Veterinary Radiation Blog

Introduction

The use of x-ray machines for imaging animals in veterinary practice is subject to legislation. Most notably is The Ionising Radiations Regulations 2017 (IRR17).
A cornerstone of IRR17 is Regulation 8 which makes it mandatory for an employer working with ionising radiation to complete a suitable and sufficient risk assessment prior to beginning the work with ionising radiation.
Also under Regulation 14 of the IRR17 the employer must appoint a Radiation Protection Adviser (RPA) in writing.

The Process of Risk Assessment

There are 5 steps in the process of risk assessment:

1. Identify the hazards
   A hazard is some adverse occurrence that may lead to a detriment. Such detriments may include, for instance, damage to human health (e.g. inadvertent exposure of a member of staff or the public to x-rays), and/or business continuity and/or reputational damage.
2. Identify who or what could be harmed or damaged by the hazard
   This could be a variety of people including staff such as vets, nurses, students, secretaries, receptionists, cleaners etc. or the public. It might also include the employer’s business.
3. Identify the risks
   A risk is the probability that the hazard will actually occur. Identifying risks means assessing all the ‘control measures’ that are in place to minimise the chance of a hazardous situation arising and deciding whether or not they are sufficient. If it is determined that existing controls are inadequate this section of the risk assessment should generate actions to implement further controls to render risks minimal.
4. Record the risk assessment
   A risk assessment is of no practical value if it is not recorded and retained. It is not sufficient to keep it in your mind.
5. Review the risk assessment
   Periodically the risk assessment should be reviewed in order to determine whether or not it is up-to-date and still valid. Obviously if there are any significant changes in x-ray work e.g. new x-ray equipment or room then the risk assessment must be reviewed forthwith. Nevertheless, even if there are no apparent changes the risk assessment must be reviewed every 3 to 5 years. The reviewer must sign and date the risk assessment to verify a review has taken place even if there are no changes needed to the risk assessment.

As all veterinary employers are aware there is a need to consult with a Radiation Protection Adviser (RPA) under the current Ionising Radiations Regulations 2017 (IRR17) regarding relevant areas of compliance with these regulations. For those veterinary practices who undertake Technetium bone scanning scintigraphy or radioiodine treatment of cats for hyperthyroidism there is an additional requirement to consult with a Radioactive Waste Adviser (RWA) to ensure compliance with the Environmental Permitting Regulations 2018 (EPR2018). It may be the case that the person you appoint can fulfill both of those roles.

An RPA or RWA must be ‘competent’. This means they must possess the appropriate knowledge and experience as verified by them holding a current certificate of competence as issue by an HSE/EA approved assessment body such as RPA2000. They must also be ‘suitable’ in that they have experience of advising in the veterinary sector. It is a responsibility of the employer to ensure that whomever they appoint as RPA or RWA is suitable. You can find out if the person(s) you are looking at appointing is a certificated RPA/RWA by going to the RPA2000 web site at http://www.rpa2000.org.uk/list-of-certificate-holders Note that the possession of the certification doesn’t necessarily make that adviser suitable for the work you carry out, so really the only way to confirm this will be to look at their website if they have one, or perhaps more importantly to ask them.

So what can you expect an RPA/RWA to do for you? Advise you on complying with the relevant parts of the legislation is the simple answer – but it is also about developing and enhancing that compliance in line with your bespoke requirements. An RPA must be consulted to look at plans for new practices and also modifications in existing practices (such as putting in a new x-ray unit) and they need to advise on other aspects such as your need for engineering controls and design features (e.g. shielding) plus any safety features and warning devices (e.g. lights and signs). They will advise on risk assessments and the requirements for your controlled areas – including those for off-site work if you carry out procedures such as equine imaging. Additionally, an RPA must be consulted for the periodic examination and testing of those engineering controls, design features, safety features and warning devices and the regular checking of your systems of work.

An RWAs remit will be to advise and help with EPR permit applications for the use of radioisotopes, constructing and developing the essential ‘cradle to grave’ procedures and the documentation required from when you receive the isotope to when it is disposed of – essentially helping you ensure your ongoing compliance with the conditions of your Environment Agency permit.

So should they visit me? Simply yes – it’s all about keeping doses as low as reasonably practicable (ALARP) so how can you see how a practice carries out the practical implementation of their radiation protection ‘systems of work’ or permit conditions without visiting? In consequence it tends to be the case that an RWA will visit annually, with the frequency of RPA visits depending on the types and complexity of procedures you carry out. A suggestion for an RPA advising on typical general small animal x-ray equipment use – how about a visit in year 1, again in year 2 (to check on the compliance from the initial advice) and then subject to discussions between the RPA and Employer, the level of compliance and the types of equipment and procedures, subsequently visits at least once every 3 years. Ultimately this will be up to you to discuss and agree with your RPA/RWA – but do make sure you contact them if you have any queries, issues or concerns.

But they are only ‘advisers’ aren’t they? That’s what the title says but do be aware that reports from an RPA /RWA indicating non-compliances can also be used by the HSE and EA as evidence in any enforcement action. It is also the case that both the HSE and the EA expect the RPA and RWA to be accountable for their advice and they can be subject to sanctions if their advice is wrong. Work together – it’s in the interest of all parties to ‘get it right’, keep doses ALARP and promote radiation protection culture in veterinary practice.