Penryn Campus Radon Management Policy

Transcription

1 Penryn Campus Radon Management Policy Prepared by Damian Prisk, Health & Safety Adviser, Falmouth Exeter Plus Checked by Jonathan Fawcett, Radiation Protection Adviser, Public Health England Page 1

2 Purpose See Policy Aims and Objectives For the attention of Falmouth Exeter Plus staff, Falmouth University students and staff, University of Exeter students and staff at the Penryn Campus, and Falmouth and Exeter Students Union staff Comes into effect on June 2014 Previewed/Date of approval Falmouth Exeter Plus Health, Safety & Wellbeing Committee, 19 June 2014 Review date June 2015 Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 2

3 Policy statement FX Plus is jointly owned by Falmouth University (Falmouth) and the University of Exeter (UoE), and manages all shared services for the two institutions at the Penryn Campus, including estates and facilities management. FX Plus, UoE and Falmouth have a duty, as employers, to comply with the legislative requirements of the Ionising Radiations Regulations 1999 (IRR99) as they relate to radon. Falmouth and UoE have agreed for FX Plus to take the lead on radon management at the Penryn Campus and to produce a single, coherent, site-wide policy. FX Plus therefore assumes the role of a Radiation Employer, as employees across the partnership work in areas where the construction of the workplace, or the ventilation provided, is insufficient to keep the concentration of radon-222 gas (See Appendix B for definition) below levels specified in the IRR99 regulations. FX Plus, as a landlord, also has a responsibility to its tenants in Glasney Village at the Penryn Campus to provide a safe home under Duty of Care and the Housing Act FX Plus therefore has an obligation to identify and manage radon in the workplace and in buildings owned by FX Plus that provide residential accommodation in order to ensure that levels are as low as reasonably practicable and minimise campus users' exposure to radon. This policy is designed to enable FX Plus to establish effective radon protection and management arrangements at the Penryn Campus on behalf of the partnership. Application This policy applies to all buildings owned or occupied by FX Plus, Falmouth, UoE and FXU at the Penryn Campus. Aims and objectives of the policy This policy, with its associated procedures, has the following aims and objectives: To comply with applicable legislation. To take steps to assess and manage radon in all buildings on the Penryn Campus. To inform staff and students about the risks of radon exposure and ensure that levels at the Penryn Campus are as low as reasonably practicable. To outline the responsibilities for all staff with regards to radon. Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 3

4 To monitor and record radon levels in all buildings at the Penryn Campus and share the results of our radon testing programme with regular users of our buildings. To manage, maintain and check the effectiveness of new and existing mitigation. To cooperate and communicate with the other organisations who use the campus and might be affected by exposure to radon. Maintain dose assessment records for employees if required (See Appendix B for definition). To ensure that FX Plus receives specialist advice from a Radiation Protection Adviser when necessary. Legislative and regulatory context FX Plus will ensure radon levels in the workplace are managed and controlled to meet the requirements set out within the Health and Safety at Work, etc. Act 1974, the Ionising Radiations Regulations 1999 (IRR99) and the Management of Health and Safety Regulations 1999 (MHSWR), Building Regulations and any other radon-relevant legislation (Appendix C). The Health and Safety at Work, etc. Act 1974 states: it shall be the duty of every employer to ensure, so far as is reasonable and practicable, the health, safety and welfare at work of all its employees and others who may have access to their work environment. The IRR99 applies to any workplace where levels exceed those quoted in the IRR99 and 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 Bqm -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 10-7 Jm -3. * Activities associated with use of radiation sources, such as medical uses, power generation and industrial radiography. In the Housing Act 2004, Radon is identified as a potential hazard in dwellings. The need for action is defined by the Housing Health and Safety Rating System which applies a numerical score to the different hazards depending on their overall risk to the occupant. If the score exceeds certain trigger points, the local housing authority (Local Authority) is obliged to act. The Local Authority will take the 'appropriate enforcement action' which is dependent on the severity of the risk. The measured annual average radon level is used to calculate the risk. Public Health England (PHE) recommends that action to reduce radon levels is taken if the annual average radon concentration in a residential property is at or above the Action Level of 200 Bqm -3. The Management of Health and Safety Regulations 1999 states: every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to which they are exposed whilst they are at work. A risk Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 4

5 assessment for radon should be carried out in relation to all workplaces located in a radon affected area. Building Regulations 2010 Approved Document C Radon protection. The guidance on radon protection has been updated to refer to the 2007 edition of BR 211 Radon: Guidance on protective measures for new buildings and the revised radon maps produced by PHE and the British Geological Survey. The maps show far more areas with a risk from radon. Roles and responsibilities Radiation Employer FX Plus is defined as a Radiation Employer where workplace radon gas levels exceed the values in regulation 3(1)(B) of the IRR99. FX Plus has a duty to consult or appoint a Radiation Protection Adviser; to protect and inform staff, students and other users of the Penryn Campus; to assess and monitor risks; and to reduce and manage doses. Director of Estates The Director of Estates is responsible for the health and safety of all staff within his/her team. The Director of Estates will also ensure that all construction activities at the Penryn Campus are compliant with radon relevant building regulations and that this is confirmed in supporting documentation. This will include ensuring that suitable radon protective measures are installed during construction, and prior to commencing any building refurbishment programmes, consulting with the Head of Technical Services, the Programme Manager, the Radon Protection Supervisor (RPS) and the Radon Protection Adviser (RPA) if applicable. Such consultation will ensure that appropriate precautions are taken as the Penryn Campus is a known radon affected area where radon levels have exceeded IRR99 action levels. The Director of Estates will communicate with the FX Plus Board of Directors, SET Directors and other departmental heads within FX Plus, our university partners and other organisations that occupy the Penryn Campus to ensure that information regarding radon is being communicated effectively. Health & Safety Adviser The Health & Safety Adviser is the appointed Radiation Protection Supervisor (RPS) for FX Plus and reports into the Director of Estates. The Health & Safety Adviser has responsibility: To implement a programme of radon monitoring across the Penryn Campus in line with PHE guidance and resources from the RPA. To carry out suitable and sufficient risk assessments (with the support of the RPA) in radon affected areas and to reduce and manage doses to ensure that they are kept as low as reasonably practicable. Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 5

6 To develop and maintain a radon plan for the Penryn Campus. This plan will include records of all the radon measuring results, the radon monitoring frequency for all areas, and the mitigation measures and safe systems that have been taken to reduce the radon risk. To assist FX Plus on compliance with the requirements of the IRR99, and to ensure staff, students, contractors and other visitors are adequately informed about the risks from radon gas on the Penryn Campus. To develop and implement this policy. To ensure that the maintenance and servicing of plant and equipment for radon mitigation is carried out. Programme Manager The Programme Manager is the appointed Deputy Radiation Protection Supervisor (DRPS) for FX Plus and in the absence of the Health & Safety Adviser will have the same responsibilities. Building Services Team The Building Services Team (BST) is responsible for carrying out the function checks on installed powered mitigation systems to ensure that they are working adequately. The BST is responsible for carrying out the inspections and subsequent upkeep of the airbricks in all buildings at the Penryn Campus to ensure that airflows remain unobstructed. Records of these checks will be maintained. Staff All staff employed by FX Plus, UoE, Falmouth and FXU have a duty to comply with written health and safety instructions and procedures, report any equipment or procedural failings or any incident/exposure for which this policy applies and attend any training provided for health and safety. Statutory responsibilities Radiation Protection Supervisor (RPS) FX Plus as the Radiation Employer shall appoint one or more suitable RPSs as specified within regulation 17 (4) of IRR99. The RPS at the Penryn Campus will receive appropriate training in order to perform the task adequately. The RPS has a crucial role to play in helping to ensure adherence to the arrangements made by the Radiation Employer, and in particular, to supervise the arrangements set out in this policy and any local rules where appropriate. FX Plus s Health & Safety Adviser will undertake the role of RPS on behalf of FX Plus, Falmouth, UoE at Penryn Campus and FXU. However, the legal responsibility remains with the four employers at the Penryn Campus and cannot be delegated to the RPS. Radiation Protection Adviser (RPA) FX Plus as the Radiation Employer has the statutory duty to consult with an RPA to fulfil the requirement of regulation 13 of IRR99. The RPA advises on Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 6

7 compliance with IRR99 and possesses the specific knowledge, experience and competence required for giving advice on the particular working conditions at the Penryn Campus. PHE has been employed as the RPA by FX Plus. RPA advice is provided to the Penryn Campus via FX Plus. Retrospective notification Notification to the Health and Safety Executive (HSE) has been made retrospectively by FX Plus as the radon levels in the atmosphere at the Penryn Campus exceed 400 Bqm -3. FX Plus will cooperate fully with the HSE and provide the HSE with any additional information that they may require in a timely manner if requested. Restriction of exposure FX Plus shall, in relation to any work where radon levels exceed those specified within IRR99, take all necessary steps to minimise, so far as is reasonably practicable, campus users exposure to radon at the Penryn Campus. Where applicable, FX Plus will reduce radon levels by using engineering controls and adopting other means of restricting exposure, including reviewing existing mitigation measures. Risk and dose assessment Each of the four employers at the Penryn Campus (FX Plus, Falmouth, UoE and FXU) is required to assess the risk from exposure to radon in the workplace. Where radon concentrations exceed 400 Bqm -3, a risk assessment will be carried out to assess the potential doses to staff working in that particular area/building and to identify any further controls required to minimise exposure. Areas with high radon levels and high occupancy by regular users will be given priority over other areas/buildings. Dose estimates will be made using representative air concentrations and known occupancy information. For example, daytime working for 650 hours in an average radon concentration of 500 Bqm -3 corresponds to a dose of approximately 1 msv. Annual doses will be calculated using the average annual radon concentrations rather than the winter corrected maximum. Where work is of short duration, as measured radon concentration values may be used to calculate doses; these may be obtained from the use of passive or active radon monitoring results during the work. If the 400 Bqm -3 action level is exceeded, but a risk assessment concludes that estimated annual doses are below 1 msv, access to these areas need not be restricted and no other action should be required provided that a periodic review is carried out to ensure that conditions and working practices are unchanged, and dose estimates remain below 1 msv. Risk assessments will be reviewed periodically, particularly if there are any changes to working practices or occupancy levels, or in light of any new monitoring data that may significantly affect calculated doses to staff, students and other campus users. Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 7

8 Dissemination and implementation Due to the Penryn Campus being located in a known radon gas affected area where radon levels may exceed the Ionising Radiations Regulations 1999 (IRR99) action level of 400 Becquerels per cubic metre (Bqm -3), we will provide FX Plus employees, students and staff from Falmouth and UoE, and staff from FXU with appropriate information about radon gas levels at the Campus, the relative level of risk associated with exposure to it and our testing and mitigation programme. This is how we will share information: FX Plus website ( We will upload our Radon Management Policy to the Health & Safety pages of the FX Plus website for all to access, and will review and update it as required. We will upload general information about radon gas; a frequently asked questions section (FAQs); which buildings we are currently testing and monitoring; the mitigation measures that we are taking to reduce radon levels; and links to other information sources. We will upload Disruption Notices to as another means of informing regular users of particular buildings about testing and mitigation works. A regular user is defined as someone who is permanently based in a particular building, not as someone who uses it intermittently. Letters via Before we test a building, we will a letter to all regular users of the building via FX Plus s Executive Support Team Manager, UoE s Communications and Marketing Manager, Falmouth s Communications & PR Manager and FXU s communications representative. This letter will explain what radon is, what the test involves and where regular users of the building can access further information. Following our receipt of test results, we will share radon readings with those regular users in a timely manner and advise them of any mitigation works that may need to be undertaken before they commence. After the mitigation works, we will re-test the building, share radon readings with those regular users in a timely manner and advise them of any further mitigation measures that are required to ensure that radon levels are below the IRR99 winter corrected action level of 400 Becquerels per cubic metre (Bqm -3) in working environments and 200 Becquerels per cubic metre (Bqm -3) in domestic settings. We will include contact details for all Health & Safety Advisers across the partnership in all of these letters so that students and staff can raise their concerns or queries individually. Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 8

9 OpUp OpUp is FX Plus s weekly e-newsletter that is published each Friday and outlines disruptions and operational changes that can be expected at the Penryn Campus during the following week. We will include radon testing in OpUp as another means of communicating with students and staff. Meetings The Health & Safety Adviser for FX Plus will produce regular radon reports for the FX Plus Health, Safety & Wellbeing Committee and the FX Plus Board. Communications process Where radon testing and mitigation works are required at the Penryn Campus, the Health & Safety Adviser will draft radon communications to inform users of a particular building about the process, in the first instance. Such communications will then be reviewed by the Public Engagement & PR Manager for FX Plus, who will then share the text with Falmouth s Communications & PR Manager, UoE s Communications and Marketing Manager, FX Plus s Executive Support Team Manager and FXU s communications representative for input and approval. Once approved, UoE s Communications and Marketing Manager, Falmouth s Communications & PR Manager, FXU s communications representative and FX Plus s Executive Support Team Manager will inform all students and staff who are regular users of the particular building, via the approved communications channels that they have at their disposal. If a student or member of staff becomes concerned about the effect of radon on their health, they will be advised to contact their respective Health & Safety Adviser. Health & Safety Advisers will provide all the necessary information to concerned individuals in order to reassure them of the relative health risks and the precautions that are being taken to minimise exposure in a particular building/area where radon is above 400 Bqm -3. Operational arrangements for managing radon To determine the extent to which IRR99 applies and to enable an assessment of the risk from radon gas exposure to be carried out, the following radon testing protocol will be adopted across the Penryn Campus. Any deviation from this must be agreed in advance with the RPA. Initial testing Initial testing for radon where there is no monitoring data will be carried out in all buildings at the Penryn Campus in accordance with radon monitoring procedures. This will be for an initial three-month monitoring period using passive radon detectors. The applied winter corrected value (see Appendix B for definition) can Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 9

10 be used as a guide as to whether winter radon levels may exceed the action level, however it may overestimate the radon readings, so all testing will begin during the winter months whenever possible. Interim testing of routinely occupied areas with results exceeding 400 Bqm -3 Where radon results exceed the IRR99 threshold of 400 Bqm -3 following monitoring with radon gas passive monitors and where the estimated annual doses exceed 1 msv (See Appendix B for definition), new radon mitigation measures will be installed. Once mitigation has been installed, a prompt three-month measurement will be made to test its effectiveness. On-going monitoring where mitigation measures have been installed and have reduced radon levels below the 400 Bqm -3 threshold will be at a reduced frequency. Re-testing will be every two years over a three-month monitoring period using passive detectors. Digital monitoring devices such as the Canary or Ramon may be used for the two yearly re-test. The duration of the measurement will be agreed in advance with the RPA i.e. a one/two month mid-winter measurement. Although measurements may be made at any time of the year, it is the high levels in winter that determine the need for action. Therefore whenever possible, monitoring will take place during the winter. Where radon levels are found to be below the 400 Bqm -3 action level, and as part of our ongoing radon monitoring procedures, monitoring will be undertaken at intervals of five to ten years, or following any major structural changes to existing buildings. The frequency of testing is summarised below: Test Type Purpose Protocol Initial To identify buildings with Radon levels above 200 or 400 Bqm -3 Three-month passive Mitigation check Periodic Radiation Area Check that mitigation has reduced Radon below 200 or 400 Bqm -3 Check that mitigation remains effective over the long term. Twoyearly test To monitor levels in a building or area that are not to be mitigated Three-month passive after completion of mitigation works Two-yearly with passive or digital monitors (three-month with passive. one/two months with digital as agreed with RPA) Two-yearly with passive or digital monitors (three-month with passive. one/two months with digital as agreed with RPA) Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 10

11 Checking of installed mitigation measures Ongoing monitoring will be required to ensure that the mitigation measures installed remain effective and levels remain below the IRR99 threshold. Twoyearly monitoring for three months will be undertaken in such areas. Where doses to staff are managed in areas exceeding 400 Bqm -3 Ongoing two-yearly monitoring for three months will be carried out in any designated area classed as a Supervised Area or a Controlled Area. Placing of monitors Radon monitors will be located in areas identified by the RPS following the guidance set out in the PHE leaflet (Appendix A Guidance on Placing and Using Radon Monitors ). This leaflet provides advice on the types of rooms to test and an indication of the number of monitors required based on area. The monitors will be put in their proper locations as soon as they arrive, as they are recording all the time. The monitors will, whenever possible, be screwed to the walls and/or some fixed furniture using a P-Clip or cable ties and the monitor s plastic fixing loop. The monitors will be returned on the specified return date, along with a completed record return sheet. Maintenance and inspection of mitigation systems Where mitigation systems are installed, they will be adequately maintained to ensure that they remain functional and effective. Function checks on installed extraction and ventilation systems will be carried out and a check made to ensure that vents are not blocked or obstructed. Newly installed powered mitigation systems will be checked monthly for an initial three to six months to ensure that any failings due to manufacturing faults are identified quickly. After this initial period, checks will be made quarterly. Airbrick inspections will be carried out to coincide with the quarterly checks on powered mitigation. Clear instruction will be given to staff who perform the checks detailing who should be contacted and what steps should be taken in the event of a problem. Any repairs or corrective action will be carried out as soon as possible. Function checks will be carried out in conjunction with any required maintenance as advised by the supplier/installer i.e. fan/equipment should be serviced at 30- month intervals. The RPS will refer to the mitigation installation certificates for the specific service dates for each system. Mitigation type Powered mitigation Ventilation airbrick Inspection and Maintenance Intervals Following Inspection Service intervals installation intervals Initially monthly Every 3 months Every 30 months for 3-6 months Initial inspection Every 3 months N/A required Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 11

12 Local rules Local rules will be developed where staff are required to work in areas designated as a controlled area. The purpose of local rules is to set out the key arrangements to ensure that doses are restricted in a particular area. If local rules are required, these will be formulated with assistance from the RPA. Local rules will be actively communicated to employees who are working in an area subjected to local rules. Students, visitors, contractors and other campus users will also be made aware of any precautions to be taken while working in such areas. Monitoring of policy This policy will be periodically monitored through self-auditing and inspections of the radon management controls in place to ensure that all elements of the policy are being implemented effectively. Continued training of the responsible persons in relation to radon will be reevaluated following regulation or guidance change and advice from the RPA. Period of review This policy will be reviewed annually by the RPS and the RPA, unless; There are important changes to legislation or regulations. The arrangements set out within in this policy are believed to be insufficient to control and manage radon. There are new mitigation techniques and monitoring methods available that may influence how the policy is implemented. In any such event, the policy will be reviewed and appropriate changes will be implemented before the next review date. Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 12

13 APPENDIX A Guidance on the number of detectors required for an individual workplace WORKPLACE TYPE Offices and other individual or small rooms Open plan office, retail or workshop, up to about 2,000 m/2. Normally high occupancy Large area or spaces other than offices, public access areas, up to 5,000 m/2 Very large areas above 10,000 m/2 Basements Wholly underground NUMBER OF MONITORS One per 100 m/2 One per 250 m/2 One per 500 m/2, fewer if limited occupancy One for each distinct area with obviously different environmental conditions, up to one per 1,000 m/2 Only if occupied for more than one hour each week, then one in each separate room, section or area irrespective of size Depends on working patterns, contact PHE EXAMPLES Banks, shops, professional practices Administrative and call centres, light industry, hotels, schools, healthcare centres Large retail and public buildings Manufacturing or process plant, warehouses Retail, bank and professional storage areas Water industry, mines and caves * PHE guidance. Monitoring radon in the workplace: April 2010 Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 13

14 APPENDIX B Definitions of terms used within the Policy Radon-222 Radon is a natural radioactive gas. Isotopes of radon, different forms of the same element, occur in the three naturally occurring decay chains headed by uranium- 238, uranium-235 and thorium-232. These radionuclides are found naturally in trace amounts in most rocks and soils. Radon-222, which occurs in the uranium- 238 decay chain, has a half-life of 3.8 days, sufficiently long to allow it to escape from the ground and accumulate in the air within buildings. The other two isotopes, radon-219 and radon-220, have half-lives of 3.9 seconds and 54 seconds, respectively, and are less able to escape from the ground before undergoing further radioactive decay into solid elements. Attention is therefore focused on radon-22 which is referred to as radon in this policy. Radon is one of a group of elements, called noble gases, that also includes helium and neon. These elements do not readily react to form chemical compounds and are simple gases under most conditions, however, radon undergoes radioactive decay by alpha-particle emission to form a short-lived isotope of polonium. Several further short-lived decay products are formed in a series of decays by alpha- and beta- particle emission before a long-lived isotope, lead-210 (half-life 22 years), is reached. The risk of lung cancer following inhalation of radon is largely attributed to alpha-particle emissions from the short-lived decay products. (Text taken from PHE advice document Limitation of Human Exposure to Radon 2010) Dose Dose estimates are made using representative air concentrations and known occupancy information; for example, daytime working for 1000 hours in an average radon concentration of 500 Bqm -3 corresponds to a dose of approximately 1 msv. Annual dose estimates are calculated using the average annual radon concentrations rather than the winter corrected maximum. Winter corrected Estimates of winter-corrected radon concentrations are provided in radon measurement reports issued by Public Health England along with as measured values. A winter correction factor is used to estimate the likely maximum (midwinter) radon concentration, as radon levels are typically higher in the winter months. Where as measured values are below the IRR99 threshold but the winter-corrected value is slightly above, testing will be arranged in the winter months to determine if the threshold has been exceeded. Annual average The domestic action level refers to the annual average concentration in a home. Radon measurements are carried out over three months, to average out shortterm fluctuations. PHE recommends that radon levels should be reduced in homes where the average is more than 200 Becquerels per metre cubed (200 Bq m -3 ). Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 14

15 Becquerels per cubic metre (Bq m -3 ) The amount of radon is measured in Becquerels per cubic metre of air (Bq m- 3 ), where one Becquerel is one atomic disintegration per second. The Ionising Radiations Regulations 1999 (IRR99) require action to protect employees if the average radon gas concentrations measured over a 24 hour period exceeds 400 Bqm -3. PHE recommends that action to reduce radon levels is taken if the annual average radon concentration in a domestic property is at or above the Action Level of 200 Bqm -3. msv In the UK the PHE has calculated that on average people are exposed to about 2.7 millisieverts (msv) of radiation a year. A millisievert is a measure of radiation dose which accounts for the fact that ionising radiation can affect different parts of the body to differing degrees. The millisievert dose also allows for the different effects of different types of radiation, x rays, gamma rays, neutrons, alpha particles and beta particles. Risk to health from radon gas Breathing in high levels of radon gas over a prolonged period is considered a health risk. Radon gas decays into radioactive particles that can get trapped in your lungs as you breathe. As they break down further, these particles release small bursts of energy. This can damage lung tissue and can be linked to some incidents of lung cancer. Falmouth Exeter Plus Radon Management Plan (Version 1.0, May 2014) Page 15

16 APPENDIX C Summary of legislation and guidance Statutory legislation Guidance documents Location Health and Safety at Work etc. Act 1974 (HSAW) Ionising Radiations Regulations 1999 (IRR99) Management of Health and Safety Regulations 1999 (MHSWR) Approved Code of Practice L121 Approved Code of Practice L21 Reference site on radon from, Public Health England Building Research Establishment (Bre): PROTECTING NEW BUILDINGS END OF DOCUMENT Page 16