HSE Inspections of Schools With Radioactive Sources: What to Expect
HSE are conducting stringent and detailed inspections regarding the management of radioactive sources in schools
As we reported in issue 36, the Health and Safety Executive (HSE) will be conducting health and safety inspections on the safe management of radioactive sources in school science.
The HSE plans to visit around 90 schools.. In collaboration with CLEAPSS, HSE agreed that where school employers choose CLEAPSS Guide L93 this is sufficient to meet the requirements of the Ionising Radiations Regulations (IRR17).
What We Know So Far
RPO's in some schools are reporting that the inspections are proving to be very stringent. In some cases, even minor non-compliances, which once would likely have resulted in either verbal advice or a letter, are resulting in a Notice of Contravention (NoC) being issued. As a result, the fees for intervention (FFI) scheme applies, and charges are being made for the inspector’s time on site and time spent writing the NoC. These can be quite considerable because the current rate for FFI is £163/hr.
What Schools Can Do to Avoid Fees for Intervention
Handsam's radiation advisor Jon Fear (Hons), MSRP has identified a number of strategies which could mean the difference between a pass and a hefty fine;
- Ensure that each radioactive source you have is given a unique identification number. This applies even if you have a modest inventory, and it is easy to distinguish your sources apart. The sources’ i.d. number must be marked either on it (where possible) or its container;
- Prepare an inventory list for all your sources. The inventory must include the following information for each source you hold – source identification number; radionuclide, activity at a specified date (in becquerels, not curies - the activity when new will suffice), date of receipt, location, CLEAPSS Type number. Photos of sources are also good to have;
- Ensure a source history form (Section 16.4, P90 of the CLEAPSS L93 Guide) has been completed as far as possible for each source you have;
- Ensure that absolutely nothing apart from the radioactive sources is kept in the source storage cabinet.
- Ensure that your SOP, risk assessments and contingency plans are taken from the latest version of the CLEAPSS L93 Guide (November 2019 with minor revisions September 2022);
- Ensure you have a copy of CLEAPSS Guidance note GL016 on file and kept with the SOP, risk assessments and contingency plans;
- If specific instructions in these documents are not relevant to the sources and work in your school, the document in question must be modified to remove reference to that source/instruction. For example, instruction 3 of the SOP refers to practical work carried out by students. If this does not happen at your school, remove this instruction, and insert a note to that effect;
- Ensure that there are no discrepancies in your documentation. For example, if your contingency plan refers to a particular person dealing with an incident, make sure the SOP and risk assessments concur with this and do not each reference different persons carrying out the same task;
- Ensure that you comply exactly with the instructions given in the relevant CLEAPSS Model Risk Assessments (Section 6.7). For example, ensure the instructions regarding storage and labelling are followed to the letter;
- Do not keep and use any sources that are not part of the CLEAPSS Standard School Holding;
- If you have a “Cooknell Apparatus” (radon-220 generator – CLEAPSS Type 11), the risk assessment refers to FFP3 masks being available in the event the bottle splits and gas mantles release fragments. You must make sure you have these masks and that persons who may need to use them have been face fit tested. CLEAPSS Guidance GL310 may help in this respect;
- You must ensure staff that use the sources have been trained and that training has been documented. Training must include familiarisation with the practical elements of working with the sources as well as awareness of the relevant management documentation (SOP/risk assessment(s)) and include your emergency (contingency) plans;
- If post-16 students are carrying out practical work with the sources, you must make sure they are trained and that their training is documented. The template provided in Section 16.5 of the CLEAPSS L93 Guide can be used to document this; and
- Your contingency plans must account for staff unavailability. For example, if following an incident, the plan says, “contact the RPS”, what will you do if the RPS is absent or not available? It is a good idea to name someone who can act as a deputy. This person must be trained so they can act in the way the plan asks them to.
Practical Rehearsals
The HSE seems to be saying that practical rehearsals of your contingency plans should have been carried out and documented. This contradicts with what CLEAPSS have been told by them. Their understanding Is that practical rehearsals of contingency plans in schools are not necessary. Table top exercises are still required and need to be documented.
Contact Handsam
Please contact HANDSAM if:
You have sources in storage awaiting disposal. HSE requires a risk assessment to be provided for such sources andHandsam can advise on this;
As the UK Radon Atlas has recently changed (December 2022), you should echeck the radon potential of the area your school is in by entering its post code at https://www.ukradon.org/information/ukmaps If the radon potential is >1%, contact Handsam.