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Posted By Liam T
All
Is there a requirement, under IRR '99, to record dose of those employees who are not designated classified workers (likely to recieve less than 6mSv per year), that do work in radiological areas.
Im sure I know the answer (after reading the IRR99 - "no"). My query is, without recording the dose, how do we know they are actually receiving less than 6mSv.
Thanks
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Posted By Kevin Drew
Regulation 21(3) requires that a formal dose record is maintained for classified radiation workers by an ADS specifically approved for that purpose. The ADS for record keeping will ensure that all assessed doses are poperly recorded and summed and will also help to ensure that a dose history is obtained for said person.
A formal record is not required for non-classifed workers but you still need to monitor/assess personal doses to ensure that they stay below the 6mSv per calendar year criterion.
Hope this helps
Kevin Drew
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Posted By Liam T
Thanks Kevin.
That seems straight forward. My concern is for employees who are moving from site to site, I feel there may be issues with their dose monitoring, due to them not having an ADS / passbook.
Do we have any RPA's / Dose Managers / RPS's etc on this site, im relatively new?
Thanks again Kevin.
Liam.
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Posted By John Donaldson
Liam,
Although it is no a requirement to badge radiation workers who are not Classified, most universities badge all workers who are working with both open and closed sources.
This is done to provide reassurance and to ensure that the work is being carried out in accordance with the Local Rules and Schemes of Work.
I hope this is helpful
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Posted By Liam T
Thanks that does help.
In particular, the site im on insists all workers within the controlled area (whether classified or non classified) wear film badges to capture all dose (and is recorded within the on site ADS)...due to it being one of the 'dirtiest' sites in Europe.
This isn't a problem. Ive been asked to look at the 'company' procedures (UK wide). The problem arises when employees are moving across the UK to other nuclear sites, accumulating dose on just EPD's and not film badges, and obviously not being recorded through any ADS.
What im thinking is to make a standard dose recording system for my company for non classified persons, to ensure they dont breach the "6 mSv" limit (or three tenths of any site limit).
Does this sound reasonable and in compliance?
Many thanks,
Liam
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Posted By Paul Leadbetter
Liam
What does your RPA think?
Paul
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Posted By Liam T
Paul
The RPA on my site is client based, so not really in a poisition to talk about a company issue.
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Posted By Paul Leadbetter
Liam
Is your company a 'radiation employer'? If so, you should surely have your own RPA.
Paul
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Posted By Liam T
Paul
The site im on, the client is the radiation employer, therefore use the clients RPA.
On other sites we dont employ classified workers due to the low dose implecations.
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Posted By Jim Walker
So......... is the RPA who looks after your staff aware they are getting a dose (however small) elsewhere??
Most Nuclear sites operate a max limit way below the legal one. Contractually you need to conform
If I've understood your situation correctly i think you need to investigate if you need your own RPA.
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Posted By Kevin Drew
Liam,
First of all the 6mSv is not a "limit". The annual dose limit is 20mSv for both classified and non-classified workers. If you think one of your employees is likely to exceed 6mSv in a calendar year you should classify them.
Secondly, not many radiation employers in the UK take too much notice of the 6mSv but rather insist on classification at potentially much lower doses so as to allow for any accidental or unplanned exposures. Many sites insist on classiifed workers only and some will only let non-classified workers perform the most trivial (radiologically speaking) of tasks in controlled areas at lower designations. As a result of this there are arguably many more classified workers than actually required by the Regs. If you examine the UK dose statistics, only a handful of workers recieve more than 6mSv which supports this view.
Thirdly, a few years back there was an initiative by the HSE to reduce the number of classified workers. This was because many workers were only classifed because it was 'administratively convienient'. If you go to visit some sites it is easier to gain access to perform tasks if you are classified rather than non-classified. As a result of the initiative many middle management grades and above were declassifed because they were never ever going to get 6mSv (because they never got out there and did any real hands-on work). The effects lower down the tree were minimal.
There is still a lack of tolerance on many sites of non-classified workers and you will often be bullied into classifying workers who arguably you don't need to. Still if you want the work.......
Hope this helps
Kevin (RPA, CMIOSH, etc, etc)
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