Part I: Local Rules3

CONTENTSPage

PART I: LOCAL RULES3

1.INTRODUCTION4

2.LEGISLATION4

2.1Current Legislation4

2.2Monitoring Changes to Legislation4

2.3Dissemination of Information4

3.REPONSIBILITIES5

3.1General5

3.2Statutory Responsibilities5

3.3Managerial & Operational Responsibilities5

4.PROVISION OF INFORMATION8

5.MONITORING8

5.1Methodology8

5.2Action Levels9

6.MITIGATION9

6.1Design & Installation9

6.2Records & Testing9

6.3Maintenance10

6.4Reporting10

7.TEST PROTOCOLS10

7.1General10

7.2Initial Test Protocol10

7.3Post-mitigation Test Protocol11

7.4Re-test Protocol12

PART II: OPERATIONAL PROCEDURES13

8.DETECTOR MANAGEMENT14

7.1Handling14

7.2Placement14

Part I

Local Rules
.

1.INTRODUCTION

This document forms the Local Rules, in accordance with regulation 17(1) of the Ionising Radiation Regulations, describing Cornwall Council’s [CC] protocols and procedures for complying with it’s Policy for controlling the levels of Radon within its properties.

2.LEGISLATION

2.1Current Legislation

Exposure to Radon will be controlled within CC properties in order to conform to the Health and Safety at Work Act and the Ionising Radiations Regulations [IRR].

The Regulations shall apply to any workplace which exceeds those levels cited in IRR Regulation 3(1)(b), which states:

“any work (other than a practice) carried out in an atmosphere

containing Radon 222 gas at a concentration in air, averaged over any

24 hour period, exceeding 400 Bq m-3 except where the concentration of

the short-lived daughters of Radon 222 in air averaged over any 8 hour

working period does not exceed 6.24 x 10-7Jm-3”

2.2Monitoring Changes to Legislation

Both the Wellbeing Manager and the Radiation Protection Supervisor are responsible for the continual monitoring of any changes to UK legislation and current good practice. This will be done through regular contact with the Health and Safety Executive [HSE], Radiation Protection Advisor, Internet access, purchase of relevant publications / journals and attendance of training/refresher courses.

2.3Dissemination of Information

Relevant CC staff will be notified of any changes to the Radon legislation and Approved Code of Practice(s) through the provision of staff training, articles in CC newsletters and Intranet site, and the cascading of information from senior council officers to their subordinates.

3.RESPONSIBLE PERSONS

3.1General

This document identifies the responsibilities of both individuals and sections within Cornwall Council in compliance with the IRR. It covers the duties relating to all aspects of the Statutory Instrument, with specific reference to controlling the levels of Radon within its properties as a Radiation Employer in accordance with regulation 2(1).

3.2Statutory Responsibilities

3.2.1Radiation Protection Advisor (RPA)

The Radiation Employer shall employ the Health Protection Agency – Radiation Protection Division[HPA] as its statutory Radiation Protection Adviser[RPA] in accordance with IRR regulation 13.

3.2.2Radiation Protection Supervisor (RPS)

In accordance with IRR regulation 17(4) the head of Cornwall Council’s Engineering Services Laboratory (the Soils & Materials Engineer) shall be appointed as the Authority’s Radiation Protection Supervisor [RPS], for the purposes of controlling Radon in the workplace, by the Radiation Employer.

3.3Managerial & Operational Responsibilities

Based on the IRR the following managerial and operational responsibilities are assigned:

3.3.1Head of Property

Is responsible for:

Ensuring compliance with the requirements of current IRR and the CCRadon Policy and Local Rules
Ensuring adequate steps are taken to identify those areas in CC properties where the IRR apply
Ensuring risk assessments are carried out wherever stated Radon levels are exceeded
Ensuring appropriate mitigation measures are taken to reduce Radon levels below the accepted threshold
Ensuring that an ongoing monitoring programme is maintained within all of it’s susceptible properties
Ensuring that the CCRadon Database is maintained and updated
Ensuring that the Private Finance Initiative (PFI) provider complies with the IRR, where appropriate.
Ensuring that adequate resources are made available for the implementation of the duty.
Ensuring that any new property procured on behalf of the Council is surveyed and appropriate actions taken to comply with the IRR.
Ensuring that all new construction(s) complies with the IRR and relevant sections of the Building Regulations that relate to Radon mitigation.
Ensuring that the Annual Report produced by the RPS is conveyed to the Well Being Manager and Corporate Leadership Team

3.3.2Corporate Property Manager

Is responsible for:

Following IRR and CCRadon Policy and Local Rules,
Appointment of the RPA and RPS.
Implementing an appropriate testing, monitoring and mitigation regime for all susceptible CC properties.
Maintaining the CCRadon Database.
Organising a regular audit of the CCRadon Database and reporting to the Head of Property.
Monitoring/reviewing the performance of the CC Radon policy & procedures

3.3.3Corporate Maintenance Manager

Is responsible for:

Following IRR and CCRadon Policy and Local Rules
Managing the Council’s financial ‘Radon Budget’
The design, construction and supervision of Radon mitigation measures in conjunction with the RPS and RPA
Maintaining, updating and replacing existing Radon mitigation measures, as appropriate
Audit of PFI provider(s) to ensure their compliance with the current IRR

3.3.4Wellbeing Services Lead

Is responsible for:

Ensuring that all aspects of the managing of Radon is performed in a practical and safe manner and that all the current Health & Safety legislation is adhered to
Liaising with the RPA and Health & Safety Executive on all matters relating to Radon
Monitoring for changes/amendments to the current legislation and disseminating the information to all relevant parties

3.3.5Soils & Materials Engineer

Is responsible for:

Following IRR and CCRadon Policy and Local Rules
Acting as RPS on behalf of the Radiation Employer
Liaising with the RPA on all matters relating to Radon
Organising the routine Radon testing and monitoring programme
Managing, updating and reporting on the CC Radon Database
Notifying Corporate Maintenance Manager of areas requiring investigation of existing mitigation systems or implementation of new measures
Producing an Annual Report for the Property Policy Manager on the status of the CC Radon Monitoring Programme

3.3.6Private Finance Initiative (PFI) Provider

Is responsible for:

Complying with the IRR, Approved Codes of Practice, appropriate Building Regulations and implementing the Radon Monitoring Protocol, as described in the project agreement

3.3.7Employees

Have a responsibility to:

Comply with the Council’s policy
Comply with any instructions provided for reasons of health and safety

Attend any training provided for health and safety
Report any incident / exposure for which this policy applies
Report any concerns or failures in safety systems

4.PROVISION OF INFORMATION

Where employees or visitors may be exposed to workplace atmosphere’s containing Radon 222 that exceed those concentrations given in regulation 3(1)(b); they shall be informed of the hazard by the Radiation Employer who shall provide support and guidance, where appropriate.

Information shall be provided either by personal communication, articles in CC newsletters and Intranet site, and the cascading of information from senior council officers to their subordinates.

5.MONITORING

5.1Methodology

Monitoring will be conducted on all CC properties located within areas identified as having potentially high Radon levels, as presented in the HPA document Indicative Atlas of Radon in England and Wales Report No.HPA-RPD-033.

Cornwall Council will address Radon issues within its property portfolio on a risk basis.

The monitoring for Radon shall be achieved by taking passive measurements using CR-39 etch-track detectors following the protocols contained in Section 7.

The frequency of testing will be:

Test Type / Purpose / Protocol
Initial / To identify premises with Radon levels >400 Bqm-3 / Three month passive
Interim / To monitor exposures in premises with Radon levels>400 Bqm-3 / Two month continuous without interruptions
Mitigation Check / Check that mitigation has reduced Radon below 400 Bqm-3 / First full two month period of Interim series after completion of mitigation works
Periodic / Check that mitigation remains effective over the long term / Three month passive, annually or otherwise as agreed with RPA
Radiation Area / To monitor levels in premises or locations that are not to be mitigated / Three month passive annually

All testing and monitoring will be conducted by the Engineering Services Laboratory (ESL) under the supervision of the RPS.

5.2Action Levels

Action Levels for mitigation in the workplace are as follows:

Occupancy
(hours per year) / Action Level
(Bqm-3)
>2000 / 200
≤2000 / 400

In residential units, mitigation will be carried out where the 45%/55% “average” lounge/master bedroom level exceeds 200 Bqm-3.

In premises with a variety of uses, mitigation will be carried out when the lowest appropriate level has been exceeded.

6.MITIGATION

6.1Design & Installation

Where areas have been identified as exceeding the Action Levels through testing and monitoring the Corporate Maintenance Manager (CMM) will be immediately notified by the RPS. In collaboration with the RPA, he shall design an appropriate remediation system(s) and oversee it’s installation.

The choice of mitigation systems will rest primarily on its ability to reduce Radon concentrations to below the appropriate action level.

Within limits of practicability and expense the system shall be designed to reduce Radon concentrations to a level as low as reasonably achievable

6.2Records & Testing

The CMM shall arrange for details of the system to be recorded on the Authority’s central property database and a planned inspection and maintenance regime put in place.

Once the installation is complete post-mitigation testing will be conducted to monitor the effectiveness of the system in accordance with the testing protocol.

6.3Maintenance

The Contractor’s work associated with all systems will be the subject of regular inspection by the Area Building Surveyor.

The fans and electrical installations associated with systems will form part of the regular electrical and mechanical maintenance programme by the Mechanical & Electrical Section.

In all buildings where systems are fitted, written instructions will be issued to the officer in charge, which will set out the following:

a)periodic checks to ensure continued operation of the system

b)periodic checks to ensure no obvious damage to the system.

c)contact arrangements/telephone number(s) for repairs, enquiries etc.

6.4Reporting

The RPS will provide an annual status report to the Property Policy Manager which will include the latest test results, plus update of the property history, system maintenance reports and recommendations for additional mitigation.

7.TEST PROTOCOLS

7.1General

All individual detectors will be placed away from major sources of heating and ventilation.

Testing will be conducted in the winter months with detectors placed no earlier than the beginning of September and retrieved no later than the end of April.

Detectors will be placed for a nominal period of three months.

7.2Initial Test Protocol

7.2.1Occupational Premises

A minimum of TWO detectors will be placed in each building however small, to avoid the problems associated with unsupported single measurements.

In the case of a number of buildings of similar layout, as far as is practicable the detectors will be placed in the same corresponding positions in each building.

The major spaces chosen for testing will be those regularly used by the largest number of people; particular emphasis will be given to areas to which members of the public have access.

Under no circumstances will a single detector cover a floor area greater than

250m2 (the largest area found by experience capable of being drained by a single sump mitigation system in the majority of cases). The preferred maximum area per detector will be 100m2.

Additional detectors will be placed in areas of potentially higher concentration such as basements, stores and boiler rooms; particular emphasis will be given to areas used by a few individuals for long periods.

7.2.2Residential Premises

TWO detectors will be placed in EACH residential unit regardless of the size of that unit.

The detectors will be placed in each unit of residential accommodation as follows:

one in the main living area and;

one in the master bedroom.

A single “average” figure for the residential unit as a whole will be obtained by adding 45% of the main living area value to 55% of the result from the master bedroom. A seasonal correction factor will be applied to the single figure to obtain a year-long average.

7.3Post-mitigation Test Protocol

Post-mitigation tests will be arranged to mirror, as far as possible, the corresponding Initial Tests.

In addition to the original test locations, further test locations may be included to ensure that ALL parts of that property are below the appropriate action level.

Tests of less than 3 months duration or outside the winter months will only be carried out in exceptional circumstances. Results from these tests will be treated as indicative only and the tests repeated to the standard protocol at the earliest opportunity.

7.4Re-test Protocol

Repeat tests will be carried out as far as possible in a different season to the previous test.

At least 50% of detectors will be placed in the same positions as in the previous test(s).

The interval between re-tests in properties with mitigation systems will remain fixed.

The interval between re-tests of borderline properties may be increased if repeat measurements remain below the appropriate action level.

Part II

Operational

Procedures

8.DETECTOR MANAGEMENT

8.1Handling

Orders for detection will be placed preferably 3 months in advance of the anticipated delivery date and no later than 1 month before.

Care will be taken to ensure that standing times between delivery and placement, and retrieval and return for processing, are kept as short as possible to minimise errors in results.

Care will be taken to ensure that the detectors are kept in areas of potentially low Radon concentration during standing times.

8.2Placement

With the exception of individual dwelling units, whose detector placements positions are fixed, 2 copies of the appropriate floor plan(s) will be sent to those placing the detectors.

The plans will be annotated by the RPS with the following information:

(a)A unique reference number for each block.

(b)A unique reference number for each room/space in each block.

(c)A date for the approximate commencement of the round of testing.

(d)The rooms/spaces where detectors are to be placed market/numbered.

The officer placing the detectors will annotate the plans as follows:

(a)The exact position where each detector has been placed marked with a cross.

(b)The number of the detectors entered in beside the cross.

For each premises, 2 copies of a standard form will be completed by the officer placing the detectors with the following information:

(a)Job title and reference

(b)Block number

(c)Room number

(d)Detector number

(e)Exact location to allow easy retrieval (if required)

(f)Exact date of placement

(g)Signature/Initials of placing officer

The standard forms will be completed by the officer retrieving the detectors with the following information:

(a)Exact date of retrieval.

(b)Signature/Initials of retrieving officer.

(c)Additional notes such as “detector missing”, as required.

Both copies of the drawings and the forms will be returned with the detectors.

Both copies of each drawing and one copy of each form will be kept as hard copy files.

A single copy of each form will be sent off with the detectors.

If you would like this information

in another format please contact:

Cornwall Council

County Hall

Treyew Road

Truro TR1 3AY

Telephone: 0300 1234 100

Email:

Control of Radon in the Workplace Local RulesPage 1 of 16

October 2009 V.2