Radioactive Substances Act 1993 and Qualified Experts
UKRSR10
September 2007

EXECUTIVE SUMMARY

Background to research

The Euratom Basic Safety Standards Directive defines Qualified Experts as:

‘Persons having the knowledge and training needed to carry out physical, technical or radiochemical tests enabling doses to be assessed, and to give advice in order to ensure effective protection of individuals and the correct operation of protective equipment, whose capacity to act as a qualified expert is recognised by the competent authorities. A qualified expert may be assigned the technical responsibility for the tasks of radiation protection of workers and members of the public’.
 
Hitherto, the concept of ‘Qualified Expert’ has mainly been applied to the field of worker protection under the Ionising Radiation Regulations 1999 in England, Scotland and Wales and the Ionising Radiation Regulations (Northern Ireland) 2000 in Northern Ireland, and has been carried through by way of the Radiation Protection Advisor scheme.

The environmental regulators in the United Kingdom are the Environment and Heritage Service (EHS) in Northern Ireland, the Scottish Environment Protection Agency (SEPA) in Scotland and the Environment Agency in England and Wales. They have recognised that although the Radiation Protection Advisor scheme meets the needs of the Ionising Radiation Regulations 1999 and the Radioactive Substances Act 1993, in the latter case, the arrangements require additional formalisation.

Although the managers of premises regulated under the Radioactive Substances Act 1993 have recognised the need to employ suitable experts and have, in the majority of cases done so, a system which formalises the arrangements would be beneficial to regulated Authorisation/Registration holders and environmental regulators themselves. This was generally accepted by industry stakeholders contacted during the course of the project.   

Objectives of research

To develop a scheme of formal certification, akin to the RPA scheme, which fulfils the following functions:
The scheme should apply at both an individual level (the responsibility of the certification body) and a site or premises level (the responsibility of the environmental regulators).

Key findings and recommendations

The research carried out to support this report, and in particular the inputs and views gained from a series of stakeholder workshops, support a recommendation that the environmental regulators should formalise the current system of determining the competency requirements for compliance with Radioactive Substances Act Authorisations and Registrations. This must be done without increasing the regulatory burden on any individual or group. This report sets out a proposed means by which this can be achieved.

RPA is a one-off certification scheme, albeit with a requirement to re-certificate at specific intervals. QE (RSA) can not work in quite the same way; there is a much more disparate set of requirements for QE (RSA), with not all requirements applying to every industry or profession. For this reason, a modular approach is recommended. Such a scheme is proposed, in which the competency requirements are presented in 18 modules, each with two levels of achievement. The first level can be achieved, in general, by attendance at training courses, on-the-job experience alongside an experienced mentor, or some combination of these. The second level requires more extensive practical experience for the majority of modules.

Such a modular scheme, with two levels of competency, is believed to satisfy most stakeholder requirements, and to overcome a number of practical difficulties expressed during the stakeholder engagement element of the research project. In particular:
This report additionally sets out a number of considerations to be taken into account regarding implementation and management of a formal certificated scheme of competency demonstration.

Keywords: Euratom Basic Safety Standards Directive; Radioactive Substances Act 1993; Qualified Expert.

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N.B. The report is available for download from the SNIFFER Website