Corporate Property Radon Management Arrangements and...

Oxfordshire County Council Radon Safety Management

Radon Safety Policy, Arrangements and Procedures

Oxfordshire County Council November 2015

Document Control P&F 2015/V2 Next Review Date: November 2016

Radon Safety Management

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TABLE OF CONTENT

Table of Contents

1. Radon Policy Statement ............................................................................................. 3

2. Introduction ................................................................................................................. 4

3. Background to Radon ................................................................................................ 4

4. Organisational and General Responsibilities .......................................................... 5

5. Procedures for the Management of Radon ............................................................... 8

6. Identification of Suitable Radon Monitoring ........................................................... 11

7. Building Protection ................................................................................................... 14

8. Use of Contractors .................................................................................................... 14

9. Radon Incident Reporting/Investigation ................................................................. 14

10. Review of the Policy and Procedures ..................................................................... 15

11. Appendices ............................................................................................................... 16

.


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1. Radon Policy Statement

1.1. Policy Statement The Policy of Oxfordshire County Council (OCC) is to:

Maintain a safe and healthy environment in premises used by OCC.

Comply with all statutory requirements, regulations & ACoPs concerning the control of radon.

Manage the risks relating to radon where they remain in buildings in order that they are minimized as far as reasonably practicable.

Remove, or reduce to an acceptable level, the radon risk where the risk to building users is assessed as being unacceptable.

Implement procedures through awareness to ensure radon risks are minimized.

Ensure that all OCC sites are risk assessed with regard to radon and that these risk assessments are reviewed at least every two years.

Review all policies and procedures on an annual basis as a minimum.

1.2. Contact Details

Oxfordshire County Council (OCC) Property & Facilities (OCC) Cuffas Lea House 3500 John Smith Drive Oxford OX2 4WD Tel: 0808 156 6659 E-mail: [email protected]

Service Provider (SP) Carillion Cuffas Lea House 3500 John Smith Drive Oxford OX2 4WD Tel: 0808 156 6659 E-mail: [email protected]

Health & Safety (H&S) Corporate Services County Hall New Road Oxford OX1 1ND H&S Helpline: 03300 240849 E-mail: [email protected]

mailto:[email protected]:[email protected]:[email protected]


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2. Introduction

This document sets out the policy and strategy to minimise the risk from exposure to radon and its decay products to:

any persons using County Council buildings

County Council employees in execution of their duties, and

other persons exposed through the Authority’s undertakings.

This document should be used in conjunction with any relevant legislation, Approved Codes of Practice, Health and Safety Executive (HSE)/Public Health England (PHE) guidance and other specific procedures relating to the presence of radon in buildings.

Within Oxfordshire certain types of rock formations give rise to higher than normal concentrations of radon. Areas where it is estimated by the PHE that 1% or more of properties have a radon level above 200 Becquerels/m³ (Bq/m³) are designated ‘radon affected areas’.

Currently the workplace action level specified in the Ionising Radiations Regulations 1999 is 400 Bq/m³ and the maximum annual effective dose for people not employed by a radiation employer is 1millisievert (mSv).

Exposure to radon and its decay products increases the risk of developing lung cancer.

3. Background to Radon

3.1. What is Radon? Radon (more properly known as radon-222) comes from Uranium which occurs naturally in many rocks and soils. Radon is a naturally occurring radioactive gas that can seep out of the ground and build up in houses, indoor workplaces and other enclosed buildings.

3.2. Where is it found?

Radon is found everywhere in varying levels throughout the country. Radon collects in underground spaces such as basements, caves and mines. High concentrations can also be found in the ground floor of buildings because they are usually at slightly lower pressure than the surrounding atmosphere; this allows Radon from the sub-soil underneath to enter through cracks and gaps in the floor and building structure.

3.3. The risk

Radon contributes by far the largest component of background radiation dose received by the UK population. The largest of these is found in domestic dwellings (due to the longer time spent there) but significant exposures are possible in workplaces. See PHE Understanding Radiation.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/297619/geho0409bppe-e-e.pdf


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3.4. Legal Requirements The Health and Safety at Work Act 1974 section 2 requires all employers to conduct their work so that, so far as is reasonably practicable, employees will not be exposed to health and safety risks and which might affect their health and safety. Section 3 places a duty on employers to conduct their undertakings in such a way as to ensure, as far as is reasonably practicable, that persons not in their employment are not exposed to risks to their health and safety. Section 4 contains general duties for anyone who has control to any extent over a workplace. In addition the Management of Health and Safety at Work Regulations 1999 requires employers to assess the health and safety risks including to third parties such as tenants who may be affected by high levels of Radon and to make appropriate arrangements to protect them.

3.5. The Ionising Radiation Regulations 1999 (IRR99) These regulations shall apply to “any work carried out in an atmosphere containing Radon 222 gas at a concentration in air averaged over a 24 hour period exceeding 400Bq/m³.

4. Organisational and General Responsibilities

4.1. Chief Executive Whilst the Chief Executive has overall responsibility for health and safety within the Council the management of radon in OCC properties is delegated to the Service Manager – Property & Facilities.

4.2 Appointed Person Radon Safety

The Service Manager Property & Facilities, who will be the Appointed Person for Radon Safety, will:

Ensure, so far is reasonably practicable that OCC Radon Safety Management System is established and maintained

Advise the Elected Members on the resources required to maintain Radon Safety Management within the Authority

Ensure effective management systems are in place to ensure the operating procedures for the management of the risk from radon in Council properties

Ensure the monitoring, remedial installation maintenance and record keeping of the identified premises’ radon levels are carried out in a manner that maintains a safe working environment for employee and others who occupy the identified premises

Appoint a Responsible Person –Radon Safety in writing.

4.3. FM Technical Officer - Responsible Person Radon Safety The FM Technical Officer will:

Manage the radon policy and procedures

Implement a strategy for undertaking and monitoring the County Council’s premises for radon Ensure that an up to date register and action plan is maintained, including a record of all

protective measures undertaken to reduce concentration Where necessary provide information for heads of establishments, premises managers,

employees and other people affected

Implement changes to the policy occurring as a result of a review

Manage the budget for the maintenance of radon safety Ensure that direct monitoring of radon levels are carried out in all relevant buildings and


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premises/workplaces Ensure suitable risk assessments are undertaken following the results of the direct monitoring and

identify suitable and sufficient control measures and/or remedial work Arrange for remedial works to be carried out when radon gas levels are found to be above the

specified action level within buildings/workplaces Where establishments have areas with access restrictions to limit radon exposure, will audit

employees’ personal exposure records to ensure persons are not exposed to more than their annual allowable dose

Ensure regular inspection and maintenance of all engineering systems provided for maintaining radon concentrations at a safe level.

Ensure that prior to occupation of leased buildings, radon levels are monitored and managed by the owner/landlord

Liaise with the appointed Radiation Protection Advisor Provide guidance and advice as required Audit employees and establishments for compliance with the radon management policy and

procedures.

4.4. Service Provider The Services Provider will:

Provide advice and guidance to the Responsible Person

Where necessary provide information for heads of establishments, premises managers, employees and other people affected

Liaise with the Radiation Protection Advisor

Implement changes to the policy occurring as a result of a review

Ensure that any training undertaken is suitable and appropriate

Implement radon monitoring surveys

Oversee remedial work and implement measures to ensure that such measures are effective

Maintain an effective record system

Undertake and review risk assessments

Undertake audits of personal monitoring forms and mechanical ventilation checks

Implement measures, where necessary, to restrict access to radon affected areas

Audit establishments for compliance with the radon management policy and procedures

Where establishments have areas with access restrictions to limit radon exposure, audit employees’ personal exposure records to ensure persons are not exposed to more than their annual allowable dose.

4.5. Directorates / Head of Establishment, Premises Managers or Other Nominated Persons

Familiarise themselves with the County Council’s policy and procedures for managing exposure to radon of employees and other persons

Ensure through delegated responsibility that the policy and procedures for managing exposure to radon are observed at all times

Where employees are required to keep records of personal exposure to radon, monitor such exposure to ensure the annual allowable dose is not exceeded

To liaise, where necessary, with OCC Health and Safety team on the Council’s radon policy, procedures and personal exposures

Where indicated by risk assessment, to check and record that any mechanical remedial measures to reduce the level of radon in their premises are in operation.


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4.6. Employees

Will receive the appropriate information, instruction and training to enable them to comply with any procedures and other control measure that are in place to ensure radon safety is correctly managed within OCC Properties.

4.7. Responsibilities for Managing Radon in OCC and other Relevant Premises

4.7.1. County Corporate Buildings OCC is responsible through Property & Facilities for the management of the particular establishment.

4.7.2. Properties leased in by OCC

The Landlord is responsible for radon safety. Refer to the terms of the lease for details. OCC is responsible, through the Service Provider, for ensuring where applicable that the management of the premises includes radon safety.

4.7.3. Properties leased to a third party by OCC. OCC is responsible in the first instance for leasing the premises in a suitable condition. T h e Service Provider is responsible for checking that radon safety management is in place prior to the occupation of the premises by a new tenant.

Thereafter the tenant is responsible for the premises radon safety.

4.7.4. Premise where OCC are tenant

The Landlord is responsible for radon safety management. OCC staff have a duty to co-operate with the landlord, so that the landlord’s arrangements, policies and procedures regarding radon safety are complied with. OCC is responsible for ensuring that the management of radon safety in the premises is suitable and sufficient and undertake monitoring as necessary.

4.7.5. OCC Maintained schools

This includes all schools except Voluntary Aided and Academies

OCC is responsible through Property & Facilities and the Head Teacher.

4.7.6. Voluntary Aided Schools The Governing Body is responsible for managing the premises radon safety.


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4.7.7. Academy Schools The Governing Body is responsible for managing the premises’ radon safety.

5. Procedures for the Management of Radon

5.1. Performance Standards These procedures are designed to ensure that OCC, and or companies/individuals who undertake radon protection related work for the Council are able to achieve the standards/best practice to comply with regulations/legislation. Areas that are covered but not restricted to:-

Clients (OCC) – liaison/requirements

Reporting - Status - compliance

Monitoring - new construction (compliance to current protection standards) - impact on existing radon reduction measures assessed - design/installation - remedial measures safety checks - defects/repairs

5.2. Risk Management

Radon safety risk management shall address issues arising from:-

Requirements of Regulations - the criteria for the identification of potential hazards and risks

relating to the premises radon levels

Prioritisation of identified risks

Formal risk assessments

Personal exposure - monitoring the effectiveness of existing risk control methods

Auditing the management action/systems and the risk review process.

5.2.1. Premises Risk Assessment

Where remedial measures have been installed, a premises Risk Assessment will be issued to the premises Duty Holder. The Duty Holder will be required to check the operation/condition of all installed measures on a weekly basis, e.g. that fans are running or air vents have not been blocked etc.

5.3. Monitoring Programme

Where required, radon monitoring will be carried out at suitable intervals commensurate with the risk based upon published geological information, radon data and/or previous monitoring results.


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All County Council premises or premises where County Council employees are permanently based, in radon affected areas will be monitored for the presence of radon

Premises in areas not designated as ‘radon affected’ will be monitored based on an assessment of the risk

In premises where the level of radon is found not to be above the action level as specified in current legislation, re-monitoring will be carried out based on an assessment of the risk

After remedial measures have been installed to reduce the level of radon in a premise the radon level will be immediately re-monitored to show that such measures are functioning correctly and effectively

Premises where remedial measures are in place to reduce the level of radon will be monitored on a regular basis to ensure that such measures remain effective

The Service Provider will check that these remedial measure checks are been undertaken

All below ground workplaces (a work place that is occupied >52hrs/yr) in OCC properties will be risk assessed for radon irrespective of the status of the Radon Affected Areas status

The Radon Protection Advisor will be consulted in matters regarding Radon risk assessment and the frequency of monitoring.

5.3.1. Frequency of Monitoring

The frequency of monitoring will be determined by risk assessment for each individual property. The Risk Assessment will be carried out by the Service Provider in consultation with the Radon Protection Advisor. Generally these guidelines will be followed:-

Where levels of radon are found to be less than 400 Bq/m³ (200 Bq/m³ for residential premises) at the initial measurement, the monitoring of radon levels will be monitored at 3 to 5 year intervals. The frequency of monitoring will be decided after consultation with the Radon Protection Advisor.

Re-monitoring will be undertaken after any significant refurbishment or change of use. Where an engineering remedial solution is identified as the most appropriate reduction method, this will be undertaken as soon as practically possible. After the engineering solution has been installed, direct monitoring of the radon levels will be undertaken to ensure the effectiveness of the remedial measures. Monitoring will be undertaken for 3 months following the remedial work, then annually for 3 to 5 years and thereafter at suitable intervals. Re monitoring will also be undertaken after any significant refurbishment or change of use. The frequency of all re-monitoring will be decided after consultation with the Radon Protection Advisor.

Radon Protection Advisor To comply with Regulation 13 of the Ionising Radiations Regulations 1999, a Radon Protection Advisor will be consulted as appropriate. The current advisor is:

Rebecca Coates PropertyCo Ltd South Vaults Green Park Station Green Park Road Bath, Somerset, BA1 1JB


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5.4. Maintenance of Records

5.4.1. OCC Radon Data Base

The Service Provider’s Radon management data base identifies each OCC property by a Unique Property Reference Number (UPRN). Radon information relating to a property is filed under the UPRN in the Radon management database system. Records will be held for 50 years from the date of production.

The radon gas data base is a live document and will contain:-

The historic details of the property’s radon level measurements

Risk posed by the property’s location and occupation

Monitoring strategy – Refer to section 5.3

Details of all radon related remedial works (installation/maintenance) undertaken at the property to control the levels of radon in the premise

Areas of controlled access

Correspondence relating to the premise.

5.4.2. On-Site Records

The Head of Establishment/Premises Manager shall keep a copy of the results of any monitoring carried out. Radon risk assessments for a premise shall be retained on site. Where mechanical ventilation is installed to reduce radon levels the Head of Establishment/Premises Manager should keep a record of any checks carried out to ensure the ventilation is operating. (Refer to appendix 4). Where access restrictions are in operation to control personal exposure to radon, such persons are required to fill in a Personal Exposure Record form, these forms should be retained. (Refer to Appendix 2). A person should not receive more than 1mSv dose of radiation from the workplace in a calendar year. Anyone required to work in a designated radon affected area will be required to record their time spent in that area on the Personal Exposure Record form. (The risk is cumulative. Short, infrequent visits are not of concern). From the site specific risk assessment and time spent in the affected area, the cumulative dose can be calculated. If a cumulative dose of 0.5 mSv is reached (i.e. 50% of the annual allowable dose) then their line manager should be informed.


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6. Identification of Suitable Radon Monitoring

6.1. Radon monitoring

Passive Monitoring

Action Level200 – 500Bqm3 Residential400 – 1000Bqm3 Commercial

Passive Monitoring

Level > 500Bqm3 Residential > 1000Bqm3 Commercial

Immediately Re-monitor using Active Monitors

Consider: Closure or restrictions to

affected area; Personal monitoring Site-specific risk assessment Inform employees

Aboveaction levels confirmed

ContinueActive Monitoring

for 1 monthPassive monitor

next cycle

No

RPA consulted.Remedial actions

agreed & Work order raised

Progress of remedial works monitored by Project Co-ordinator

On completion of remedial works

Active Monitoring

Yes

Radon levels reduced below

Action Level

No

Passive MonitoringAnnually for 3 to 5

years

Update Radon Risk

Register

Yes

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6.2. Non Residential Workplaces Located In Radon Affected Areas (Commercial)

RADON MANAGEMENT PROCESS

Cap

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Esta

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Car

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arill

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IMS

Man

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Pro

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Man

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th

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(P

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Rad

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Pro

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Co

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NoProject Co-ordinator

uploads onto Risk Register

Above400Bq Action

Level?

InRADON

affected Area?>1% Risk

No Further Action

No

Re-monitor 3

to 5 yearly

RADON Register updated

IMS Manager liaises with RPA and agrees

interim and long term remedial

measures

Estates team provides updated property list

to Project Co-ordinator

Hassite been

monitored previously?

No

Yes Yes

Yes

No

Site monitored for 3 months

RPA advises on interim and long-term

remedial actions

Estates team checks if new acquisitions have

been Risk assessed and pass information to Project Co-ordinator

Estates team reviews RADON register and passes on info

with disposals

Project Co-ordinator

sends letter to site to inform

of high reading and planned

remedial actions

Project Co-ordinator issues Notification to

HSE

Where necessary, visit site with IMS

Manager

Project Co-ordinator instructs contractors

Contractors carry out remedial works


advises IMS Manager

Project Co-ordinator arranges

monitoring immediately

after remedial works

Site monitored for 3 months

Above400Bq Action

Level?

No

Yes


advises IMS Manager

IMSManager reviews

remedial measures with RPA

Project Co-ordinator arranges

re-monitoring after 1 year

Premises management ensures maintenance of remedial

measures

Project Co-ordinator sends

letter to site advising low

reading

Letter to site advising of remedial measures

If below 400 Bq (200Bq for

Residential) after 1 year re-monitor

every 3 to 5 years.

RPA to advise on Re-monitoring

frequency

RPA advises on Re-monitoring frequency

YesorNo

Yes or No

Propertyhas a basement

occupied >52hrs/yr?

Yes

Carillion Project Managers inform Estates team of

significant refurbishment to property

Project Co-ordinator arranges monitoring

200Bq Action Level for Residential Accommodation

Capita Project Managers notify Estates team of

New buildings and extensions to existing

buildings

Project Co-ordinator sends notification to HSE to inform

of high reading & planned remedial actions in

pursuance of Reg 6 of IRR 1999


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7. Building Protection 7.1. New Buildings

As it is better to prevent radon from entering a building than to try to remove it once present, all the Council’s new buildings in radon affected areas and those areas where the Building Research Establishment recommend basic radon measures should be considered will be designed and built with basic radon prevention measures in place. Consideration will be given to introducing basic radon prevention measures in all the Council’s new buildings.

7.2. Existing Buildings

Where an existing building has been shown, through monitoring, to have a radon level above the recognised action level remedial measures will be designed and implemented as soon as is reasonably practicable. Any such measures will be appropriate to the levels of radon detected, the type of building affected and the occupancy rates.

Following the introduction of remedial measures the premises will be monitored as detailed in Section 6.

In certain circumstances access restrictions may be introduced on a temporary basis until it is shown that radon levels have been reduced to an acceptable level.

8. Use of Contractors

All property related work to OCC Corporate Estate will be carried out by the OCC Service Provider who will carry out radon remedial work. They are required to be familiar with the principles of such work and, dependent upon the type and amount of work involved, comply with the Council’s policies on:-

Entry into the Council’s premises

Asbestos

Fire/Hot Work

Confined spaces

Radon

Emergency Procedures

9. Radon Incident Reporting/Investigation

Radon levels that pose, or have the potential to pose, immediate threat to the safety of persons and/or property will be notified to the HSE. The Radon Protection Advisor will be consulted and appropriate interim measures will be put in place until long-term remedial actions can be implemented.


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10. Review of the Policy and Procedures

10.1. Annual Review

The radon policy will be continually monitored and reviewed annually by Property & Facilities, OCC Service Provider and OCC Health and Safety team.

Any changes to the policy that result from the annual review will be reported to and authorized by the Appointed Person and actioned by the Responsible Person.

10.2. Review as a result of legislative changes

It is the responsibility of the OCC Responsible Person to ensure that legislative changes relating to radon are monitored and any necessary actions, including amending the policy, are implemented.

10.3. Review as a result of incidents, complaints or corrective action

It is the responsibility of the OCC Responsible Person to monitor and act upon incidents, complaints and any corrective action taken relating to the management of radon that will have an impact upon the effectiveness of the radon policy.

Any changes to the policy that result from this review will be actioned by the Responsible Person.


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11. Appendices


Page 17 of 23

Appendix 1 – Generic Risk Assessment for Management of Radon


Page 18 of 23


Page 19 of 23


Page 20 of 23

Appendix 2 – Record of Personal Radon Exposure

Name…………………………………….. Employee Number………………..

Job Title…………………………………………………………………….....………

Section………………………………………………………………………..…

Department……………………………………………………………………

Area Date Task Time (hrs)

% of M A E (see over)

TOTALS


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NOTES

Radon affected areas are areas where the concentration of radon is above 400 Becquerels/m³ (Bq/m³).

M A E = Maximum Annual Exposure = 1 milliSievert (mSv)

Example:-

In the basement of a building the measured radon level was 640 Bq/m³. Hence 774 hours exposure would be required in one year to reach a dose of 1mSv.

Therefore 7 hours exposure in the area is approximately equivalent to 1.0% of the MAE.

Time spent in the affected area should be entered onto the form above e.g.

Area Date Task Time (hrs) % of M A E

Basement 10/01/11 Filing 5 0.7 “ 11/01/11 “ 4 0.6 “ 13/01/11 “ 5.5 0.8

% MAE = Hours spent in area Hours equivalent to 1% MAE

This form should be returned to your manager when either:-

a) 50% of your MAE has been reached, or b) one year from the first entry.

Notes for Managers

No person should receive an exposure of more than 1mSv from their workplace activities in any rolling year.

If a person has received 50% of their exposure, especially in a relatively short period of time, then working practices should be examined to determine if exposure times can be reduced. If this is not possible then job rotation will be necessary.


Page 22 of 23

Appendix 3 – Example of restricted access notice

CONTROLLED AREA

THIS AREA IS AFFECTED BY RADON GAS.

LIMITATIONS ON ACCESS ARE:-

ANY PERSON REQUIREDTO WORK IN THIS AREA FOR

LONGER THAN 2 HOURS IN ANY ONE DAY…..

…..MUST CONSULT the Responsible/Appointed person for the property before proceeding


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Appendix 4 – Checking and recording the operational state of remedial measures

Where mechanical equipment has been installed to reduce the level of radon within a building each fan should have been fitted with a fan ‘proving device’. This device indicates as to whether or not the fan is operating. If a fan fails for any reason the device activates a light.

Each fan should be checked weekly and its operational condition recorded. (Form ????????). If an indicator light is showing the Property & Facilities Helpdesk should be informed in order that repairs can be undertaken.

Radon Protection Measures

Form ????????). Record of the operational condition of radon reduction measures

Date

Condition of premises radon

reduction measures

Defects

Action Taken

Property & Facilities Helpdesk 0808 156 6659

Each remedial measure identified must be checked weekly and its operational condition recorded.

Guidance Notes

Mechanical remedial measures to reduce radon gas should operate constantly and should not be switched off for any reason other than repair or maintenance.

The neon light attached to the fused spur outlet should be on at all times. This indicates that the power is on. It does not indicate that the fan is working.

Where a fan failure device is fitted, a separate, second box adjacent to the fused spur has an

amber neon light, when on indicates that the fan has failed. Air bricks that form part of the ventilation system – clear/good condition.

Check Radon vents stack for damage/incorrect use, e.g.:-

o Waste water connected to stack o Rain caps removed o Stack being capped off when re-roofing o Stack damaged due to vandalism

If you have any concerns regarding the correct operation of the system contact your Property & Facilities Helpdesk immediately on 0808 156 6659.

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