The Health and Safety Executive (HSE) recently hosted its annual workshop for Radiation Protection Advisers (RPAs) across the UK. The session provided a critical retrospective on the HSE’s enforcement activities over the last 12 months and dropped major indicators regarding where inspectors will focus their attention through 2026 and 2027.
For employers working with ionising radiation, the data shared by the HSE serves as a stark reminder: compliance under the Ionising Radiations Regulations 2017 (IRR17) requires continuous vigilance.
Here is our comprehensive breakdown of the key takeaways from the workshop, the most common regulatory failures, and how your business can stay ahead of the curve.
The Headline Statistic: A 64% Material Breach Rate
During Priority Local Inspections over the past year, the HSE uncovered a staggering 64% material breach (MB) rate.
What is a Material Breach? A material breach occurs when an inspector judges that a company has broken health and safety law significantly enough to warrant formal action. This ranges from verbal advice and official Notice of Contravention (NoC) letters to binding Improvement Notices, Prohibition Notices, and outright prosecution.
While non-compliance was found across various aspects of IRR17, four specific regulations stood out with the highest failure rates.
| Regulation | Focus Area | Breach Rate | Common Failure Points Identified |
| Regulation 19 | Additional Requirements for Designated Areas | 46% | Specifically Reg 19(6); inadequate or missing dose assessment in controlled areas. |
| Regulation 20 | Monitoring of Controlled Areas | 36% | Complete absence of monitoring, or infrequent monitoring in and around controlled areas. |
| Regulation 9 | Restriction of Exposure | 29% | Deficiencies in physical shielding, malfunctioning warning lights, missing e-stops, or flawed access restrictions. |
| Regulation 8 | Radiation Risk Assessments (RRA) | 29% | Failing to follow the specific Approved Code of Practice (ACOP) outlined in paragraphs 70 & 71 of IRR17. |
HSE Inspection Plans for 2026/2027: Where the Spotlights Are Turning
The HSE’s Radiation Specialists announced clear operational shifts for the upcoming cycle. Organizations should prepare for an uptick in proactive and reactive scrutiny:
- Increased Focus on RADAN Consents: A major administrative priority is processing and auditing application consents through the digital RADAN system.
- Reactive Investigations & Local Inspections: Expect more unannounced or quick-response local site visits.
- Airport Security Blitz: In a major industry-specific announcement, IRR17 investigators are launching a targeted campaign of inspections on airport X-ray security systems over the next year.
Mastering the RADAN Consent Process: Critical HSE Dos and Don’ts
Since transitioning to the RADAN system, the HSE has received 186 submissions and granted 92 consent certificates. Navigating this system efficiently is a major bottleneck for many firms. To speed up your approval process, the HSE provided three essential pieces of practical advice:
- Don’t upload your Radiation Risk Assessment (RRA) unprompted: Only upload documents explicitly requested in the portal, such as your Safety Assessment. Your assigned inspector will request the RRA directly via email prior to an audit if needed.
- Use a generic company email for submissions: Avoid using an individual employee’s login credentials. The HSE has flagged multiple cases where a consent application stalled mid-process because the employee who started it left the company, locking out the business.
- Highlight revisions in RED: When modifying your Safety Assessment or Local Rules based on inspector feedback, ensure all changes are in red text. This allows inspectors to verify updates instantly, drastically reducing review turnaround times.
Industrial Radiography Focus: The Good vs. The Bad Practices
The HSE also compiled specific feedback stemming from desktop reviews and on-site inspections of industrial radiography providers. If your facility handles radiography, use this checklist to gauge your compliance.
What the HSE Applauded (Good Practices):
- Radiation Risk Assessments that rigidly follow paragraphs 70 & 71 of the IRR17 Approved Code of Practice.
- Highly detailed, granular descriptions of equipment and active work scopes in Section 1 of Safety Assessments.
- Proactively documenting the outcomes of critical examinations—and their subsequent corrective actions—directly inside the safety assessment.
What the HSE Flagged (Bad Practices):
- Discrepancies in Safety Gear: Physical warning lights on-site failing to match the specifications written in the Safety Assessment.
- Admin Failures: A total lack of formal procedures for managing and processing Radiation Passbooks.
- Poor Handovers: No formal, documented arrangements for handing over custody of Controlled Areas.
- Ignoring Non-Radiological Staff: Failing to train staff who work near radiation but aren’t radiographers. The HSE specifically highlighted a failure to account for the safety and awareness training of on-site cleaning crews.
How HTSL Group Keeps Your Business Compliant
Navigating a 64% industry failure rate means you cannot afford to guess when it comes to radiation safety.
We provide expert radiation protection compliance services backed by decades of UK industry-leading expertise. We regularly help employers across the medical, nuclear, industrial, and security sectors manage their IRR17 duties seamlessly.
Whether you need a robust Radiation Risk Assessment, support navigating your RADAN application, or specialised staff training, we are here to safeguard your workforce and shield your business from costly material breaches.
