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Radiation Protection Regulations in the UK

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1 Radiation Protection Regulations in the UK
Craig Moore Radiation Protection Adviser Radiation Physics Department CHH Oncology

2 But first….. What we do in Radiation Protection
We are part of Radiation Physics Service (other half is Radiotherapy Physics) Based in Oncology CHH We provide scientific and technical support in the fields of Ionising (x-rays, etc.) and non-ionising (lasers, UV, MRI, etc.) radiation safety Diagnostic imaging physics (including equipment quality assurance) Radiotherapy metrology, treatment planning, equipment management Research & development Teaching & training

3 Who are we?? Radiation Protection Advisers Rad’n Prot’n Team
John Saunderson – x Craig Moore – x Rad’n Prot’n Team Andrew Davis, Dave Strain, Tim Wood – ext Radiation Protection website Trust Policy CP137

4 What’s the Point in Legislating?
Ionising radiation such as X-rays can cause the following effects: Tissue effects such as skin burns and loss of hair Stochastic effects (per 1 mSv) 1 in 20,000 risk of fatal cancer 1 in 100,000 risk of non fatal cancer 1 in 77,000 risk of hereditary effects Staff receive radiation doses from X-rays that scatter from the patient and radiation emanating from patient Ionising radiation is invisible so you can’t see or smell it, hence it can cause damage without you knowing about it (at first!!!)

5 The Ionising Radiations Regulations 1999 (IRR99)
Protection of Staff Public from ionising radiation

6 Enforced by the Health and Safety Executive
Authorisation Enforced by the Health and Safety Executive

7 Structure of IRR99 7 ‘Parts’ 41 Regulations 9 Schedules
Approved Code of Practice - Statutory Guidance (HSE approved) Non-statutory guidance (i.e. guidance notes)

8 Statutory and Non-Statutory Guidance
Approved code of Practice & HSE Guidance Medical & Dental Guidance Notes

9 So what’s included in IRR99
General Principles and Procedures Risk assessment Dose restriction Dose limitation Arrangements for the Management of Radiation Protection Radiation Protection Adviser Radiation Protection Supervisor Local Rules Designated Areas Controlled Areas Classification and Monitoring of Persons Dose badges Control of Radioactive Substances Duties of Employees All of us have duties under these regulations

10 Reg 7: Prior Risk Assessment
Must be undertaken before work commences with ionising radiations Identify hazards Decide who might be harmed and how Evaluate risks and decide whether existing precautions are adequate or not Record findings of risk assessment Review and revise it By Law has to be done (or approved) by a certified Radiation Protection Adviser

11 Reg 8: Restriction of Exposure
Doses must be optimised As Low As Reasonably Practicable (ALARP) Hierarchy of protection measures: Engineering controls such as the design of X-ray tubes and shielding Systems of work such as local rules PPE such as lead aprons Dose constraints (planning) 1 mSv to foetus during declared term Formal Investigation levels of staff dose

12 Regs 9: Personal Protective Equipment
Should be provided where necessary Should comply with PPE regulations Should be properly maintained

13 Lead Apron Storage Always return to hanger Do not
fold dump on floor and run trolleys over the top of them!!! X-ray will check annually But if visibly damaged, ask X-ray to check them.

14 Reg 10: Engineering Controls
All safety features of an installation must be maintained and tested at suitable intervals QA manual should spell out who does what (user, engineer, physics etc)

15 Reg 11: Staff and public dose limits


17 Radiation Dose Absorbed Dose (Jkg-1)
Amount of energy deposited per kilogram Dose to an organ or tissue Unit is the Gray (Gy) DOSE TO A CERTAIN PLACE IN THE BODY Effective Dose (Jkg-1) This is the average dose to whole body Unit is the Sievert (Sv) This gives us the risk of contracting cancer of the x ray exposure THIS IS THE OVERALL DOSE TO THE WHOLE BODY RADIATION TISSUE

18 External and Internal dose
Dose from external sources X-ray Radiation emanating from patient (Nuclear Medicine and Brachytherapy) Contamination of work surfaces etc Dose from internal sources: Ingestion Inhalation Absorption Committed effective dose Dose delivered due to deposition of radionuclide in the body

19 Reg 11: Dose Limits for staff & public (mSv) per calendar year
Effective dose 6 1 Lens of eye 45 15 Skin 150 50 Hands, legs etc Possibly changing to 6 mSv/yr in a couple of years

20 Dose Monitoring Most employees who work with radiation in a Hospital Trust have radiation monitoring badges. These monitor the exposure to radiation of an employee Doses received are assessed by the RPA to ensure they are being kept ALARP BUT, it is also an RPS duty to monitor results Please ensure your staff wear and return it promptly There have been recent prosecutions for not doing so under these regulations

21 Typical Dose Monitoring Results across the Trust
Physics: Typically less than 0.1 mSv/month This equates to less than 1 mSv/yr Much lower than legal limit of 6 mSv/yr Radiotherapy: Nuclear Medicine: Typically less than 0.3 mSv/month This equates to less than 4 mSv/yr Lower than legal limit of 6 mSv/yr Radiology: Dental: Under reg 8 we have to set dose investigation levels

22 Dose Investigation Levels
Physics: 0.1 mSv/month Radiotherapy: Nuclear Medicine: 0.5 mSv/month Radiology: 0.35 mSv/month Dental: Breast Screening:

23 Women of reproductive capacity
Refers to ‘women at work’ But 1 mSv to foetus during declared term

24 Exclusions to Dose Limits
Comforter and Carer These knowingly and willingly incur an exposure having been fully advised of the risks Not as part of their job What about the other? Persons undergoing medical exposure

25 Reg 12: Contingency plans
Contingency plan required for ‘reasonably foreseeable’ accident Radiotherapy: Emergency stop buttons In Brachytherapy if the source fails to retract during treatment: Take out applicators and place in lead pot Wire cutters may be needed in some instances! Radiology: Nuclear Medicine: Spills and contamination Plan must be documented in Local Rules Must be rehearsed at appropriate intervals dependent on: Potential severity Likely doses Complexity of plan Number of people involved Involvement of emergency services

26 Arrangements for the Management of Radiation Protection
Part 3 Arrangements for the Management of Radiation Protection

27 Reg 13: Radiation Protection Adviser
RPA must be suitably qualified Must be certified by HSE approved body Employer must consult RPA on the following matters: Implementation of Controlled and Supervised Areas (eg signage) Prior examination of plans for installations and the acceptance into service of new or modified sources of radiation in relation to safety and warning features Regular calibration of equipment provided for monitoring levels of ionising radiation Regular checking of systems of work provided to restrict exposure to ionising radiation In addition, employer should consult RPA on: Risk assessment Designation of controlled areas Conduct of investigations Drawing up of contingency plans QA programmes In this Trust: Craig Moore John Saunderson

28 Reg 14: Information, Instruction and Training
Employees must receive adequate training Risks from ionising radiations Precautions to reduce risk Importance of complying with regs Also need training under the IRMER regulations (much more physics!!!!!)

29 Reg 15: Cooperation between employers
If staff work in controlled areas of other employers (private hospitals for example) Must be able to demonstrate that total dose is less than 6 mSv/yr Improvement notice has been issued at another Trust recently Also needs to be clear which procedures staff members have to follow HEY Trust or other employer

30 Part 5 Designated Areas

31 Reg 16: Designation of Controlled and Supervised Areas
Based on risk assessment Controlled ……..if it is necessary to follow special procedures to restrict significant exposure to ionising radiation in that area or prevent or limit the probability and magnitude of radiation accidents of their effects, or any person working in that area likely to receive effective dose greater than 6 mSv or 3/10 of any other dose limit (eye, hands etc)

32 Reg 16: Controlled Areas External Beam Radiotherapy:
LINAC treatment room including the maze when the unit is switched on Brachytherapy: Whole of treatment room whilst the treatment unit is capable of sending source out Radiology & BSU: Whole room when the unit is switched on Nuclear Medicine: Radiopharmacy Dispensing room Waste Store Therapy Room Dental: 1.5m or 2 m from the patient (depending on workload)

33 Reg 17: Local Rules & Radiation Protection Supervisors
Local rules must be provided for controlled areas RPS’s must be appointed if an area is subject to local rules

34 Local Rules Local Rules must be written and adhered to for every radiation controlled area Essential contents of local rules include: Dose investigation level Contingency arrangements Name of radiation protection supervisor & Adviser Identification of area covered Working instructions Local rules may also contain management and supervision of the work Testing of engineering controls Radiation monitoring Testing of monitoring equipment Personal dosimetry Arrangement for pregnant and breastfeeding staff

35 Reg 17: Radiation Protection Supervisor
There to ensure local rules are being followed Knowledge of regulations and Local Rules Ability to command respect Understanding of precautions required and extent to which these will restrict exposures RPS must be adequately trained

36 Reg 18: Additional requirements for designated areas
Physical demarcation of controlled areas Warning signs (controlled and supervised) Entry restricted to controlled areas

37 Reg 19: Monitoring of Designated Areas
Legal requirement to monitor dose rates around controlled area at commissioning Monitoring at appropriate frequencies Monitoring recorded and reviewed Results kept for two years by qualified person Monitoring equipment maintained and tested at regular intervals Also carry out monitoring with badges stuck on walls every couple of years

38 Reg 21: Dose assessment and recording
In this Trust, anyone working in a radiation controlled area must wear a dose badge Unless the dose to this employee can be shown to be low by other means

39 Regs 27 to 30 About control of radioactive substances Reg 27: Reg 28:
Sources should be sealed if possible Containers must be fit for purpose Suitable leak tests must be carried out Reg 28: Accounting for sources Must know where all sources are at any time Reg 29: Keeping and moving of sources Suitable stores Suitable receptacle for moving Reg 30: Have to notify HSE if radioactive substance is no longer under his control

40 Reg 31:Duties of Manufacturers
Design & construct X-ray units and other articles to restrict exposure & ALARP Perform critical examination upon installation Safety features Consult RPA on crit ex Provide proper instructions on proper use, testing and maintenance

41 Reg 32: Quality Assurance Programme
A suitable quality assurance programme to be provided ensuring that equipment remains capable of restricting exposure to radiation Adequate testing before clinical use Adequate testing of the performance throughout lifetime of equipment Assessment of representative doses Handover procedure(s) As an engineer you must ensure that after you have tested the equipment, it is handed back in a clinically fit state

42 All X Ray Equipment Should have a lights on the control panel to show mains switched on Fitted with a light/indications that gives a clear indication that an exposure is taking place Exposure switches/peddles should only function while continuous pressure is applied

43 Reg 34: Duties of Employees
Must not recklessly interfere with sources Must not expose themselves unnecessarily Report immediately to the RPS/Employer if an incident or accident has occurred

44 Duties of Employees – DO NOTS
DO NOT X-ray yourself (even if you think you have broken a bone) DO NOT X-ray your colleagues (even if you suspect they have broken a bone) DO NOT fail to use lead glass screen properly DO NOT fail to wear lead aprons and thyroid collars (if you have a thyroid collar!!) DO NOT fail to wear any other PPE correctly DO NOT fail to report to your RPS any defects in lead aprons DO NOT fail to return lead aprons to their hangers DO NOT tamper with dose badges DO NOT hand badges in late DO NOT fail to wear badges UNDER your lead apron DO NOT fail to inform your RPS if you believe yourself or someone else has received an overexposure

45 Notification of Incidents
Must report to external body when the dose to a patient is ‘much greater than intended’ If it was a machine fault this must be reported to the HSE If any other fault (e.g. radiographer) then inform Care Quality Commission

46 Exposures much greater than intended
Diagnostic multiplying factors HIGH DOSE PROCEDURES Barium, angio, NM(>5 mSv), CT 3 x MEDIUM DOSE PROCEDURES Lumber spine, abdo, pelvis, mammo 10 x LOW DOSE PROCEDURES Extremities, skull, dental, chest 20 x Radiotherapy (inc NM therapy) Whole course x 1.1 One fraction x 1.2 Also: Incorrect patient Incorrect anatomy of the correct patient

47 Incidents Any untoward occurrence that may have resulted in excess radiation to staff or patients must be referred to the RPS and RPA The RPA will estimate the dose and inform management, HSE, CQC etc if necessary Suspect equipment must be withdrawn from service and labelled accordingly.

48 Female Staff of Child Bearing Age
Staff working with radiation are naturally concerned to minimise the risk to a foetus should they become pregnant IRR99 places the onus on the employer to provide adequate information and on the employee to inform that they are pregnant The employer must: ensure that the dose to the foetus does not exceed 1 mSv Notify female employees working with radiation the risk to the foetus, and the importance of informing the employer in writing as soon as they are pregnant

49 Doses and Risk to the Foetus
Current legal limit to foetus is 1 mSv For X-ray, this corresponds to around 2 mSv to the abdomen Assuming 8 months of declared pregnancy, dose to abdomen must be kept below 0.25 mSv per month For X-ray, over many years, experience tells us that these dose levels are never reached in most areas of Trust, assuming Local Rules are followed Only areas that work may need to cease is when using radioactive sources Dose to abdomen = dose to fetus (e.g. higher energies from Tc99m)

50 Conclusions – Staff Pregnancy
Staff should inform their RPS as soon as they learn that they are pregnant RPA must then carry out a risk assessment (if required) Usually, provided Local Rules are followed, there are no grounds for amending staff working practice during pregnancy

51 Compliance with the Regulations
HSE Inspectorate Regional specialist inspectors Powers of enforcement Improvement notice Prohibition notice Prosecution Unlimited fine Maximum 2 years in prison

52 Ionising Radiation (Medical Exposure) Regulations 2000 - IRMER

53 Principles of Radiation Protection
JUSTIFICATION Benefit of the radiation exposure must outweigh risk OPTIMISATION As Low As Reasonably Practicable (ALARP) LIMITATION

54 What is IRMER? The Ionising Radiation (Medical Exposure) Regulations 2000 The regulations apply to the following medical exposures: The exposure of patients as part of their medical diagnosis or treatment including any exposure of an asymptomatic individual The exposure of individuals as part of occupational health surveillance The exposure of individuals as part of health screening programmes The exposure of patients or other persons voluntarily participating in medical or biomedical, diagnostic or therapeutic, research programmes The exposure of individuals as part of medico-legal procedures ‘Medical exposure’ means an exposure to ionising radiation, such as: Diagnostic X-rays, CT and DEXA Radiotherapy (including brachytherapy and therapy using unsealed radioactive sources Radionuclide imaging (including diagnostic imaging and in vitro measurements in Nuclear Medicine Dept) MRI and Ultrasound are not covered by IRMER

55 IRMER IRMER specifically places duties on those professionals responsible for the patient exposure to ionising radiation

56 Main Duty Holders under IRMER
Employer Referrer IRMER Practitioner Operator Medical Physics Expert (MPE)

57 Referrer Registered Healthcare professional who is entitled in accordance with the with the employer’s procedures to refer individuals for medical exposure to an IRMER Practitioner Must have access to referral criteria Must supply the IRMER practitioner with sufficient medical data to help him justify exposure. Reg 5(5) In HEY, those who are allowed to act as referrers are depends on department – written procedure must be in place

58 IRMER Practitioner Registered healthcare professional who is entitled in accordance with the employer’s procedures to take responsibility for an individual medical exposure Must justify exposure Must authorise exposure (or delegate) Must be adequately trained – IRMER reg 11 May delegate practical aspects (operator) In HEY dependent on department and modality – must be a written procedure


60 Operator Any person who is entitled, in accordance with employer’s procedures, to carry out practical aspects of the exposure Functions and responsibilities of individual operators must be clearly defined in employer’s procedures Need to be adequately trained – IRMER reg 11 No overarching responsibility allowed MUST optimise every exposure

61 Medical Physics Expert (MPE)
An MPE must be involved in every medical exposure to which the IRMER regulations apply and shall be: Closely involved in every radiotherapeutic practice other than standardised nuclear medicine practices Available in standardised therapeutic nuclear medicine practices and in diagnostic nuclear medicine practices Involved as appropriate for consultation on optimisation, including patient dosimetry and quality assurance, and to give advice on matters relating to radiation protection concerning medical exposure, as required, in all other radiological practices In this Trust, MPEs are: X-ray Craig Moore John Saunderson Radiotherapy Andy Beavis Jenny Marsden Pete Colley

62 Duties of employer 4(1) Written procedures MUST be in place and adhered to by all IRMER Practitioners and Operators 4(2) Written exposure protocols MUST be in place to ensure consistent patient exposure 4(3) The employer MUST establish Referral criteria (these must be made available to the referrer) QA programmes Diagnostic reference levels Upper levels of dose for research exposures and make sure these are adhered to

63 Duties of employer Reg 4(4)
Employer shall ensure every practitioner and operator undertakes continual education and training Reg 4(5) Exposure to ‘much greater than intended’ must be reported Reg 4(6) Take corrective action whenever patient Diagnostic Reference Levels are consistently exceeded These are upper levels of patient dose that should not normally be exceeded

64 Duties of IRMER Practitioner and Operator: Optimisation
Practitioner and operator to keep doses ALARP Legally obliged to make sure this happens Possibly the most important aspect of these regulations As an X-ray engineer: You are an IRMER Operator Must ensure that an X-ray system is fit for clinical use Handover procedure?

65 Case Study 1 An SHO sends a patient to the X ray dept for chest X ray
The radiographer checks the request form against justification guidelines written by a radiologist and x rays the patient Who is the: Referrer? SHO Operator? Radiographer Practitioner? Radiologist who writes the written guidelines

66 Exposures of patients for research purposes
Must be approved by ethics committee Each exposure must be justified by IRMER Practitioner Dose constraints must be derived by an MPE Dose constraints must be adhered to Patient must participate voluntarily Patient must be informed of the risks in advance

67 Image Evaluation Clinical Outcome
There MUST be a record of the outcome of the procedure with radiation

68 Clinical Audit Core component of clinical governance
Must follow national procedures

69 Equipment Inventory of equipment MUST be in place
Name of manufacturer Model number Serial number Year of manufacture Year of installation Avoid unnecessary proliferation – if you have more x ray units than you need, you are breaking the law!!!

70 Training Adequate training must be given Records must be kept
Dependent upon activity Lots of physics Records must be kept Continual Professional Development and training

71 IRMER Legal Requirement under Reg 4(1) & Schedule 1
Employer’s Written Procedures

72 Employer’s Procedures
(a) Procedures to identify correctly the individual to be exposed to ionising radiation If we X-ray or treat the wrong patient we have to report it to the CQC

73 Employer’s Procedures
(b) procedures to identify individuals entitled to act as referrer or practitioner or operator

74 Employer’s Procedures
(c) procedures to be observed in the case of medico-legal exposures

75 Employer’s Procedures
(d) procedures for making enquiries of females of childbearing age to establish whether the individual is or may be pregnant

76 Employer’s Procedures
(e) procedures for ensuring quality assurance programmes are followed

77 Employer’s Procedures
(f) procedures for the assessment of patient dose

78 Employer’s Procedures
(g) procedures for use of diagnostic reference levels established by the employer for radiographic examinations stating that these are not expected to be exceeded for standard procedures when good or normal practice regarding diagnostic and technical performance applied DRLs are doses that you shouldn’t consistently exceed under normal operating conditions DAPs, DLPs, screening times

79 Employer’s Procedures
(h) procedures for the use of dose constraints for research programmes where no direct medical benefit for the individual is expected from the exposure

80 (i) procedures for giving information and written instructions to radioactive patients

81 Employer’s Procedures
(j) procedures for carrying out and recording of an evaluation for each medical exposure including where appropriate, factors relevant to patient dose

82 Employer’s Procedures
(k) procedures to ensure that the probability and magnitude of accidental or unintended dose to patients is reduced as far as reasonably practicable

83 Enforcing Authority Care Quality Commission (CQC)
Powers of enforcement Improvement notice Prohibition notice Prosecution Unlimited fine Maximum 2 years in prison

84 Further information HEY Trust Radiation Safety Policy
CP137 Radiation Physics Department website

85 Quiz Time!!!!

86 Question 1 What is the effective dose limit for a non-classified radiation worker?

87 Question 2 What is the dose limit to the eye for a non-classified radiation worker?

88 Question 3 What is the public dose limit?

89 Question 4 In X-ray, what is the definition of an exposure that is ‘much greater than intended?’

90 Question 5 If a patient is exposed to much greater than intended, and it was the operator’s fault; who does this need reporting to HSE? CQC?

91 Question 6 In this Radiology Department, what staff group acts as IRMER Practitioner?

92 Question 7 What are the five elements required by law needed in the local rules?

93 Question 8 In this Trust, what function under IRMER do Radiographers perform?

94 Question 9 What ‘persons’ are exempt from dose limits under IRR?

95 Question 10 For an X-ray room, what three items are required legally to be displayed the controlled area sign?

96 Question 1 What is the effective dose limit for a non-classified radiation worker? 6 mSv/yr

97 Question 2 What is the dose limit to the eye for a non-classified radiation worker? 45 mSv/yr

98 Question 3 What is the public dose limit?? 1 mSv/yr

99 Question 4 In X-ray, what is the definition of an exposure that is ‘much greater than intended?’ High dose procedures x 3 Medium dose procedures x 10 Low dose procedures x 20

100 Question 5 If a patient is exposed to much greater than intended, and it was the operator’s fault; who does this need reporting to HSE? CQC? CQC

101 Question 6 In this Radiology Department, what staff group acts as IRMER Practitioner?? Radiologists

102 Question 7 What are the five elements required by law needed in the local rules? RPS Controlled Area Systems of work Contingency plans Dose investigation levels

103 Question 8 In this Trust, what function under IRMER do Radiographers perform?? Operator

104 Question 9 What ‘persons’ are exempt from dose limits under IRR?
Comforters and Carers Patients

105 Question 10 For an X-ray room, what are the legal requirements of the controlled area sign? Trefoil Controlled area X rays

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