Legislation for the FRCR Physics Exam: IRR17, IRMER, ARSAC and EPR Explained

Legislation is the topic many FRCR Part 1 Physics candidates dread. It’s also one of the most scoreable areas in radiation protection, once you know which facts are current. The regulations have changed, and older revision material hasn’t always kept up. This guide is built from the source legislation on the UK government website, so you’re revising the facts the exam tests now.

Practising outside the UK? You still need to know UK legislation for FRCR Part 1 Physics.

→ IRR17: protects workers and the public. Enforced by the HSE.

→ IRMER 2017: protects patients and others undergoing medical exposures. Enforced by the CQC in England.

→ ARSAC licensing covers giving radioactive substances to people, under IRMER.

→ EPR: covers radioactive waste. Enforced by the Environment Agency.

Justification: the benefit must outweigh the risk. Optimisation: doses kept as low as reasonably practicable. Dose limitation: limits apply only to workers and the public. Patients have no dose limits.

Dose limit, constraint, DRL or investigation level?

• Dose limit: a legal requirement.

• Dose constraint: a planning tool.

• DRL: a typical dose, not a legal limit.

• Investigation level: a level that triggers a review (15 mSv a year for workers under IRR17).

• HSE tiers: notification for low-hazard work, registration for X-ray, CT and fluoroscopy, and consent for nuclear medicine and radiotherapy.

• Employer: holds overall legal responsibility. In an NHS trust, that’s the CEO.

• RPA: advises the employer and can be an external organisation.

• RPS: an employee, usually a senior radiographer, named in the local rules.

• Annual limits: employees 20 mSv effective and 20 mSv to the lens; trainees under 18, 6 mSv; members of the public, 1 mSv.

• Pregnancy: once a worker has told her employer in writing, the dose to the fetus must stay under 1 mSv for the rest of the pregnancy.

• Classified workers: likely to receive more than 6 mSv a year. They must be 18 or over and must have dosimetry. Their dose records are kept until age 75, or for at least 30 years.

• Controlled areas: likely to exceed 6 mSv a year (or 7.5 µSv/h) and physically marked off. Supervised areas: likely to exceed 1 mSv a year, with signs.

The referrer provides the clinical information, the practitioner justifies the exposure, and the operator carries it out, which includes reporting. Referrers and practitioners must be registered healthcare professionals, so a solicitor or a Border Force officer can never be a referrer.

DRLs: national DRLs are set at the third quartile of national dose surveys. One patient going over a DRL isn’t unlawful. If a DRL is exceeded regularly, the employer must review practice. Significant accidental or unintended patient exposures are reported to the CQC. Incidents involving workers or the public are reported to the HSE.

You need an employer licence for each installation and a practitioner licence for whoever justifies the procedure. Licences last up to five years. Staff who carry out the injection don’t need a licence, and neither do trainees supervised by a licensed practitioner.

• 13 mSv to the abdomen (women of reproductive capacity, IRR99): removed under IRR17.

• 150 mSv lens limit: now 20 mSv.

• IRMER enforced by the Healthcare Commission: now the CQC in England.