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Understanding IRR17: Consent and the Safety Assessment Requirement

If your business works with ionising radiation, staying compliant with The Ionising Radiations Regulations 2017 (IRR17) is non-negotiable. Under Regulation 7, specific high-risk practices require more than just notification—they require formal Consent from the Health and Safety Executive (HSE) or the Office for Nuclear Regulation (ONR).

A critical part of this application is the Safety Assessment. Here is everything you need to know about the requirements and how to ensure your submission is successful.

What is a “Specified Practice”?

The requirement to submit a safety assessment applies only to “specified practices.” According to Regulation 7(1) of IRR17, these high-risk activities include:

  • Medical & Veterinary: Deliberate administration of radioactive substances to people or animals for diagnosis, treatment, or research.
  • Industrial Radiography & Irradiation: High-energy imaging and material processing.
  • High-Activity Sealed Sources (HASS): Any practice involving these sources (excluding radiography/irradiation).
  • Accelerators: The operation of particle accelerators (excluding electron microscopes).
  • Nuclear & Mining: Exploitation of uranium mines or the operation/decommissioning of radioactive waste storage facilities.
  • Manufacturing: Adding radioactive substances to consumer products or medicines.
  • Environmental Discharge: Practices discharging significant airborne or liquid radioactive effluent.

Note: If you perform more than one specified practice, you must apply for a separate consent for each individual activity.

What is an IRR17 Safety Assessment?

A safety assessment is a formal demonstration that your facility has identified risks and implemented controls. It isn’t a single document, but a package consisting of:

The HSE Safety Assessment Template: A specific form tailored to your work practice.

Local Rules: Your site-specific procedures for managing radiation.

Contingency Plans: Formalized steps to be taken in the event of an accident or equipment failure.

The Goal of the Submission
The HSE uses these documents to determine if your safety arrangements meet legal standards. For the employer, it is a vital exercise in proving that compliance with IRR17 is being actively maintained.

How to Submit Your Safety Assessment

The process differs depending on whether you are starting a new practice or updating an existing one.

  1. Select Your Template
    Visit the HSE Safety Assessment Templates page and select the practice applicable to your business.
  2. Choose the Right Version
    New Consent Template: Use this if you do not yet have consent for the specific work practice. Continuing Consent Template: Use this if you already hold consent but have been asked by the HSE/ONR to submit a safety assessment retrospectively.
  3. Complete and Upload
    Download the template (available in Word or OpenOffice), complete it thoroughly with your Radiation Protection Adviser (RPA), and upload it to the HSE portal during your application process.
Retrospective Submissions: Are You at Risk?

Since January 1st, 2018, consent has been a legal requirement. However, many employers hold “Consent” but have not yet submitted a formal Safety Assessment.

The HSE and ONR are currently contacting these holders to request retrospective submissions. If you receive this request, it is vital to act quickly to ensure your legal authority to work with radiation remains valid.

Expert Support with HTSL Group

Navigating HSE applications can be complex. The technical requirements for contingency plans and safety templates often require expert oversight to avoid rejection or delays.

HTSL Group provides industry-leading radiation protection compliance services. Our experienced team can act as your Radiation Protection Adviser (RPA) and Radioactive Waste Adviser (RWA), guiding you through the entire safety assessment process and providing bespoke training for your staff.

Ensure your business stays compliant.
Visit our RPA webpage

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