives, flammables and DSEAR.
Has anyone else had to deal with this situation?
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Rank: Forum user 
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With regard to the radiation, I think you have already answered the question for yourself - why not just put a note on the CoSHH assessment to the effect that the substance is radioactive and cross refer to a radiation assessment.
Then complete a suitable assessment for the radiation aspects of the material.
As regards the DSEAR - depending upon the quantity of the substance, work processes, material properties, ventilation - your DSEAR assessment is likely to consider different issues than your CoSHH assessment.
While its understandable to try and combine the assessments into one document - you might well end up with quite a length (and possibly confusing) document.
Would you not then extract the key points & controls for the troops on the shopfloor to read & understand/provide training for etc
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Rank: Super forum user
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Without having all the detail the basics are these;-
Where Radiation exists [irrespective of where it is found etc] it [the radiation] becomes the primary situation so a substance that is radioactive falls primarily under radiation law where there could be a secondary situation i.e. it is also a substance which could come under COSHH
Don't forget your disposal regs and similar as the disposal will most likely be as a radioactive substance and not just a COSHH substance
Keep your names etc but ensure that your cross referencing system is correct and consult your RPA. If you have not got an RPA and you are dealing with a radioactive substance you need to take advice
'Mildly radio active': Whilst differing types of radiation carries with is differing names etc it is all radioactive and should be treated as such. I would not use the term 'mildly radio active' I would use the official term for the substance being discused
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Rank: Super forum user 
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I haven't needed to assess radioactive substances, but for a simple small-scale process have often completed a "risk assessment" that covers both COSHH and fire risks of flammable substances - I don't see any reason not to do so unless it is going to be more complicated that way (which will depend on your particular situation). It doesn't matter what the title on the top of the document is, so long as you can point to the required assessments.
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Rank: Super forum user
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The radiation hazard in this instance is only in the event of inhalation of the powder and then exposure to the surrounding tissue in the lungs.
Exposure to radiation in this case is not an issue via the skin or external to the body.
Employ engineering control methods and include radiation exposure via inhalation in the COSHH RA
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Rank: Super forum user
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In my personal opinion Bleve has basicially got it. However that I believe that the radation RA would be the primary RA doc re the radioactive parts of the substance with an additional reference / comment etc in the overall COSHH RA/RA's for that area so as both areas are then covered in an appropriate way
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Rank: Forum user
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"a powder substance that is mildy alpha particle radioactive"
I'm guessing this must be naturally occuring radioactive material (NORM) of some description? In my humble opinion, as a Radiation Protection Adviser (RPA), you need to produce a radiological risk assessment (RRA) in accordance with the Ionising Radiations Regulations 1999 (IRRs). I have worked for organisations that have tried to produce combined COSHH/DSEAR/Lead risk assessments and in my experience they don't work. They become too cumbersome and don't really cover any of the hazards adequately. Trying to morph a radiological risk assessment into a COSHH assessment, etc is one step too far. Produce separate COSHH and RRA documents as part of your SSoW. It isn't that uncommon in the nuclear industry to have separate COSHH, DSEAR and IRR risk assessments for a single task. The fact that your control measures for COSHH and IRR maybe one and the same is no excuse.
Additionally, there maybe implications under what was the Radioactive Substances Act (RSA) but which was changed to the Environmental Permitting Regulations in April of this year. It maybe that one of the multiple Exemption Orders to the Act apply to your undertakings? What is the specific activity of the powder?
It is worth stressing that alpha particles represent the most significant internal radiation hazard of all ionising radiations. You must approach your RPA if you haven't already done and seek their advice.
Apologies for the acronym overload.
Kevin
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Rank: Super forum user
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I do not see the point in having two or three separate risk assessments when one would be S&S under law.
We have an activity involving the handling of a substance, there may be hazards and risks associated with the storage, use and disposal of this material or any other for that matter that can quite readily and simply be set out within a single r/a document, there in many cases will be common control measures and the hierarchy of control will typically apply regardless of the statute being applied.
This approach results in a single point of reference and makes things easier for individuals to understand. Multiple sources of information have the potential for an error to occur.
Legislation requires for significant hazards to be identified and assessed, there is no legal requirement for multiple assessments.
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Rank: Forum user
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Having also been a RPA at one time I would entirely support the advice that Kevin has given
I might just add that the present range of Exemption Orders are due to be consolidated and I think its fair to say no one is exactly sure what the outcome will be.
Also it is worth noting that in Scotland, SEPA does things somewhat differently to the Environment Agency in England
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Rank: Super forum user
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Ultimately, there are no requirements under law to carry out duplicate r/a. It is a simple matter to cover the requirements of multiple statutes under a single RA. I cannot see how anyone can say multiple asessments dont work when they have been accepted by enforcement agencies throughout the worl.
Back to basics, keep things simple and short etc
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Rank: Super forum user
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M,
In response to your original question, you can call your asse3ssmentsa what you like. As long as they contain a sufficient & suitable content to meet legislative requirements there is no issue.
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Rank: Super forum user
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Duplicate Risk Assessments / multi law's in one RA:
As I see it each law requires its own risk assessment e.g. Fire = a fire RA, First aid = a FA RA, COSHH = a COSHH RA and so on
We have gone down the route in the past of looking to combine simple situations under 1 RA but have found that in a court situation a claiments 'brief' can easily distroy this style of working. However it is very easy to have a very simple cross referencing system that moves a person from one RA to another so all areas in any given situation are easily identified. Additionlally concentrating on one subject at a time allows for a quality product as RA 'drift/creep' can sometimes take place when combining many laws and subjects in 1 RA
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Rank: Super forum user
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Guess it what ever works for you at the end of the day (horses for courses) etc.
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Rank: Forum user
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I always encourage people writing risk assessments to keep them as simple and succinct as possible - we are all guilty of over complicating things on occasions.
Chemicals, radioactive materials, asbestos, lead, explosives, etc are all hazardous materials and I would love to be able to write one risk assessment that covers everything. Unfortunately, the assorted regulations that cover these substances are significantly different and have different requirements. For a fairly simple low hazard task it is possible to write a suitable and sufficient risk assessment that covers everything. It maybe that the task that "m" has described is one of those simple tasks?
However, due to my training and experience, I'm naturally cautious about working with alpha emitting powder for the reasons described above and would recommend a separate radiological risk assessment.
Furthermore, despite the HSE allegedley encouraging a "holistic approach", when the inspector calls this isn't the case as I have found out to my cost. Essentially, we were served with an improvement notice for not having a specific WRULD risk assessment when the basics were covered by a simple risk assessment but thats another story.
Kevin
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Rank: Forum user
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I think its also worth adding the Environment Agency Inspectors are very pedantic when it comes to looking at arrangements for handling and disposing of Radioactive Substances.
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Rank: Forum user 
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I have to agree with Kevin in regards to the separate need for assessments. The requirements under the radiation risks must be covered to satisfy the Ionising Radiation Regs which will also need to cover disposal issues. These requirements are likely to be more stringent than the COSHH legislative requirements (having worked in the nuclear industry). I would also echo Kevin's concerns about alpha emitters. Outside the body they represent a low risk but once they enter the body then they present a significant risk (having done risk assessments in relation to alpha emitters).
Bill
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