Pregnant Women Working in Radioactive Environments at Sellafield

Mae'r ymateb i'r cais hwn wedi cael ei oedi. Yn ôl y gyfraith, dylai Department for Business, Energy and Industrial Strategy fel arfer wedi ymateb yn brydlon a erbyn (manylion)

Dear Department for Business, Energy and Industrial Strategy,

Pregnant Women Working in Radioactive Environments

One Sellafield policy that I STRONGLY disagree with, and was not the case in the past, is the expectation that women who normally work in the active area, a controlled radioactive environment at Sellafield complex, with potential exposure to radiation & radioisotopes, continue working in this environment during in the early stages of their pregnancy.

Yes, these women are generally restricted to mundane monitoring tasks, in their normal workplace environment in the active area, which is usually in the Health Physics offices, but it should be noted that these offices are a hub of activity, and a focal point within each building in the active area, and are not inherently safe. There is typically a regular inflow of personnel bringing potentially contaminated items into these offices, so that they can be monitored for radioactive contamination, and this obviously carries a degree of risk.

Contaminated items being brought into HP&S offices is not uncommon, and this could lead to a pregnant woman being inadvertently exposed to radioactive isotopes, and potentially receiving an intake via one of three pathways, inhalation, ingestion or via an open wound (something as simple as a papercut). Once in the body, these substances can be quickly transported to the unborn child via the umbilical cord.

Criticality Risk

Another risk factor that should clearly be considered when assessing the suitability of pregnant women working in a controlled area, is that of a criticality. A criticality is basically an uncontrolled nuclear fission, chain reaction, resulting in the release of high levels of gamma radiation. The level of risk for a pregnant woman and her unborn child would depend on several factors, including the distance from the source, shielding, and the nature of the building these pregnant women are required to work in.

There will always be the possibility (no matter how remote) of a criticality taking place in a number of alpha buildings on the Sellafield Site, and over the years there have been a number of close calls. A Pregnant woman caught up in an incident of this nature could potentially result in the woman and her unborn child being exposed to high levels of gamma radiation. As a criticality event is almost instantaneous, and can occur without warning, there would be no chance of taking evasive action, all people can do is evacuate after the fact.

The factors that determine whether a person has been exposed to high levels of gamma radiation, or not, will depend on where you were at the time of the incident, distance from the source and shielding factors. Even on hearing the criticality alarms, gamma radiation has already been released, and all personnel can do is evacuate to a safe assembly area, well away from the incident, where they will be assessed to determine if they have been exposed to gamma radiation, and if they require urgent medical attention.

Imagine the outcry if the unthinkable happened, no matter how remote the possibility, and an unborn child was exposed to a massive dose of radiation due to the inanity of this flawed and irrational Sellafield policy, which has no doubt been assessed by BEIS under ‘the Justifications of Practices Involving Ionising Radiation Regulations 2004 & 2018.

I fail to understand why Sellafield Ltd and BEIS would deem it acceptable for pregnant women to continue working in a radioactive environment, with the potential of exposing a pregnant woman and her unborn child to radioisotopes, and in the event of a criticality, expose them to high levels of gamma radiation. Alternative work, in safe and radiologically clean environment could easily be found for these women, well away from the dangers of radiation and radioactive isotopes and contamination, so why force women to take what is an easily avoidable risk.

THE JUSTIFICATION OF PRACTICES INVOLVING IONISING RADIATION REGULATIONS 2004

Justification is a process based on EU legislation which requires that before any new class or type of practice involving ionising radiation can be introduced in the UK, the Government must first assess it to determine whether the individual or societal benefit outweighs the health detriment it may cause. This principle of justification derives from the recommendations of the International Commission on Radiological Protection (ICRP

The process of justification requires that before a practice is introduced, it should
be shown to give an overall benefit. It is also implicit that all aspects of the practice
should be considered.

Justification is relevant not only when a new practice is being introduced but also
when an existing practice is being reviewed in the light of new information about its
efficacy or consequences.

On basis of the above information, and in accordance with ‘the justification of practices involving ionising radiation regulations 2004 & 2018’.

I would like Sellafield Ltd & BEIS to provide all relevant policy documentation, including risk management analysis and technical justifications, that require pregnant women to continue working in an radioactive environment which exposes them, and their unborn child to unacceptable risk from radiation and radioactive isotopes, during the early months of their pregnancy.

I would also like to know if these arrangements are compliant with IRR17 Radiation Regulations, and the Radioactive Substances Act 1993 (RSA93).

Yours faithfully,

Roger A Coleman

FOI Requests, Department for Business, Energy and Industrial Strategy

BEIS ref: FOI2021/11830

Dear Mr Coleman

Thank you for your request for information which was received on 26th
April. Your request has been passed on to the appropriate official at the
Department for Business, Energy and Industrial Strategy (BEIS) to process.

Your request is being considered under the terms of the Freedom of
Information Act 2000 or the Environmental Information Regulations 2004 and
we will reply at the latest by 25th May.

If you have any queries about this email, please contact the Information
Rights & Records Unit at BEIS. Please remember to quote the reference
number above in any future communications.

Kind regards,

Information Rights & Records Unit

Information Rights & Records Unit | Department for Business, Energy and
Industrial Strategy | 1 Victoria Street, London, SW1H 0ET |
www.gov.uk/beis | [email address] |

Dear FOI Requests,

Further Questions relating to pregnant women working in an elevated radioactive environment at Sellafield
Are pregnant women at Sellafield, the ones who are required under Sellafield Ltd policy to continue working in an elevated radioactive environment during the early stages of their pregnancy, placed on a high frequency biological sampling regime during this time, so as to determine if they have received an intake of radioactive isotopes during this critical stage of their pregnancy?

It should be noted, that biological sampling is not a preventative measure, it will simply indicate the presence of radioactive isotopes, and that at some stage the subject was exposed to radioisotopes, which are now present in their body.

Secondly, although I am not in agreement will the policy of allowing pregnant women to continue working in a radioactively elevated environment, with all the associated risks for her and their unborn child, I will assume that these women are closely monitored during this critical stage of their pregnancy. On this basis there will be statistical data showing the results of this monitoring.

With that in mind, could Sellafield Ltd and BEIS provide a breakdown of the data which captures these results, and set out, if, during the past 10 years, or the time that this policy has been in place, which ever in the greater, the number of positive cases, i.e., pregnant women that have been exposed to an internal dose of radioactive isotopes during this critical stage of their pregnancy.

If biological sampling has been conducted, and there have been positive results, i.e., cases where pregnant women were indeed exposed to radioisotopes, and received an internal dose during this period, was a follow-up investigation carried out, and were the subjects informed?

Before being requested or advised to continue working in an elevated radioactive environment, are pregnant women advised of the risks to her and their unborn child, and are they given a choice?

From a legal and regulatory perspective, an unborn child cannot legally subscribe to being a classified worker, but in this instance, they have no choice. In my view an unborn child should not knowingly be exposed to elevated levels of ionising radiation, and this is especially true when you consider the possibility, no matter how remote, of being exposed to a criticality, from a legal standpoint, how and why is this allowed at Sellafield?

Yours sincerely,

Roger A Coleman

FOI Requests, Department for Business, Energy and Industrial Strategy

BEIS ref: FOI2021/11837

Dear Mr Coleman

Thank you for your request for information which was received on 26th
April. Your request has been passed on to the appropriate official at the
Department for Business, Energy and Industrial Strategy (BEIS) to process.

Your request is being considered under the terms of the Freedom of
Information Act 2000 or the Environmental Information Regulations 2004 and
we will reply at the latest by 25th May.

If you have any queries about this email, please contact the Information
Rights & Records Unit at BEIS. Please remember to quote the reference
number above in any future communications.

Kind regards,

Information Rights & Records Unit

Information Rights & Records Unit | Department for Business, Energy and
Industrial Strategy | 1 Victoria Street, London, SW1H 0ET |
www.gov.uk/beis | [email address] |