I'd like to get the opinion of my peers, if I may, with regards an issue we have concerning the control and safety systems of an X-Ray pit area we have within our factory.

In short we have received a annual report from our RPA that the current safety system, although working correctly (their words not mine), although when opening the enclosure door the X-Ray set stops working, when the door is closed the systems does start up again; however no X-Rays are produced as further action by the operator is required to start the set.

They suggest that we have the system checked out against the 2006 Machinery Directive and also consider fitting a new control system to ensure we have electrical wiring plans (there are none at the moment), warning lights are fail to safe,

We have taken on board their comments and are in the process of specifying improvements and a new control system to enable us to comply.

My question is and understanding the action we are taking is that are we in breach of the IR Regs and as such not legally complaint?

Thanks for reading and I look forward to hear from you soon.

Doobrifurkin

You need to confirm with your appointed RPA.

I assume that this is radiography within an enclosure using a radiation generator, rather than site radiography with radioactive sources.

For information, the following might be of use:

"In short we have received a annual report from our RPA that the current safety system, although working correctly (their words not mine), although when opening the enclosure door the X-Ray set stops working, when the door is closed the systems does start up again; however no X-Rays are produced
as further action by the operator is required to start the set".

If you go to the HSE website and do a search for "prior authorisation" you will see that the conditions to meet reg.5 IRR99 and the generic HSE prior authorisation are listed. These are important.
http://www.hse.gov.uk/ra...on/ionising/certxray.htm

"They suggest that we have the system checked out against the 2006 Machinery Directive and also consider fitting a new control system to ensure we have electrical wiring plans (there are none at the moment), warning lights are fail to safe"

reg. 8 IRR99 (Restriction of Exposure), 8(2)a states "a radiation employer shall so far as is reasonably practicable achieve the restriction of exposure to ionising radiation required under that paragraph by means of engineering controls and design features and in addition by the provision and use of safety features and warning devices"

reg. 8(2) Guidance para. 78 states "Warning devices indicate the status of the equipment in normal operation and alert operators to faults or failures which have occurred and which reduce the safety integrity of the installation. These devices will not of themselves prevent exposure but they will indicate to the equipment operators what action to take and not to take".

reg. 8(2) ACoP para. 99(c) states "for X-ray generators other than those used for diagnostic radiology, are designed to be automatic and fail-safe, ie if the warning device itself fails the exposure will not proceed".

Note reg. vs ACoP vs Guidance

Given that potential accidental exposures are likely to be life and limb threatening, difficult to argue against para. 99(c) really, as the purpose is to avoid unintended exposures if the warning lights fail. If it was me, I would take the system out of service (secure the key control) until corrected. But like I said, that is for discussion with your appointed RPA. Not sure about relevance to the machinery directive myself.

Hope that helps.