I attended the SRP one day meeting on the Implementation of BSS: Ionising Regulations (IRR) and Other Regulations held on 19/1/17 in London. The aim of the Basic Safety Standard Directive in question (Directive 96/29/Euratom – ionizing radiation) is to establish uniform basic safety standards to protect the health of workers and the general public against the dangers of ionising radiation…”.
It was explained that the 2013 Basic Safety Standard has to be implemented in UK law by February 2018 but there were issues relating to registration and dose records that made 1/1/18 a more practical starting date for some clauses of the regulations. Before then there would be a consultation period (which should have started by now), a review of the draft based on the consultation, a final consultation with lawyers and then the draft would be put to the Ministers. The impression was given that the Ministers have a greater ability to change the draft than the consultees. The regulations should be submitted to the EU in autumn and become law in early 2018. It was not explained why so much activity is compressed into the last year of the implementation period given that the BSS was published in 2013 and had been widely consulted on before that.
The graded approach to regulation to be used in IRR17 was described. This balances the requirements of the BSS against the desire for minimal change to UK law and as light a touch as is appropriate. The system of Notification, Registration and Licensing of practices of increasing potential harm will require the user to enter the details of their practices into a web-site database and answer a series of questions to confirm that they have met the requirements of the regulations in terms of risk assessment, contingency planning, training and consultation of an RPA. This system seems very sensible although a number of questions were asked about the number of entries that users of multiple systems and multiple different practices would have to make – one per practice apparently.
The section on REPPIR was very disappointing. It seems possible that the drafting of these regulations and associated guidance are further behind schedule than the IRRs. There was either a reluctance or inability to answer fairly predictable questions from the audience which does not bode well. There are a number of contentious issues with regard to emergency planning regulation in the UK and very little time to adequately consult and get this regulation right. It is important to decommissioning sites, generating sites and new build operators and to the local authorities in whose patches the nuclear sites are found.