POLICY NO: HR- 30.0
DATE OF APPROVAL: Senior Management Group 11 May 2005
AMENDMENTS: April 2018; Revised 17 January 2020 (Executive Director: People, Talent and Culture).
REFERENCE AUTHORITY:
Executive Director: People, Talent and Culture
CROSS REFERENCES:
Health, Safety and Injury Management Policy (C-6.4)
Work Health and Safety Act, 2012 (SA)
Work Health and Safety Regulations, 2012
Radiation Protection and Control Act, 1982
Radiation Protection and Control (Ionising Radiation) Regulations, 2015
Ionising Radiation Policy (HR - 29.0)
The University of South Australia is committed to the effective management of non-ionising radiation to protect the health of staff, students and visitors to the University from the effects of non-ionising radiations and to minimise adverse environmental consequences.
The University will as far as is reasonably practical comply with all legislation, codes of practice and Australian Standards relevant to non-ionising radiation.
Radiation is a form of energy transmitted either as electromagnetic waves or as particulate matter. Radiations are classified into two categories based on the effects that they produce when they pass through matter:
Ionising Radiations
Non-ionising Radiations
Coverage of this Policy: Non-ionising radiations as defined in the Radiation Protection and Control Act 1982, namely electromagnetic radiation of a wavelength greater than 100 nm, are the subject of this policy. These radiations may be produced intentionally for teaching or research purposes, or may be incidental such as from electricity supply substations, microwaves ovens in staff rooms, the sun, etc. Sound and ultrasound are not included in this policy and queries concerning such radiations should be directed to the appropriate Department Radiation Safety Officer or the University Radiation Safety Officer.
The properties and effects of non-ionising radiations are very diverse. For the purpose of this policy non-ionising radiations include:
Extremely low frequency (ELF) radiation
Electromagnetic radiation with frequencies in the range 0 Hz (static fields) to 3 kHz, including the 50 Hz electric and magnetic fields associated with the domestic mains electricity supply such as in domestic electrical appliances, electricity supply substations and overhead power lines.
Radiofrequency (RF) radiation
Electromagnetic radiation with frequencies in the range 3 kHz to 300 GHz, which is produced by artificial sources such as visual display units and mobile phones.
Microwave (MW) radiation
Electromagnetic radiation with frequencies in the range 1 GHz to 300 GHz, which is produced by artificial sources such as in microwave ovens and by microwave communication devices. (This radiation is now considered part of Radiofrequency radiation.)
Infrared (IR) radiation
Electromagnetic radiation with wavelengths between 700 nm and 1 mm, which is present in sunlight and produced by artificial sources such as electric radiator heaters.
Visible light
Electromagnetic radiation with wavelengths between 400 nm (blue) and 700 nm (red), which is present in sunlight and produced by numerous artificial sources, including lasers.
Ultraviolet (UV) radiation
Electromagnetic radiation with wavelengths between 100 nm and 400 nm, which is present in sunlight as well as produced by artificial sources such as arc welding and sterilization lamps.
The South Australian Radiation Protection and Control Act, 1982, governs the use of ionising and non-ionising radiation in South Australia (SA). This Act is administered by the Radiation Protection Branch of the Environment Protection Authority (EPA), who license users and/or register prescribed non-ionising radiation apparatus. At present, no licenses are required to operate non-ionising radiation apparatus and no non-ionising radiation apparatus is required to be registered. The standards for non-ionising radiation safety are specified by various Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) Codes of Practice, Australian Standards and Safe Work Australia documents. A list of relevant standards and codes which may be used under the Act are provided in this Policy.
The South Australian Work Health and Safety Act, 2012 (SA), and the Work Health and Safety Regulations, 2012, govern general issues of health and safety in the workplace. These instruments aim to prevent the occurrence of occupational injury and illness and this principle also applies to the use of non-ionising radiation.
In addition, the general duty of care to employees, students and the general public, and of respect for the environment, must be considered in any use of or incidental exposure to non-ionising radiation in the University.
This policy statement outlines the University’s general policy on the use of non-ionising radiation, and of the obligations of the University, its staff and students under the Act.
The University is committed not simply to meeting but, as far as possible, exceeding the protection standards for non-ionising radiation set by legislation or recommended by the Radiation Protection Branch of the Environment Protection Authority (EPA), the NHMRC, ARPANSA, Codes of Practice, Australian Standards, and Safe Work Australia.
Non-ionising radiation exposure limits are available in ARPANSA Codes of Practice and applicable Australian Standards. There is however debate about some exposure limits. The adequacy of levels recommended for exposure to ELF magnetic fields has been argued in the public arena for some time and more recently the RF limits have come under scrutiny following concerns about the safety of mobile phones. While health authorities argue that there is no firm scientific evidence to suggest that the existing exposure limits are inadequate, this ongoing debate makes risk assessment difficult. To address these concerns, the “as low as reasonably achievable” (ALARA) principle can be used. Although this principle was developed for ionising radiation, where it is assumed there is no threshold level for an effect, it can also be used for non-ionising radiations. The difficulty is quantifying what is reasonably achievable. In no case should the relevant exposure limits specified in the Codes of Practice or the Australian Standards be exceeded.
The University supports the use of the ALARA principle for non-ionising radiations.
The ALARA principle requires that any use of non-ionising radiation must be subject to risk-benefit analysis, which will include the risk to the environment as well as humans. The primary responsibility for this risk-benefit analysis lies with those initiating the work with non-ionising radiation. These will be the principal investigators in the case of research projects or contracts, the course co-ordinators responsible for teaching courses in which non-ionising radiation is used, the Facilities Management Unit when designing and constructing University infrastructure, and Directors of Research Institutes, Executive Deans and Units for the local incidental radiation environment.
The University will meet these goals and give effect to this policy through a comprehensive Radiation Management Plan, which will include physical control measures, and the management of training, supervision and recording of all aspects of the use of non-ionising radiations.
The University is committed to the provision of the appropriate human and physical resources to meet these policy goals and to manage the radiation safety program effectively.
All members of the University, both staff and students, have responsibilities for ensuring the application of this policy. Specific responsibilities are detailed in this policy and in the Radiation Management Plan.
This policy will apply to all aspects of work with non-ionising radiation carried out by staff and students of the University, whether at a University campus, or in the field. It includes outdoor workers, and students and staff on field trips and at camps, exposed to radiation from the sun. This policy sets the minimum standards that must be adhered to when staff or students are working outside the University.
For Non-ionising Radiations the University will delegate responsibilities in the same manner as those specified in the Radiation Protection and Control (Ionising Radiation) Regulations, 2015, and described in the Ionising Radiation Policy, which are:
The Vice-Chancellor, as the Principal Officer, and the Executive Director: People, Talent and Culture, as the Responsible Officer have responsibility for meeting the requirements of the SA Work Health and Safety Act, 2012, and the SA Radiation Protection and Control Act, 1982.
The University adopts this Policy and the Radiation Management Plan and delegates particular aspects of the plan in accordance with the University’s general management policies.
In particular, the Vice Chancellor is responsible for providing sufficient resources for the University to meet the requirements of the legislation and this Policy, and for appointing a University Radiation Safety Officer.
Oversight of Radiation Safety, both ionising and non-ionising, is established with the Executive Director: People, Talent & Culture, through the Associate Director: Wellbeing and Employee Benefits, the University Radiation Safety Officer, University Work Health, Safety and Wellbeing Committee, and the University Radiation Safety Committee.
The University Radiation Safety Officer is appointed in accordance with the Radiation Protection and Control (Ionising Radiation) Regulations, 2015, and advises the Safety and Wellbeing Team, University Work Health, Safety and Wellbeing Committee and the University Radiation Safety Committee on all radiation safety matters. Other duties relevant to radiation safety in the University are set out in the Radiation Management Plan.
All staff and students intentionally using non-ionising radiations are responsible for their own safe use of the radiation and have an obligation to ensure that their work does not affect the safety of staff, students or the public by any action or inaction. In particular, they must:
All research grants and contracts that involve the intentional use of high power non-ionising radiation must comply with this policy and with the University’s systems for the management of non-ionising radiation. No research grant or contract will be accepted without a specific declaration that the principal investigator(s) understands this policy and the management requirements, and agrees to apply them.
The University Radiation Safety Officer must approve all projects involving the intentional use of high power non-ionising radiation by staff or students where there is a potential for the safety level standards to be exceeded.
Specific advice from the University Radiation Safety Officer must be requested and received by the appropriate ethics committee on all research proposals involving non-ionising radiation and human subjects. Stringent guidelines will be established to ensure that as far as possible individual research subjects will, or might, benefit from the radiation exposure they receive when balanced against any possible harm.
A radiation worker in this context is anyone intentionally using non-ionising radiation for research or teaching. The University requires all people who are not radiation workers, including staff, students and outside contractors, to obtain permission from the supervisor of the area before entering any radiation area in which non-ionising radiation, other than from the sun, is being used for research or teaching purposes.
The Legal Framework for Controlling Radiation Hazards
The Act imposes responsibilities on those who intentionally work with non-ionising radiation and their employers, and on those who own non-ionising radiation sources. Students working with non-ionising radiation are classed as radiation workers. At present, no activities with non-ionising radiations in a university environment require licences, registrations or approvals under the Radiation Protection and Control Act, 1982. This may change in the future for certain types of non-ionising radiations. Non-radiation workers must also be protected from unintentional exposures to non-ionising radiations in their workplace.
The University will implement and maintain appropriate management structures and practices to ensure the primary aims of this policy are met. Particular attention will be given to:
The University will ensure that this policy is reviewed and evaluated regularly for its effectiveness in delivering ongoing effective management of non-ionising radiation, with an aim to develop continuous improvement. This will be particularly necessary if legislation is enacted in SA regulating the use of any non-ionising radiation sources.
The University will ensure that this policy is readily available to all members of the University, especially those working with non-ionising radiation, by publication on the appropriate web site and through other means.
The University is committed to providing training programs for those working with non-ionising radiation that covers all aspects of radiation safety relevant to their work, and to providing information for others who may be exposed to non-ionising radiation through their work in the University, including contractors and visitors.
The University will publish a Radiation Safety Manual and Information Sheets on particular types of non-ionising radiation, which will cover all use of and exposure to non-ionising radiation by members of the University.
South Australian Approved Work Health and Safety Codes of Practice:
Welding Processes, SafeWork SA, March 2019.
ARPANSA Radiation Protection Series:
No. 3. Radiation Protection Standard – Maximum Exposure Levels to Radiofrequency fields – 3 kHz to 300 GHz (updated 2016).
No. 12. Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006).