Radioactive Sources & Radioactive Material Users
Proportionate advice across the full lifecycle of radioactive material
RP Alba Ltd supports organisations that use, store, maintain or manage radioactive sources and radioactive material, including both sealed and unsealed radioactive substances.
Our advice recognises that regulatory duties apply across the entire lifecycle of radioactive material — from acquisition and use, through storage and security, to eventual transfer or disposal — and that different regulatory regimes apply at different stages.
Support can be provided on a stand-alone basis (RPA or RWA), or in an integrated manner where both radiation protection and environmental considerations apply.
Types of radioactive material we support
We commonly advise organisations working with:
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Sealed radioactive sources, including High-Activity Sealed Sources (HASS);
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Unsealed radioactive substances used in industrial, research or non-nuclear applications;
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Portable or fixed sources used in gauges, analysers, inspection or security equipment;
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Radioactive material held temporarily by contractors, service providers or maintainers.
Advice is tailored to the nature of the material, the work undertaken and the regulatory framework that applies.
Radiation Protection Adviser (RPA) support – IRR17
Under the Ionising Radiations Regulations 2017 (IRR17), duty holders must appoint a suitable Radiation Protection Adviser (RPA) where required and consult them on specified matters.
RPA support typically covers:
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radiation risk assessments and control measures;
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designation of controlled or supervised areas;
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local rules and contingency arrangements;
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information, instruction and training requirements;
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critical examinations and changes to radiation work;
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engagement with the Health and Safety Executive (HSE) or ONR, where applicable.
RPA advice focuses on the protection of workers and others from ionising radiation during the use and handling of radioactive material.
When do you need an RPA?
RPA appointment and consultation are required where work with ionising radiation is undertaken under IRR17. This includes the use, maintenance or installation of radioactive sources and equipment emitting ionising radiation.
Duty holders are expected to demonstrate that suitable RPA advice has informed radiation protection arrangements.
Radioactive Waste Adviser (RWA) support – EASR and environmental permitting
Where radioactive material becomes radioactive waste, environmental legislation applies.
RWA support focuses on compliance with environmental requirements, including the Environmental Authorisations (Scotland) Regulations 2018 (EASR) and equivalent legislation elsewhere in the UK.
RWA advice may include:
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classification and management of radioactive waste from sealed or unsealed sources;
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application of the waste hierarchy;
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compliance with permits, registrations, General Binding Rules (GBRs) or standard conditions;
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preparation and review of environmental safety assessments;
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advising on material changes, transfers or disposal routes;
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environmental reporting and dose assessment.
When do you need an RWA?
Formal RWA appointment is not required at all times. However, competent radioactive waste advice is required where radioactive material becomes waste, or where environmental authorisation, reporting or disposal applies.
This commonly includes situations where:
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sealed sources become disused, are accumulated or disposed of;
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unsealed radioactive substances generate waste streams;
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waste is stored on site beyond short-term holding;
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activities rely on GBRs, standard conditions or exemptions and advice is needed to confirm applicability and ongoing compliance;
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disposals or discharges require assessment or routine reporting.
General Binding Rules, standard conditions and scope of regulation
Under EASR, not all activities involving radioactive material require an environmental permit or registration.
Some activities are regulated through General Binding Rules (GBRs) or standard conditions, and in certain circumstances may fall outwith regulatory control, provided all conditions are met.
RP Alba Ltd advises duty holders on:
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whether activities fall within EASR authorisation, registration, GBRs or exemption;
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interpretation and ongoing compliance with applicable GBRs or standard conditions;
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evidencing and documenting compliance where reliance on exemption or GBRs is claimed.
Regulators expect reliance on GBRs or exemptions to be robust, justified and demonstrable.
Environmental monitoring, reporting and impact assessment
Environmental authorisations commonly require routine reporting of radioactive waste disposals and discharges.
We can advise on:
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preparation and review of routine environmental returns;
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submissions to SEPA reporting systems, including the Scottish Pollution Release Inventory (SPRI);
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assessment of doses to representative persons;
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assessment of impacts to non-human biota / representative wildlife;
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proportionate environmental monitoring arrangements.
Security, transport and interfaces with other regimes
Use and storage of radioactive sources can raise wider regulatory considerations.
We can support advice on:
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appropriate security arrangements for radioactive sources, including liaison with a client’s Counter Terrorism Security Adviser (CTSA) where relevant;
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interfaces with transport requirements and coordination with Dangerous Goods Safety Advisers (DGSAs);
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engagement with authorised disposal or take-back routes for disused sources.
Working with other advisers and regulators
RP Alba Ltd supports constructive engagement with regulators and advisers, including:
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HSE and SEPA;
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the Office for Nuclear Regulation (ONR), including for Class 7 dangerous goods transport where applicable;
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coordination with RPAs, RWAs, DGSAs, MPEs or LPAs appointed by the client.
Support can be provided alongside a client’s existing advisers, or as part of an integrated advisory arrangement.
Competence and continuity
Advice is provided by an individually certificated and competent adviser, ensuring continuity, accountability and proportionate support aligned to the client’s activities.