Which radioactive substance activities are ‘out of scope’?
Most radioactive substances are required by law to be regulated and this usually means obtaining a permit from the relevant regulator.
For very low concentrations of Naturally Occurring Radioactive material (NORM) in solids liquids and gases and for solids and “relevant liquids” of other radioactive substances, the legislation contains “out of scope” values (see Tables 1 and 2 of Schedule 23 to EPR2010 and Tables 2 and 3 of Schedule 1 to RSA93).
Below these values the substance poses such a low risk that no special precautions need to be taken regarding its radioactive content therefore the radioactive waste legislation does not apply to them. Such substances are regarded as ‘out of scope’.There are no restrictions under EPR or RSA93 to keep or use radioactive materials, or accumulate and dispose of radioactive waste regarded as ‘out of scope’.
Above these “out of scope” values, the law states that regulation is required. There are two alternative approaches to regulation envisaged: for higher risk radioactive substances a permit is required from the appropriate environment agency; but, for some lower risk radioactive substances the standard conditions of an exemption may be the proportionate approach to regulation.
Which radioactive substance activities are considered exempt?
Some practices or products involving radioactive substances as well as being low risk are also very widespread; these include cases in which the radioactivity is an essential property, eg smoke detectors. If we were required to issue individual permits to each user in these cases, this would be a massive administrative burden on us and you.
The list of specific guidance documents above indicates the types of activities and items that are covered by exemption provisions. “Exempt” means that no permit is required under EPR or RSA93 to keep or use such radioactive sources, or accumulate and dispose of such radioactive waste, provided that the conditions specified are met.
Details of which radioactive substance activities are regarded as ‘exempt’ can be found on the Environment Agency’s website. Here is a list of their guidance documents:
- General guidance on the use of exemption provisions
- Very low level radioactive waste
- Medical and veterinary use of radioactive sources
- Radioactivity in museums
- Waste sealed radioactive sources
- Small sealed radioactive sources
- Uranium and Thorium
- Small amounts of open radioactive sources
- Guidance on lamps containing radioactive substances
- Guidance on radioactive material and radioactive waste 'stored in transit'
- Guidance on interpretation of 'Relevant liquid'
- Guidance for NORM industrial activities on how to comply with the radioactive substances exemption regime