In the first of a series of articles aimed at veterinary practice managers and others working in the field, Paul Connolly outlined the background to radiation protection in veterinary practice including some basic legal requirements applicable to the safe use of ionizing radiation. In this article I would like to describe some of the fundamental components of operational radiation safety specifically aimed at protecting workers and the general public, in particular the role and relevance of local rules and support provided by the Radiation Protection Adviser.
The overall framework for radiation protection
- The design, layout and designation of the radiation environment
- Ensuring that the x-ray equipment and associated safety controls and measures function correctly
- The safety and operational management system in force
- Information instruction and training for staff
- Monitoring, audit and verification of all components
In this article I will concentrate on the third component, which should ensure that all the other components have been adequately implemented. The starting point for operational management concerns the radiation employer as the duty holder under the Ionizing Radiations Regulations of 1999 (IRR99). For fixed or mobile x-ray equipment employed within the confines of a veterinary practice this would normally be the principal(s) of the practice or in the case of a corporate practice the directors. However, when mobile x-ray equipment is employed off site and involves employees of other employers working on these sites then responsibilities under IRR99 may be less clear.
The safety and operational management system
The safety and operational management system ensures that all the basic requirements of the components listed above are being fulfilled. This system is embodied in key operational arrangements for the safe use of ionizing radiation, namely:
- Obtaining prior advice through the services of a Radiation Protection Adviser (RPA)
- Carrying out a prior risk assessment in conjunction with an RPA
- Appointment of a Radiation Protection Supervisor (RPS)
- Employment of staff who are properly trained and supervised
- Drawing up written local rules in conjunction with the RPA, which are readily available to all staff and easily understood
- Compiling written arrangements for non-classified persons entering the controlled area
- Devising procedures for the management of animals that avoids the use of manual restraint wherever possible
- Use of equipment and techniques that can minimise exposure and the need for repeat examinations
X-ray imaging services are operated in variety of different ways within the veterinary field. The majority involve the use of a fixed or mobile x-ray set employed in a specific location. The x-ray exposures are usually undertaken by the veterinary surgeon who is a principal within the practice. Nonetheless, if this person acts as the RPS, this appointment needs to be in writing. Also,if staff not involved in x-ray work are not permitted to enter a defined area, whilst an exposure is undertaken, then this requirement needs to be in writing. Verbal guidance is not sufficient.
Two of the most important operational arrangements for the safe use of ionizing radiation concern the appointment of an RPA and the production of local rules.
The RPA and local rules
For any work with ionizing radiations a radiation employer should consult with a suitable RPA in respect of compliance with IRR99. The appointment should be in writing and indicate the scope of the activities for which advice is required. The RPA must possess the necessary knowledge, experience and competence needed to give advice. The Health and Safety Executive (HSE) has published criteria of competence for individuals and bodies intending to give advice as RPAs. A suitable person to act as an RPA for veterinary practices will be accredited by a recognized assessing body.
Matters about which an RPA should be consulted are outlined in Appendix 2 of the Guidance Notes for the Safe Use of Ionizing Radiations in Veterinary Practice published by the British Veterinary Association. An important area for consultation concerns the advice on plans including room layout prior to the installation and acceptance into service of new x-ray installations or verification that an existing layout is satisfactory following modifications or re-design. Relevant background information concerns the weekly/annual x-ray workload, location of the source relative walls, windows and doors and access and occupancy of adjacent areas. All of these factors can influence directly the overall cost of any changes.
The formulation of local rules and written arrangements is another very important matter for a radiation employer to seek advice from an RPA. Local rules constitute a scheme for safe work practices or within a quality Management System a set of Work Instructions. Suggested contents of local rules are presented in Appendix 4 of the Guidance Notes. The name of the RPA and RPS should be included as well as identification of the controlled area. The local rules should, amongst other things, also include a set of written arrangements to ensure that staff involved in veterinary radiological practices receive doses of ionizing radiation that are as low as reasonably practicable, a fundamental aim of radiation protection.
Forthcoming articles in this series will cover quality assurance, as embodied in monitoring and audit processes, including personal monitoring, as well as developments in web based RPA services that can help to ensure high quality and cost effective support.Moores, B. M., 2012. Practical radiation protection – what do I need to do? Veterinary Management for Today, June Issue, pp.34-35.
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