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Section F

Dose Records   

 

Persons who are likely to receive an effective dose in excess of 6mSv per year or three-tenths of any relevant dose limit must be classified (Regulation 20 (1) – the results of any prior risk assessment (PRA) will identify these individuals. To be designated as classified, the Employee must be over 18 years of age and fit to work with ionising radiation (as determined by a medical adviser).
It is highly unlikely that therapeutic radiographers and many diagnostic radiographers would be “classified workers” and will normally be non-classified.
Further information on the appropriateness of designation of classified persons may be obtained from HSE http://www.hse.gov.uk/radiation/ionising/doses/designation.htm

Those persons engaged in the following practices should normally be classified:

  • therapeutic interventional radiology & cardiology procedures
  • endoscopy using x-rays
  • radiopharmaceutical or radionuclide preparation
  • diagnostic & therapeutic radiopharmaceutical administration
  • source preparation, insertion or removal in brachytherapy procedures
  • intravascular or intra-operative procedures             (IPEM, 2002 - p. 12 of MDGN)

Staff and patient doses in interventional radiology are among the highest received from medical exposures and consequently radiation protection has to be a priority and reliable dosimetry needs to be established. The ICRP recommendation is that two personal dosimeters should be worn (under and over the apron) for high workloads (Personal Dosimetry ICRP report 85 (2001).  Periodic audit of staff eye and extremity doses is also recommended due to the potentially high doses received by the hands, feet and eyes during interventional procedures which puts them at a greater risk of experiencing deterministic injuries to the hands and eyes.  The whole body doses received by operators during interventional procedures give an increased lifetime risk of fatal cancer.

Classified persons must have an assessment of their dose of ionising radiation made by an approved dosimetry service (see http://www.hse.gov.uk/radiation/ionising/dosimetry/ads.htm) and their dose records must be kept by their Employer for at least 50 years or until the individual reaches the age of 75 (Regulation 21 (3a). Health records for classified staff must be kept for at least 50 years, or until the individual reaches the age of 75 (Regulation 24(a). Dosimetry services are approved by HSE (Regulation 35) – see pages 91-93 of L121 (HSE, 2000).

The occupational radiation exposure records for all members of non-classified staff who are routinely monitored should be stored by the RPS and kept for at least two years as per Regulation 18(5) up to a maximum of five years which would enable any requests for an individual’s dose information from other departments, following transfer of employment, to be efficiently dealt with.
Results of periodic dose audits (e.g. for extremity dose monitoring for specific types of examinations) should be kept at least until the audit has been repeated – unless there have been significant changes in practice or areas of concern highlighted such audits are repeated every three years.  The results of such audits should be circulated to all staff members that have been involved in the audit.

Investigation reports for doses received by Employees that exceed the investigation level must be kept for at least two years (Regulation 8(7). This should also trigger a review of working conditions in the event of recorded doses exceeding the appropriate investigation level.

Note:
The Society and College of Radiographers were notified by HSE Inspectors that during a recent HSE inspection of site radiography activities there was a discovery that a classified radiation worker had not been wearing his personal whole body dosimeter. This Employee was subsequently required to give a tape recorded statement under the Police and Criminal Evidence Act and consideration is being given to the prosecution of that individual under Section 7 of the Health and Safety at Work (HSW) Act 1974.

SCoR Guidance
It is not a legal requirement to monitor radiation doses of non-classified staff but many are subject to dosimetry as required by written arrangements in Local Rules. Employees who have been provided with a dosemeter by their Employer to ensure compliance with Regulation 18(2) (c) (ii), have a duty to look after that dosemeter and return it for processing as required (i.e. within time constraints). Provided the Employer has informed the Employee of that duty and is exercising the appropriate level of supervision, Employees who persistently fail to wear, look after or return their dosimeters promptly may be committing an offence under Section 7 of the HSW Act 1974 for which they could be prosecuted.
Personal monitoring reports should be made available to any member of staff who wishes to see their individual dose records. In cases where a radiographer may have two Employers or when a radiographer moves into new radiographic employment, there needs to be effective cooperation between those Employers such that there is a proper exchange of information regarding exposures and recorded doses.

Some Employers are keen to stop monitoring non-classified staff (including radiographers) within clinical imaging/radiotherapy departments but this issue raises some anxieties amongst many radiographers as they see their personal monitoring as a safety mechanism. SCoR are of the opinion that research is required to dispel any myths (e.g. perhaps an audit of dose measurements using personal dose meters versus environmental dose meters would give evidence that environmental monitoring is adequate for non-classified staff). SCoR advise that, in those local departments where radiographers (designated as classified or non-classified staff) wear personal dosemeters, student radiographers who attend that department for clinical placement as part of a radiography education programme, should also be subject to personal dosimetry. It is important that effective relationships are robust enough between the placement provider and the educational institution to ensure that this is acknowledged.

SCoR advise that Employers of non-classified persons working in controlled areas must be able to demonstrate either by personal dose monitoring or other suitable means that doses are properly restricted. In practice this means that if an Employer can demonstrate that suitable measurements have been undertaken (and the area continues to be monitored) and restrictions are proved to be working, then personal dose monitoring is good practice but not essential.
 Where personal dose monitoring is provided the IRR’99 regulations state that it is ‘…desirable, but not essential, that dose monitoring for these individuals is carried out by an approved dosimetry service…

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