The High Activity Sealed Radioactive Sources and Orphan Sources Regulations

A Guide to HASS 2005 Regulations

The HASS Regs are to be fully implemented in to UK legislation by 31 December 2005, in accord with council directive 2003/122/EURATOM (the HASS Directive).

In summary the Regs are aimed at:

1. Preventing the exposure of workers and members of the public from inadequate control of high activity sealed sources (HASS), and
2. Ensuring the security of HASS and other sealed sources (which present a similar potential hazard) on civil non-nuclear sites.
   

What is a HASS?

A source whose activity at the time of manufacture exceeds the relevant HASS threshold. For the radioisotopes in common use these are listed below.

Note: the HASS regs do not apply to natural uranium or natural thorium at any activity level, nor to gaseous tritium light devices (GTLDs).

A source ceases to be a HASS when its activity falls below the relevant Exemption Level.

The vast majority of sealed sources used in industry and research are not affected by the HASS regulations as their activity is below the requisite thresholds.

If the regulations apply - what is required?

The HASS Regs will:

1. Amend RSA93 such that those affected by the changes will need to obtain a new or amended Registration or Authorisation and comply with the relevant conditions prescribed for the safekeeping, accounting and proper disposal of HASS.
2. ) Introduce a regulatory regime for ensuring the security of radioactive sources on civil, non-nuclear sites. This will apply to both HASS and other sealed sources which are a 'similar level of potential hazard'*.

* Any source, or collection of sources, in a single storage or use location, which falls in to any of the source categories 1 to 4 in the scheme set out in the National Security Advice Centre's document Security Requirements for Sites and Sectors working with Radioactive Sources (NSAC, October 2005).

When do the HASS regulations apply?

Whilst the requirements apply to new HASS from 1 January 2006, they do not have to be applied to existing sources until 1 January 2008.

From these respective dates those affected must be in possession of a Registration (or amended Registration) for the keeping and use of a HASS and/or an Authorisation to accumulate a waste HASS.

HASS Security requirements

New arrangements for ensuring the security of sources will be introduced in the new HASS licences. In determining approval for a HASS licence the EA must be satisfied that:

1. The applicant has adequate arrangements for the safe management of HASS, including when they become disused sources;
2. The applicant has made adequate financial provision for the safe management of sources when they become disused sources;
3. The applicant has adequate security measures in place appropriate to the source and the premises in question.

Similarly, in respect of sealed sources which are not HASS but are a 'similar level of potential hazard', the Agency will need to be satisfied of 3) above, prior to issuing a licence.

For those with existing sources which are a 'similar level of potential hazard' there is no specified timetable for bringing in the security requirements. However, site licences for the higher risk sites will be amended proactively by the Envnt Agency through 2006/07 to introduce the security requirements. Other sites should expect to have their Registrations amended through 2008.

If a variation is required to an existing license, the Environment Agency will use the opportunity to modify the registration to bring in the new requirements. This is applicable for both HASS users and those with sources of a 'similar level of potential hazard'.

How to apply for a HASS licence and what is the likely cost?

Arrangements need to be in place for the whole life of the source before a Registration licence is granted, including some suitable means for guaranteeing disposal. New HASS Registration licences will have their own application cost and subsistence charge.

For 2006/2007 the costs are £1,996 for application and £1,311 subsistence charge.

For those with a band 4S licence (registration concerning the keeping and use of sources of a 'similar level of potential hazard to a HASS') the costs are £1,442 for application and £1,177 subsistence charge.

This band covers those who have a source under an existing Registration which will be classified as a high activity source under the directive.

Radman Associates is a long established RPA Body formally recognised by the HSE. For Radiation Protection Advice (including current UK legislation) and for RPS Training please contact Radman.

The High Activity Sealed Radioactive Sources and Orphan Sources (HASS) Regulations 2005

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HASS Regulations 2005

What is a HASS?

If the regulations apply - what is required?

When do the HASS regulations apply?

HASS ecurity requirements

How to apply for a HASS licence and what is the likely cost?

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