Whether you need to notify HSENI, or apply for registration or consent depends on the level of risk of the work you carry out. That is, the size and likelihood of exposure to ionising radiation.
Notification
Every employer is required to notify HSENI of low-risk work that they carry out with ionising radiation or in an atmosphere containing radon above a certain level.
You will need to notify HSENI if you work in an atmosphere containing radon above an annual concentration of 300 Bq m-3. This is the most common reason for employers being required to notify HSENI.
You may also need to notify HSENI if you work with:
- artificial radionuclides or naturally occurring radionuclides, which are processed for their radioactive, fissile or fertile properties
- naturally occurring radionuclides which are not processed for their radioactive, fissile or fertile properties
However, in the vast majority of cases for this work, you will need to apply to HSENI for a registration and we recommend you consider the following:
A. Work with artificial radionuclides or naturally occurring radionuclides processed for their radioactive, fissile or fertile properties
Refer to the column values in The Ionising Radiation Regulations (Northern Ireland) 2017 Schedule 7 Part 1 table on the legislation website:
Now consider the following:
1. Are activity concentration values (Bq/g) level with or below values in column 2, for any amount of material?
- Yes - you don’t need to notify or register
- No - go to step 2
2. Are activity values (Bq) level with or below the values in column 3, for any amount of material?
- Yes - you don’t need to notify or register
- No - go to step 3
3. Is the amount of radioactive material 1000kg or less?
- Yes - go to step 4
- No - register
4. Are activity concentration values (Bq/g) level with or below the values in column 4?
- Yes - notify
- No - register
B. Work with naturally occurring radionuclides not being processed for their radioactive, fissile or fertile properties
Refer to the column values in The Ionising Radiation Regulations (Northern Ireland) 2017 Schedule 7 Part 2 table on the legislation website:
Now consider the following:
1. Are activity concentration values (Bq/g) level with or below the values in column 2, for any amount of material?
- Yes - you don’t need to notify or register
- No - go to step 2
2. Are activity values (Bq) level with or below values in column 3, for any amount of material?
- Yes - you don’t need to notify or register
- No - go to step 3
3. Is the quantity of radioactive material 1000kg or less?
- Yes - go to step 4
- No - register
4. Are activity concentration values (Bq/g) level with or below the values in column 4?
- Yes - notify
- No - register
Work in an atmosphere containing radon above an annual concentration of 300 Bq m-3
If the radon concentration in your workplace is above an annual average of 300 Bq m-3 you must notify HSENI. If you have taken multiple measurements, notify HSENI of the highest.
If your workplace is below ground or in a radon affected area your risk assessment should include the measurement of your employees' exposure to radon. The radon concentration measurements done as a result of your risk assessment will indicate the annual average concentration in units of Bq m-3.
Examples of when you would need to notify
You work in a:
- school in a radon affected area and have radon concentration measurements at or above the 300 Bq m-3 level
- shop in a radon affected area and have radon concentration measurements at or above the 300 Bq m-3 level
- hospital basement not in a radon affected area and have radon concentration measurements at or above the 300 Bq m-3 level.
- in an underground area (for example a show cave or mine) and have radon concentration measurements at or above the 300 Bq m-3 level
- situation were you have performed multiple measurements in your workplace, with some providing results under an annual average of 300 Bq m-3, but with one or more results above
Notification for multiple sites
You only need to notify this work once for all sites that are under your control where you carry out work with ionising radiation.
For example, if you have five different sites all working with notifiable levels of naturally occurring radionuclides which are not processed for their radioactive, fissile or fertile properties, you should only notify HSE once, for all the relevant sites.
Registration
There are three categories of work with ionising radiation that may require you to apply for a registration from HSENI:
- work with radiation generators
- work with artificial radionuclides or naturally occurring radionuclides which are processed for their radioactive, fissile or fertile properties
- work with naturally occurring radionuclides which are not processed for their radioactive, fissile or fertile properties
Work with radiation generators
A radiation generator is a device capable of generating ionising radiation such as x-rays, neutrons, electrons or other charged particles.
This includes the following work:
- x-ray devices used by dentists, vets, chiropractors and NHS trusts
- x-ray devices used by:
- an airport to scan baggage
- a post room in an office building to scan incoming packages
- a port or dock to scan incoming or outgoing cargo
- a handheld x-ray Fluorescence (XRF) device used to determine the metallurgic content of metal
- using x-rays in a cabinet that cannot be entered to examine products
You will need to apply for a registration to work with a radiation generator unless you use it for work that requires consent such as the operation of an accelerator, industrial radiography, or industrial irradiation.
Work with artificial radionuclides or naturally occurring radionuclides which are processed for their radioactive, fissile or fertile properties
Examples of this includes work:
- in a school or university that uses radioactive material as a teaching source
- with a sealed source that is not a high activity sealed source
- with nuclear density gauges
- transporting or storing radioactive substances, unless explicitly included within a work practice that needs consent
For the examples above and in the vast majority of cases you will need to apply for a registration for this work. Notification will only apply where there are very small quantities of radioactive material, for example, in a museum that holds articles containing radium. If you think you may need to notify instead, you can check using our work with radionuclides.
Work with naturally occurring radionuclides (not processed for their radioactive, fissile or fertile properties)
An example of this is working with zircon sand in a foundry.
In the vast majority of cases, you will usually need to apply for a registration for this work with HSENI, but you can check using the HSE guide on work with radionuclides.
Where registration does not apply
If registration does not apply to the work you do, you may need to:
- notify HSENI if you carry out work in an atmosphere containing radon above an annual average concentration of 300 Bq m-3
- apply to HSENI for consent to carry out any of the eight specified higher-risk work practices
Consent
You must apply for consent if you do any of the following high-risk work with ionising radiation:
The deliberate administration of radioactive substances to people or animals for medical or veterinary diagnosis, treatment or research
You will need to apply to HSENI for consent if you wish to administer radioactive substances to:
- people for medical purposes
- animals for veterinary purposes
This consent will apply to all fixed sites operated by the employer where you carry out this practice.
The deliberate addition of radioactive substances in the production or manufacture of consumer products or other products, including medicinal products
If you manufacture or produce products that have radioactive substances deliberately added to them, you will need consent from HSENI for this work practice. This includes where radioactive substances are added to medicinal products by a radiopharmacy.
The consent will only apply to the addition of radioactive substances in the production and manufacture of these products. Any other practice associated with these products, including the sale of the products, is not covered by the consent. The consent will apply to all fixed sites you operate where this practice is carried out.
The deliberate addition of radioactive substances in the production or manufacture of any consumer product will require justification under the Justification of Practices Involving Ionising Radiation 2004 (on legislation.gov.uk), which can be found at the following link:
Operation of an accelerator (except an electron microscope)
The regulations define an accelerator as an apparatus or installation in which particles are accelerated and which emits ionising radiation with energy higher than 1 MeV.
You must apply for consent for an accelerator unless you are working with an electron microscope. The consent will apply to all fixed sites you operate where you carry out this practice.
Examples - you work:
- in an NHS Trust using an accelerator to perform radiotherapy
- with a particle accelerator for the purposes of research
Industrial irradiation
The regulations define this as the use of ionising radiation to sterilise, process or alter the structure of products or materials.
You must apply for consent if you perform industrial irradiation using:
- radioactive sources (for example HASS)
- accelerators
- radiation generators
The consent will apply to all the fixed sites you operate where you carry out this practice.
Examples - where you:
- work with a particle accelerator to perform ion implantation
- use ionising radiation to sterilise articles or food
- use neutrons to activate materials
Industrial radiography
The regulations define industrial radiography as the use of ionising radiation for non-destructive testing purposes where an image of the item under test is formed (but excluding any such testing which is carried out in a cabinet which a person cannot reasonably enter by stepping inside and closing the door).
If you are carrying out industrial radiography using either radioactive sources (for example HASS), accelerators or radiation generators, you will need consent from HSENI for this practice.
The consent will apply to:
- industrial radiography in enclosures on all fixed sites you operate where you carry out this practice
- sites where you perform site radiography in line with the conditions associated with this consent
- the transport of the radiation sources used for the purposes of industrial radiography between sites.
HSENI does not consider the use of x-rays for the inspection of mail, packages or baggage, or for security purposes as industrial radiography.
Examples:
- you use ionising radiation to inspect welds on a variety of structures at fixed locations you are responsible for
- you inspect welds on a variety of structures at sites you are not responsible for (site radiography)
Work with a high activity sealed source (HASS)
The Ionising Radiations Regulations 2017 define this as a sealed source for which the activity of the radionuclide is equal to or exceeds the relevant activity value set out in Schedule 7, Part 4 (on legislation.gov.uk).
You must apply for consent if you are performing work with or transporting a HASS, unless you are performing the specified practices of industrial radiography or industrial irradiation and have consent for them.
The consent will apply to all fixed sites you operate where you carry out this practice.
Examples - were you:
- work in an NHS Trust using HASS for brachytherapy or radiotherapy
- supply HASS to other operators
- work in a research facility and irradiate biological materials with HASS
Working on any facility for the long-term storage of radioactive waste or disposal of radioactive waste (including facilities managing radioactive waste for this purpose) but not any such facility situated on a site licensed under section 1 of the Nuclear Installations Act 1965
HSENI considers the long-term storage or disposal of radioactive waste to be a very specific practice and, therefore, it only applies to a small number of sites in Great Britain and not Northern Ireland. This will only appear as an option to the duty holders responsible for these sites.
Examples - you work:
- in a recognised installation for the long-term storage of radioactive waste facility
- on a site that disposes of (non-exempt) radioactive waste to land, such as a landfill
Discharging significant amounts of radioactive material with airborne or liquid effluent into the environment
You will need to apply for consent if you discharge radioactive material with airborne or liquid effluent into the environment and expect the quantities of radioactive material, in a single discharge, to exceed the quantities specified in the Ionising Radiations Regulations 2017, Schedule 7, Part 1, column 5 (legislation.gov.uk). (Except for gallium-67 where the quantity exceeded is 1011 Bq and for zirconium-89 it is 1010 Bq).
The consent will apply to all the fixed sites you operate where you carry out the practice.
Definitions of the above work descriptions are also included in our detailed guidance document:
If you carry out more than one of these work practices you must apply for a separate consent for each one.
Work that does not require you to notify or apply to HSENI:
- work on nuclear premises - there are currently no nuclear premises in Northern Ireland
- work that is exempt
- work with very small amounts or concentrations of radioactive substances
- work with apparatus of a type approved by HSE / HSENI
- work involving the operation of some electrical devices
If you think this may include your work, check the exempt work listed under Schedule 1 of the L121 - Work with ionising radiation: Approved Code of Practice and guidance (hse.gov.uk).