The New IRR17 Consent Process

IRR17 Consent Training Course

The Ionising Radiation Regulations 2017 (IRR17) brought into effect a new Graded Approach for how regulators (HSE, ONR and HSENI, we focus on HSE in this article) would authorise work with ionising radiation – the higher the radiation protection risk, the greater the requirements. A three-tier system of regulatory control, Notification, Registration and Consent was introduced in IRR17, with consent reserved for the highest hazard/risk activities.

The International Atomic Energy Agency’s (IAEA) undertook an Integrated Regulatory Review Service (IRRS) mission to the UK in 2019 which identified improvements needed to be made in the existing Consent process including that Employers should submit a Safety Assessment.

The UK has adopted this recommendation and from April 2023 (for GB Nuclear sites regulated by ONR) and October 2023 (for HSE) a new Consent Process will be adopted. This will apply for all new applicants after these dates, also for any Employer who is making a material change to their existing Consent Certificate and on those existing Consent Certificate holders who will be invited on a randomised basis to re-apply over a period of 5 years.

Existing Consent Certificate holders will be contacted within a period of 5 years and asked to submit an on-line Safety Assessment for review and inspection, with an expected timescale of one month to submit a Safety Assessment upon request from the HSE, recognising that existing Consent Certificate holders should already have all their compliance arrangements in place.

This is likely to include key details taken from the Radiation Risk Assessments that must already be in place including the nature of activities, sources of ionising radiations, expected doserates and doses, details of Installed Control Measures, details of routine examination, maintenance and test undertaken, the results of the Critical Examinations undertaken, details of the radiological protection training provided including refresher training and a summary possible Radiation Accident scenarios. The applicant will also need to provide details of locations where work is undertaken and a basic sketch/drawing of the facilities. Along with this, the applicant will also need to provide a copy of their current Local Rules and Contingency Plans.

If the initial review is unsuccessful, the application is passed back to the Employer with feedback and a request to resubmit. If a subsequent review still shows deficiencies the application is rejected completely (if it is an existing Consent Certificate Holder then current certificate will be revoked).

Provided the Safety Assessment is accepted by the HSE they will then visit the Employers site(s) to inspect and confirm that the stated compliance arrangements are in place and are effective. Once this process has been successfully completed will a Consent Certificate for the specified practice. Again, if there are deficiencies from the inspection then these will be highlighted and the Employer will need to correct them, if still not acceptable than for an existing Consent Certificate Holder the current certificate will be revoked.
In the current HSE Consent Application process, the Employer pays a nominal £25 application fee, this will be changed in the new HSE Consent Application process will result in HSE charging the full cost of the application to the Employer, which is likely to be several thousand pounds, whether the applicant is successful or not.

The HSE have characterised the new Consent process as a once in a generation opportunity to improve radiation protection in Great Britain.

L2 Business Consulting Limited is a HSE recognised RPA Body with significant experience of supporting Employers who require Consent Certificates under IRR17. It is imperative for anyone who will need to apply to this new process that they get ready all radiation protection documentation and the physical arrangements to be fully compliant to IRR17 ahead of the commencement date, as for existing HSE Consent Certificate holders you could be selected at anytime from October 2023.