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Posted By Ian D. Has anyone applied for registration (HASS) for sources of similar potential. What is the deadline for applying, I have been told March 08, however the application has to be in 4 months prior top this deadline.
This is not quoted in the guidance June 07
Any help appreciated
Ian
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Posted By Darren (Daz) Fraser
The deadline you are referring to is for those who keep HASS sources. That's for the individual source, not your entire holding. My understanding is, if each individual source is below the threshold limit, but your entire holding is above the limit, you will not be required to register. You do need to take into account however, the security requirements of the HASS Regulations. There is no timetable for compliance with the security requirements, basically, if you needed to vary your registration for any reason, you would need to confirm you complied with the security requirements in your application. Other than that, the EA will progressively require companies to vary their Registrations to meet the security requirements.
It may be useful to consider the security requirements you'll need in place and advice on this can be found in a booklet "Security Requirements for Radioactive Sources", This is available only from your local constabulary Counter Terrorist Adviser. Also search the security services website for additional information that may prove useful.
If you have not done so already, contact an independent Radiation Protection Advisor (RPA) for further guidance and advice.
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Posted By Taff Hi Ian ,
If you are an existing user of radionuclide's and they have an activity that makes them a HASS for registration purposes then you need to to this now. You should have already received a visit from NaCTSO to review your security arrangements.
If you are unsure if your sources are HASS after consulting the guidance then I would suggest you contact your RPA for further advice.
I have already been through this process and it's pretty straight forward. Contact me if you have any specific questions and I'll try to help you out.
Taff
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Posted By John Donaldson Ian,
You don’t say what type of organisation you work for.
If you are in the education sector you will encounter problems when it comes to setting up the “bond”. The bond is causing lots of problems for the HE sector.
I would suggest you have a word to your Environment Agency Inspector.
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Posted By Ian D. Thank you all for the responses
We do not come under the HASS regs due to the activity level, but come under the security aspects due to the similar potential phrase.
We have already had the security visit, I heard though unofficially that the deadline for similar sources was March, I have approached our RPA can they can not confirm as yet
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Posted By CT The following is an extract from the notes of the 'Small Users Liaison Group' meeting of 26th June'07. The full notes can be found at : http://www.srp-uk.org/sulg28.pdf'Owners of High Activity Sealed Sources (HASS) must apply for a HASS registration before 1/9/07 if the source has been held before 1/1/06 in order to ensure that they are in possession of a valid registration before 1/1/08. The Environment Agency will remove all HASS sources from older registrations for such sources by the end of the year. As a consequence anyone who has not applied for a new HASS registration for these sources will be in breach and liable to prosecution. It should be remembered though that a HASS will remain a HASS through its decay process until its activity drops below the Exemption Values in the Basic Safety Standards Directive. The security category however will change ccording to the D values as published in the ACPO/CTSA guidance document. New D values for security classification have been issued, the majority remain unchanged however users should be aware of changes that may affect them. All currently registered HASS users need to have informed the Environment Agency of the financial provision they have in place for source disposal by the end of the year. It was noted that SEPA and EA are currently interpreting the HASS Directive differently in terms of the annual reporting requirements. The EA are moving towards the SEPA approach of requiring annual reports to be made on a fixed date, probably 1st January.' regards, CT
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