Radioactive Substances Act 1993
and Qualified Experts
Background to research
The Euratom Basic Safety Standards Directive defines Qualified Experts
‘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).
- To assist the environmental regulators in clarifying and
communicating their requirements under Radioactive Substances Act 1993
Authorisation and/or Registration conditions. (The RPA scheme only
applies to Authorisations under the Radioactive Substances Act 1993).
- To assist radioactive substances professionals in
understanding the current and possible future requirements of a
Qualified Expert for the purposes of the Radioactive Substances Act
1993, thus enabling planning, training and professional
Key findings and
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.
- It will enable persons already in possession of RPA
certification to progress to certification under the new scheme without
having to revisit any issues already covered by that scheme.
- It will enable large complex sites, such as most nuclear
installations, to demonstrate competency corporately, perhaps by
deploying a number of individuals as is the current practice.
- It will accommodate the vast range of disparate
requirements, varying from industry to industry, for demonstrating
compliance with Radioactive Substances Act 1993 conditions.
- It will enable the environmental regulators to develop
their own internal competency scheme for their own officers.
Euratom Basic Safety Standards Directive; Radioactive Substances Act
1993; Qualified Expert.
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The report is available for download from the SNIFFER Website