Steve Walker Principal Specialist Inspector radiation

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I'm from headquarters and here to help you!
Steve Walker Principal SpecialistInspector
(radiation) The Bootle Centre
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Supplier Information (User Information)

• Contents
• Why have any?
• Is it necessary?
• What should it contain?

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Contents

• Why have any?
• Employers cant comply without information
• Health and Safety at Work etc. Act 1974 (HSAW)
• Management of Health Safety at Work Regulations
  1999
• Provision Use of Work Equipment Regulations
  1998
• Personal Protective Equipment at Work Regulations
  1992 (amended in 2002)
• And of course, the Ionising Radiations
  Regulations 1999.

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Contents

• Is it necessary?
• YES!
• Section 6 of HSAW

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Section 6 HSAW

• It shall be the duty of any person who designs,
  manufactures, imports or supplies any article for
  use at work.
• to ensure, so far as is reasonably practicable,
  that the article is so designed and constructed
  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
• to carry out or arrange for the carrying out of
  such testing and examination as may be necessary
  for the performance of the duty imposed on him by
  the preceding paragraph
• to take such steps as are necessary to secure
  that persons supplied by that person with the
  article are provided with adequate information
  about the use for which the article is designed
  or has been tested and about any conditions
  necessary to ensure that it will be safe and
  without risks to health at all such times as are
  mentioned in paragraph (a) above and when it is
  being dismantled or disposed of and
• to take such steps as are necessary to secure, so
  far as is reasonably practicable, that persons so
  supplied are provided with all such revisions of
  information provided to them by virtue of the
  preceding paragraph as are necessary by reason of
  its becoming known that anything gives rise to a
  serious risk to health or safety.

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How onerous is the Section 6 Duty?

• It extends to everything that is reasonably
  foreseeable
• Section 6(10). For the purposes of this
  section an absence of safety or a risk to health
  shall be disregarded in so far as the case in or
  in relation to which it would arise is shown to
  be one the occurrence of which could not
  reasonably be foreseen and in determining
  whether any duty imposed by virtue of paragraph
  (a) of subsection (1), (1A) or (4) above has been
  performed regard shall be had to any relevant
  information or advice which has been provided to
  any person by the person by whom the article has
  been designed, manufactured, imported or supplied
  or, as the case may be, by the person by whom the
  substance has been manufactured, imported or
  supplied.

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Reasonably Foreseeable?
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Contents

• What should it contain?
• Short, sharp and to the point.
• Less is often more!

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• Because one can have too much of agood thing!

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Current Information Provision is Often Poor

• Quantity Activity
• Nuclide
• Warnings
• A radiation trefoil
• RPA consultation recommendations
• Encapsulation Description
• Fabricated to standard XXX
• Radioactive Substances Act Registration
• Information about registration and holding
• Ionising Radiations Regulations?
• Cinderella topic

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So how much information do we need?

• Dose Rates
• Contamination
• Handling Precautions
• Fabrication
• Fire Performance
• Dispersibility
• Special Form
• Longevity
• Design Life
• Working Life
• Storage needs
• Leakage testing
• Appropriate?
• How?
• Transport Information

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But Shouldnt RPAs do this for employers?

• Currently they do
• Mainly because of the way in which source use has
  evolved in industry
• Big competent users in medical and nuclear
  sectors.
• But is this efficient Health and Safety
  Assurance?
• One RPA giving advice to the supplier obviates
  the need for the same advice to be given again
  and again to each radiation employer.
• And always remember its the employer who has the
  duties, not the RPA
• So, up-front help is clearly important to overall
  compliance performance.

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Finally, when the inspector calls
Thank You. Any Questions?

• Ignorance is a poor defence!