National Radon Strategy

UK National Radon Action Plan, PHE-CRCE-043 https://www.gov.uk/government/publications/uk-national-radon-action-plan

`The abstract to this document claims that “This report presents in a single document, the elements that make up the national radon strategy and the national radon action plan. It fulfils relevant requirements in the 2013 European Union Basic Safety Standards Directive on protection against ionising radiation (EURATOM, 2013).” I think that this statement admits the thought that occurred to me as I read the document for the first time; although labelled as the UK National Radon Action Plan it is not really a plan or a strategy, instead it is a comprehensive description of the work being undertaken in the UK to understand the extent of exposure to Radon, to identify where action should be taken to reduce Radon dose, and to take such steps and monitor their effectiveness.

The section labelled “UK radon strategy” talks about the UK strategy in the third person. It is not a strategy itself but describes a strategy that is off-stage. Where the document states that the UK strategy meets the requirements of the BSS it is really making the credible claim that the UK is already doing what it would have decided to do had it started with a blank sheet of paper and written a strategy in line with the guidance. Essentially the UK had a comprehensive Radon programme before the need was fully articulated in the BSS.

Radon appears in the BSS in a number of places (Article 54 Radon in the workplace, Article 74 Indoor exposure to Radon, Article 103 Radon Action Plan). The BSS requires that there is a national plan to address the long- term risks from radon exposure recognising that the combination of smoking and high radon exposure presents a substantially higher individual lung cancer risk than either factor individually and that smoking amplifies the risk from radon exposure at the population level.

The Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 which came into force on 8th May 2018 require the Secretary of State to set a reference level for public exposure to radon. The reference level for the annual average radon activity concentration in air must not exceed 300 becquerel per cubic metre (regulation 8) in line with BSS Article 74. The BSS calls for a “basis for the establishment of reference levels”. The basis of the UK limits is not clear to me but there is probably a justification somewhere.

Further regulation is found in the Health and Safety at Work etc Act of 1974 and the Management of Health and Safety at Work Regulations 1999.

The SoS is also required to publish information about the hazards of indoor radiation, its measurement and ways of reducing it (Regulation 9). This is satisfied, at least in part, by the website at https://www.ukradon.org/.

There must be a national plan address long term health risks from radon ingress to dwellings, workplaces and buildings with public access (Regulation 10). This must be updated at intervals of no more than five years.

Annex 18 of the EU BSS gives a list of 14 things to consider when setting up a national radon plan. The use of this list is mandated by the 2018 regulations.  While I don’t think that the UK is missing anything important with the current approach it is not entirely obvious where each of these topics are covered.

Public Health England have a group focused on the radon issue and they provide leadership within the UK. This document was written by the PHE group along with several other government departments covering the UK and the devolved administrations.

The UK has maps are that identify radon Affected Areas, which are defined as where at least 1% of homes are expected to be above the radon Action Level (200 Bq m-3). These can be found at https://www.ukradon.org/. This shows that my home in Gloucestershire has a “maximum radon potential of less than 1% (in the clear) but with the surrounding area going up to 3 – 5%. Since these values are “indicative” I’m maybe not entirely in the clear.  This clearly shows that the need for an “approach, data and criteria for the delineation of areas” is satisfied. It is less clear that a risk assessment has been used to systematically identify the types of buildings that should be surveyed although the UK has a long standing survey programme.

The Forward plan for action on radon states that established UK infrastructure and provisions will be “maintained and supported” but not who will do this and who they will be answerable to which you may expect to find in a strategy. The New topics for consideration” explicitly mentions the annex of the EU BSS and picks up some of the missing elements and promises that they will be given attention and places actions, but not a time frame, on Public Health England.

Maybe next time the PHE will publish a document that looks more like a strategy. In the meantime keep up the good work.

References

EURATOM (2013). Council Directive 2013/59/EURATOM of 5 December 2013 laying down basic safety standards for protection against the dangers arising from exposure to ionising radiation, Official Journal of the European Union L13/1.

Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 (which came into force on 8th May 2018)

Two new pieces of advice for local authority emergency planners

Local authorities’ preparedness for civil emergencies: A good practice guide for Chief Executives And A councillor’s guide to civil emergencies

The Ministry of Housing, Communities & Local Government has reissued advice to local authorities on preparedness for civil emergencies (Local authorities’ preparedness for civil emergencies: A good practice guide for Chief Executives, November 2018). This document, which is not intended to be prescriptive, lists 10 aspects it would expect to see in a well prepared authority.

In the introduction Jake Berry MP states that the nature of emergencies facing us continue to increase in variety and complexity “terror attacks in London and Manchester, the use of nerve agent in Salisbury and the devastating fire at Grenfell Tower have tested the resolve of our communities and reminded us all of the importance of local authority leadership in times of crisis”.

The section entitled “are you ready” asks nine questions about:

  • the ability of residents to contact the authority including out of hours and on bank holidays;
  • the authority’s ability to communicate risks and to warn and inform people in the area, including tourists and other visitors, before, during and after an emergency;
  • the ability of senior staff and elected members to manage in an emergency, including managing the authority’s role and as a senior officer within the strategic response and recovery mechanisms;
  • the testing of plans to ensure that they address local risk and resilience standards and describe how to maintain essential services, ensure business continuity and contain agreements with other local authorities for support in a crisis;
  • the resilience of supply chains;
  • the role of the authority within the LRF and the accuracy of the role description in multi-agency plans and the ability to deliver;
  • resource plans for no notice and sustained emergencies, including over holiday periods;
  • a knowledge of the authority’s strengths and weaknesses and where support and further resource can be obtained;
  • the ability to assess the full impact of an emergency on community needs.

The report discusses the role of the local authority in civil resilience in terms of the CCA, in which the local authority is a category 1 responder.

Importantly the regulations or guidance require that the local authority “to ensure that they can continue to exercise their functions in the event of an emergency. The duty relates to all functions, not just emergency response functions”. This appears to include the ability of an authority to provide support to any population within countermeasure zones during a nuclear emergency. “Plans should be clear about what operational support the local authority will put in place for different emergencies, and how this can be activated in and out of business hours” …. “Plans must be clear about how this support will be activated and managed. This support could include on the ground community alerting, for example, door knocking, checking on vulnerable residents, operating rest centres and providing on-going welfare support for people directly affected by emergencies”.

To achieve this all business critical functions should have robust business contingency plans for the services that the authority delivers and those that are contracted out.

An example that is pertinent to nuclear authorities is “consider building ‘all-risk resilience’ into contracts (for example, how to ensure domiciliary care is delivered during petrol shortages or severe disruption to transport networks)”. Reinforcing this is the statement that “Local authorities are expected to manage the humanitarian aspects during emergencies. This requires staff at all levels to be effectively trained to deal sensitively with victims and survivors, including their friends and family. Training and exercising reserves and volunteers builds a further level of resilience in the event of concurrent or long duration incidents”.

An example of communicating with the public given is that of Calderdale Council which utilised social media during floods in December 2015. It is claimed that the council reached over 420,000 people on Facebook and received over 1 million impressions on Twitter.

On the matter of community leadership the document states that “The public, media and politicians will also look to the council to provide information and clarity on what has happened, what is still happening and what will happen next”.

The importance of training and exercising is stressed. It builds “confidence and competence to enable robust delivery of the local authority role whether it is delivered in response or recovery”.

A list of useful documents is given at the end of the document.

This is a document that should be read by the local authority manager responsible for emergency planning and by the Chief Executive of the authority fairly regularly. It might be a useful one to have on the desk when performing periodic readiness or accountability reviews. At a mere 27 pages it makes a welcome change from some of the “door stop” guidance documents that sap the will to live.

A related document, A councillor’s guide to civil emergencieshas also been updated recently (November 2018). The forward mentions that the last version was issued in 2016 but reports that a lot has happened since then with terrorist attacks, tower fires and nerve agent attacks within the UK.

This document introduces some core terms including the definition of a civil emergency, the difference between a rising tide and a no-notice event, categories of responders and levels of response.

A number of case studies are discussed.

The overview section outlines the responsibilities of councils and individual councillors and, later, the role of leaders, portfolio holders and Ward councillors. These headings are then revisited in sections devoted to “preparedness and resilience”, “response”, and “recovery”.

Appendices give suggested questions for leaders/portfolio holders (Appendix 2) and scrutiny committees (Appendix 3) to ask.

This document is a good read and a useful resource for councils and councillors.