The Offshore Ionising Radiation Inspection Guide

Open Government Status Fully Open Publication Date 20/09/2023 Review Date 20/09/2026

Review History Date Changes

The review history should be used for any post publication reviews/changes

Target Audience OMAR Inspectors / ED Offshore Inspectors / ED Specialist Inspectors

Contents • Summary • Introduction • Relevant Legislation • Action • Background • Other relevant Inspection Guides

• Specialist Advice • Organisation Targeting Timing Resources Recording & Reporting Previous HSE Radiation inspection findings Health and Safety • Appendices Appendix 1 – Plan, Do, Check, Act for Radiation Management Appendix 2 - Application of EMM and Dutyholder Performance Assessment

Summary This guidance outlines an approach to inspection of dutyholder’s arrangements for managing health risks offshore associated with Ionising Radiation. It also sets out criteria for satisfactory and unsatisfactory performance factors against which the dutyholder performance will be rated for each of these areas. References are made to technical standards and guidance that inspectors will use to form opinion for legal compliance. The effectiveness of such systems is a key component of occupational health risk management and securing effective control of health risks to prevent or minimise the incidence of occupational diseases from exposure to radiation and ensure radiation doses are kept as low as reasonably practicable (ALARP).

Introduction The aim of this inspection guide is to provide information and guidance to offshore inspectors to support the delivery of consistent and effective health risk management. It does this by highlighting current key areas to be covered during inspections, providing a framework for inspectors to judge compliance, assign performance ratings, and decide what enforcement action to take should they find legislative breaches. In doing so, it complements HSE’s Enforcement Policy Statement (EPS) and Enforcement Management Model (EMM).

The operational guidance outlines HSE’s priorities for inspection of Ionising Radiation health risks offshore. It is important to note that this guidance does not include detailed information on other offshore health risks such as Hazardous Substances, Asbestos, Ergonomics or manual handling,

Thermal Environment, Personal Protective Equipment, Food/Water hygiene, First-Aid and Welfare, which continue to form part of the remit of the ED Industrial Hygiene Team.

Relevant Legislation Health and Safety at Work etc Act 1974, Section 2(1) – It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.

Health and Safety at Work etc Act 1974, Section 3(1) – It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety.

Health and Safety at Work etc Act 1974, Section 6 – Places duties on any person who designs, manufactures, imports or supplies articles and substances for use at work to ensure these articles and substances are designed, constructed and tested and that it will be safe and without risks to health at all times when it is being set, used, cleaned or maintained by a person at work.

The Management of Health and Safety at Work Regulations 1999, Regulation 3 – Requires every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to which they are exposed whilst they are at work; and the risks to the health and safety of persons not in his employment arising out of or in connection with the conduct by him of his undertaking.

The Management of Health and Safety at Work Regulations 1999, Regulation 5 – Requires employers make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.

The Ionising Radiation Regulations 2017 (IRR17), Regulation 8 – Requires employers, before commencing a new activity involving work with ionising radiation in respect of which no risk assessment has been made by that employer, must make a suitable and sufficient assessment of the risk to any employee and other person for the purpose of identifying

the measures the employer needs to take to restrict the exposure of that employee or other person to ionising radiation.

The Ionising Radiation Regulations 2017 (IRR17), Regulation 9 – Every employer must, in relation to any work with ionising radiation that it undertakes, take all necessary steps to restrict so far as is reasonably practicable the extent to which its employees and other persons are exposed to ionising radiation.

The Ionising Radiation Regulations 2017 (IRR17), Regulation 14 – Every employer engaged in work with ionising radiation must consult such suitable radiation protection advisers as are necessary for the purpose of advising the employer on the observance of these Regulations and must, in any event, consult one or more suitable radiation protection advisers with regard to the matters set out in Schedule 4.

The Ionising Radiation Regulations 2017 (IRR17), Regulation 16 – Co-operation between employers where work with ionising radiation undertaken by one employer is likely to give rise to the exposure to ionising radiation of the employee of another employer, the employers concerned must co-operate by the exchange of information or otherwise to the extent necessary to ensure that each such employer – (a) has access to information on the possible exposure of their employees to ionising radiation; and (b) is enabled to comply with the requirements of these Regulations in so far as their ability to comply depends upon such co-operation.

The Ionising Radiation Regulations 2017 (IRR17), Regulation 18 – Requires employers, for the purposes of enabling work with ionising radiation to be carried on in accordance with the requirements of these Regulations, every employer engaged in work with ionising radiation must, in respect of any controlled area or, where appropriate having regard to the nature of the work carried out there, any supervised area, make and set down in writing such local rules as are appropriate to the radiation risk and the nature of the operations undertaken in that area.

The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015, Regulation 16 – Requires a dutyholder who prepares a safety case pursuant to these Regulations demonstrate that the dutyholder’s management system is adequate to ensure that the relevant statutory provisions will, in respect of matters within the dutyholder’s control, be complied with.

Offshore Installations and Pipeline Works (Design and Construction etc) Regulations 1996, Regulation 12 and specifically Schedule 1 – Requires dutyholder’s ensure that the additional requirements set out in Schedule 1 are complied with in relation to an installation, while it is in use, unless in the case of any such requirement it would not prejudice the health, safety or welfare of any person if it were not complied with.

Working with Ionising Radiation ACOP (L121) This Approved Code of Practice and guidance will help employers comply with their duties under the Ionising Radiations Regulations 2017, which came into force on 1 January 2018. The publication is also relevant to employees who work with ionising radiation, radiation protection advisers, radiation protection supervisors, and general health and safety officers.

COSHH essentials NORM (breaking containment) This guidance consolidates good control practice and reinforces existing knowledge with additional information. It provides guidance to carry out IRR risk assessments, review existing assessments, deliver training and in supervising activities involving radioactive substances. Offshore COSHH essentials ORE1 - Breaking containment - naturally occurring - radioactive materials (NORM) (hse.gov.uk)

HSE information sheet Industrial radiography - managing radiation risks This information sheet is for clients and principal contractors who engage specialist non-destructive testing (NDT) contractors to carry out a radiographic inspection. This includes inspection of products, operating plant, civil engineered structures or pipeline installations. The information sheet will also be relevant to managers of these NDT companies, self-employed contractors and companies who carry out in-house radiography Ionising Radiation Protection Series No. 1 (hse.gov.uk)

Action Inspectors should review relevant documentation outlined within the IG prior to the installation visit and test compliance during the installation visit against the “Success Criteria” given in Appendix 1.

Inspection of this topic should include both inspection of the priority areas as well as an inspection of the overall policy, procedures and organisation for managing occupational health risks to establish a consistent and complete coverage of the topic. In inspecting individual topic areas, it may be

necessary to have input from the relevant specialist inspectors where there are technical issues beyond the competence of the IMT inspector.

Ionising Radiation - Fundamental requirement Firstly, the main dutyholder must manage the risk from radiation on the installation, IRR17 sets down requirements for the safety of people who work with ionising radiation to ensure their radiation dose is kept to ALARP. Before a dutyholder starts work with radioactive substances for the first time, they are required to consult with a suitable Radiation Protection Adviser (RPA) on various matters pertaining to application of IRR17 – where they receive advice from the RPA, they need to appoint the RPA in writing and lay out the scope of advice they will receive (IRR17 Regulation 14 and Schedule 4). They will then need to carry out a radiation risk assessment (IRR17 regulation 8) to allow them to identify the necessary controls etc.. Staff working with the radiation will require training and relevant documentation will be required (safe systems of work etc). At this point the dutyholder will be in a position to comply with IRR17 Regulation 5, 6 and 7 (notification, registration or consent for certain practices) dependant on what the work with radiation entails. This is a graded approach with notification required for lower risk work moving up to registration and consent level work being the highest risk.

Under IRR17 employers must carry out a prior risk assessment (IRR17 Regulation 8 – considering where relevant as stated in ACoP Paragraphs 70 & 71) before undertaking any activity involving work with ionising radiation and, for any areas designated as controlled, must prepare written local rules (IRR17 Regulation 18) summarising the arrangements for controlling work with ionising radiations. Local rules may also be considered appropriate for supervised areas, depending on the nature of the work carried out there. Where local rules apply, a radiation protection supervisor (RPS) who has received specific RPS training must be appointed to ensure that the arrangements set out in the local rules are followed. Dutyholder responsibility for compliance with IRR17 cannot be devolved to the RPS.

By the conclusion of the inspection, it should be possible to: • have undertaken a targeted proactive inspection of the Radiation management system • investigate concerns associated with Ionising Radiation • decide whether the measures in place were adequate to control the risk of exposure; and take any necessary enforcement action where these are deemed inadequate

When carrying out inspections covered by this IG inspectors should:

• Assess dutyholder responses against the success criteria in Appendix 2 • Use the performance descriptors in Appendix 1 and 2 to: o Determine the appropriate performance rating o The initial enforcement expectation o Consider how and when the issues raised during an inspection are to be closed out

Background The aim of Occupational Hygiene is to prevent or control exposure to health risks by recognising health hazards, evaluating the risk and establishing appropriate control measures. The occupational health hazards may include; • Physical agents (e.g. noise, vibration, radiation) • Hazardous substances (e.g. chemicals, asbestos) • Biological agents (e.g. Legionella, food hygiene) • Ergonomics/manual handling

The essential requirements for managing occupational health are the same as those for any management system. Any sub-system for managing occupational health risks should therefore have the key features of any good management system i.e., policy, organisation, planning and setting standards, performance measures and auditing and review. Confirmation should be obtained that a recognised code, standard or body of guidance has been considered in determining the required performance of the occupational health management system.

Other relevant Inspection Guides The Offshore Health Risk Management Inspection Guide - The Offshore Health Risk Management Inspection Guide (hse.gov.uk)

Specialist Advice Specialist advice should be sought from ED Industrial Hygiene Team in circumstances when considering enforcement / debate over relevant standards on any aspects of Ionising Radiation and further advice and support can be obtained from the HSE Radiation Team.

Potential Radiation Risks Offshore Although the use of ionising radiation is not without potential hazard, radioactive sources are useful in a number of ways and are used in the offshore environment in the form of sealed sources for

process control, including vessel level detection and pig detection, logging tools, grout density gauging (normally subsea) and smoke detectors.

In addition, ionising radiation is used in the form of X-ray in XRF laboratory equipment, these do not contain a radioactive source, but when energised creates x-ray radiation. Ionising radiation may also be encountered from natural or third-party sources, as follows: Naturally Occurring Radioactive Material – NORM – this is radioactive material that is extracted from the subsea gas/oil reservoirs either in gaseous or liquid form which subsequently deposits in vessels or pipework where pressure drops occur. It is sometimes referred to as Low Specific Activity (LSA) Scale. Third-party specialist industrial radiography companies are employed for the non-destructive testing and inspection of pipework and vessels (welds). Also, third-party specialist companies may be employed on an offshore installation to carry out well logging using radioactive sources and electrically generated ionising radiation. Industrial radiography and well logging should be considered the highest risks to radiation offshore and should only be inspected by a radiation specialist inspector.

As stated above, the main uses of ionising radiation associated with the offshore sector is work with nucleonic level gauges, NORM, industrial radiography and well logging, as set out below in more detail.

Nucleonic level gauges utilise sealed radioactive sources (sometimes high activity sealed sources, HASS) to determine the flow, fill level or profile of sediment or material within tanks and pipelines. The radioactive sources should be housed in dedicated shielded containers ensuring dose rates on the outside of the shielding are low, however uncontrolled work activities such as accessing inside tanks for cleaning or inspection when nucleonic level gauges are present without appropriate shielding or shutters could result in a significant radiation exposure to an individual.

The process of extraction of oil and gas reserves results in NORM. NORM is found naturally in different concentrations within the earth’s crust and are brought to the surface during the extraction process. Concentrations in well fluids may become enhanced due to extraction processes and subsequently form enriched deposits within production facilities thereby forming NORM. Examples include produced water, scales, sludge and pigging debris. Uncontrolled work activities involving NORM can lead to unwanted exposure and dispersal posing a risk to human health and the environment. NORM contains a number of radionuclides which are from the radioactive decay chains of Uranium-238 and Thorium-232. This can produce radioactive liquids, sludges and solid scale or powders. There is a risk of loose contamination when working with NORM tanks and

pipelines which can result in a person inhaling radioactive material or becoming contaminated if it is not carefully managed. The build-up of scales containing elevated levels of NORM can pose an external radiation hazard on the outside of pipes and valves.

Due to the harsh environments and ageing infrastructure of offshore assets, industrial radiography is undertaken regularly. Industrial radiography is a modality of non-destructive testing that uses ionising radiation to inspect materials and components with the objective of locating and quantifying defects and degradation in material properties that would lead to the failure of engineering structures if left. Industrial radiography tends to be undertaken by subcontractor companies on offshore assets and requires a team of radiographers to use high activity radioactive sources or x-rays to undertake the radiography inspection. This operation can be very hazardous as it involves exposing significant amounts of radiation. If this work is not carefully managed a person could receive very high radiation doses exceeding regulatory dose limits within a few seconds and potentially lethal doses within a few minutes. Offshore industrial radiography is generally undertaken on night shift or at times when fewer people are working.

Well logging activities can be carried out offshore using high activity sealed radioactive sources and electrically generated pulsed neutron devices. These sources and devices are exceptionally dangerous and if this work is not carefully managed a person could receive very high radiation doses exceeding regulatory dose limits within a few seconds and potentially lethal doses within a few minutes.

People can be exposed externally to radiation from a radioactive material or a generator such as an X-ray set, or internally by inhaling or ingesting radioactive substances. Wounds that become contaminated by radioactive material can also cause internal radiation exposure. Everyone receives some exposure to natural background radiation and much of the population also has the occasional medical or dental X-ray. HSE is concerned with the control of exposure to radiation arising from the use of radioactive materials and radiation generators in work activities.

Organisation

Targeting Inspections should be planned to ensure that the necessary site personnel are available and arrangements can be made to facilitate physical inspection of the system(s).

Timing Inspectors should undertake Inspections as part of the agreed Intervention Plan or as determined by the EDSLT.

Resources Further guidance can be sought from: HSE website - Occupational health risks offshore - HSE The Ionising Radiations Regulations 2017 (IRR17). Work with Ionising Radiation ACOP (L121) HSE Information Sheet – Industrial radiography – Managing radiation risks – IRP1; HSE Information Sheet – Radiation Protection Supervisors – IRP6;

Recording & Reporting The dutyholder performance ratings should be entered on the Inspection Rating (IRF) Tab of the relevant installation Intervention Plan Service Order. Findings should be recorded in the post inspection report and letter.

Previous HSE Radiation inspection findings The results from the focused HSE inspection intervention demonstrate a high level of IRR17 material breaches, the most common