FireNet Community
FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Technical Advice => Topic started by: splidge on January 12, 2006, 12:30:20 PM
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Hi all
Does any one know where I can find information as to the quantity of ionization smoke detectors that can be kept in any one location, ie, storage cuboard, these figures would be for new and or used condition, and what type of storage they are supposed to be kept in?
Any help would be appreacicated.
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I remember hearing about a EuropeanDirective that was going to make it difficult to store or transport Ionization detectors in bulk. I don't know what happened about it.
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ODPM F&RS Circular 46-2004 Home Fire Risk Check Initiative Paragraph 4.1 mentions that the Radioactive Substances Act 1993 sets a storage limit of 500 alarms in any one premises and then said that ODPM were negotiating an exemption with the Environment Agency.
Never did hear whether they got an exemption!
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Manufacturers have special licences granted because of volume they hold; regards Fire Brigade Purchases they are aware of difficulties local FRS have when bulk ordering.
Drip feeding is offered by many manufacturers.
Of course its not an issue with Optical Alarms.
Have any Brigades engaged on large scale installation been considering the impact of WEEE regs down the line, when alarms installed for free, need disposing of legally; regime in 10 years time may well be even more harsh than now.??
Who knows Ion alarms may have been banned by then, as they are in most of EC except UK & Eire.
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gel, i think youll find most brigades have determined that once they have installed them then they become the property of the occupier - most brigades include some sort of reference to that fact as a disclaimer (also with reagrds to maintenance etc)
i dont think anyone would seriously consider 'taking back' smoke alarms. they will hopefully have a regime to fit new ones but i cant see them taking the old ones back!
dave bev
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Well after a bit more research it seems that the limit is 500, and this does not include the ones fitted through out your premises. Although the type of storage they are to be kept in i've yet to find?
As for the dispsal of these items this has to be by speacial means not your common old dustbin, the minimum cost of a private company to dispose of them is over £3.00 per device.
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return them to the manufacturer
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splidge - are you referring to disposal by an individual or disposal by a 'business' ?
dave bev
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The Radioactive Substances (Smoke Detectors) Exemption Order 1980 (SI 1980 No. 953 as amended) exempts up to 500 detectors from registration under the Radioactive Substances Act 1993, subject to certain conditions being observed. The exemption order was amended in 1991 by SI 1991 No 477.
The Ionising Radiations Regs 1999 may provide a clue on storage facilities.
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nice one Fed
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Graeme this is possible but they will charge for this service, Dave Business, licenced to deal with this paticular waste, unfortuanitly no one (business) will do this for free!
Thanks Fred I will check those regs.
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i have done in past and did not get charged.
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Most manufacturers will dispose of ICCGD's but costs vary from one to another. Also depends on material(usually Americium 241) and strength. If manufacturer has gone bust or will not dispose, you can contact ACB ( active collection bureau) via web site.Costs a lot more than £3.00 per head, prepare for a shock!
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i didnt realise that anything other than americium 24 was used in domestic ionising detectors/alarms. as for the strength, again i thought that was controlled - when i did my rps course (some time ago with the nrpb) they told us of a woman who swallowed 3 sources in the usa with no effect - she worked in an assembly plant - they passed through her system with no effect apparently - of course you should not try this at home children - or growed ups either!
dave bev
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i take it that she never had lunch that day and was feeling peckish?
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We tried to look up all the information this morning to give a clear responce but it would appear that whatever you try to do to comply with one set of legislation, then another gets you. Safest way is to eat them on the premises. Don't try to move them in a vehicle whatever you do.
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More data here from what was the NRPB. There's a higher level of radiation in a luminescent watch face incidentally than a smoke alarm.
http://www.hpa.org.uk/radiation/understand/information_sheets/icsds.htm
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Thanks Gel but here comes the rub!! Domestic smoke detectors are not covered by the RSA according to DEFRA report noDEFRA/RAS02.013 dated march 2002 which was a proposal to modify the exemption orders under the act. Therefore can you legaly throw these in the rubbish? And if they are not covered by the RSA how many can you store, which is how this started. Clear as mud
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i was always under the impression an individual could legally dispose them by 'binning' them, but a 'business/company' etc had to dispose of them via registered waste carriers - bearing in mind the actual dangers posed by the source type and strength i still have no reason to believe otherwise - unless someone can definitively prove that not to be the case on a legal basis? i am always willing to learn if someone does have the definitive answer
dave bev
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IONISATION CHAMBER SMOKE DETECTORS &
THE RADIOACTIVE MATERIAL (ROAD TRANSPORT)
REGULATIONS 2002
1 BACKGROUND
Statutory Instrument 2002 No. 1093, The Radioactive Material (Road Transport)
Regulations 2002, introduced new regulations pertinent to the transport of
radioactive materials. These regulations, which are commonly known as
RAMRoad02, came into force on 7th June 2002. The 2002 regulations were
amended, with effect from 22nd August 2003, by Statutory Instrument 2003 No.
1867, The Radioactive Material (Road Transport) (Amendment) Regulations 2003.
The introduction of the 2002 Regulations revokes the 1996 Regulations.
International Regulations
Statutory Instrument 2002 No. 1093 implements the international agreement on the
Regulations for the Safe Transport of Radioactive Material (1996 Edition (Revised))
published by the International Atomic Energy Authority (“IAEA1996”). It also covers
the European Agreement concerning the international carriage of dangerous goods
by road (“ADR”) with any amendment up to 1st July 2001 and the Council Directives
96/29/EURATOM and Commission Directive 2001/7/EC.
2 INTRODUCTION
The regulations covered by RAMRoad02 affect many BFPSA members who either
manufacture or use ionization chamber smoke detectors (ICSDs). In order to raise
the awareness of the changes and the implications that the new regulations have on
the way that companies operate their businesses, this document summarises the
key requirements that apply to the Fire Detection and Alarm Industry and what
companies have to do to comply with the requirements for packaging ICSDs and
transporting them.
3 PACKAGING REQUIREMENTS OF RAMROAD02
Requirements
Under regulation 41, ion detectors in packages (i.e. a box or a pallet of boxes if
bound together) whose total Am241 activity is less than 1GBq (or less than 30,000
ion detectors at 33.3kBq each) can be transported as ‘excepted packages’. Under
this regulation, the dose rate on any surface must not exceed 5μSv/h. The following
conditions also apply to excepted packages:
1) Each package must be legibly and durably marked on the outside of the
packaging with an identification of either or both the consignor or consignee
(Schedule 6).
2) The outside of the package must be marked with “UN2911” but does not
require an indication of the presence of radioactive material within (no trefoil
need be present).
3) The package must however include a warning, visible when the package is
opened, to the effect that it contains radioactive material.
BFPSA Fact File No. 8 Page 2 of 4
4) The package must be accompanied by a signed “transport document”, (Schedule 6,
paragraph 17), which:
a) Includes a heading or reference to The Radioactive Material (Road Transport)
Regulations 2002;
b) Lists the consignors name and address, and provides an emergency telephone
number;
c) Lists the consignees name and address;
d) Includes the UN class and UN number and proper shipping name assigned to
the material transported, i.e. “Class 7, UN2911 RADIOACTIVE MATERIAL,
EXCEPTED PACKAGE – INSTRUMENTS”.
5) The transport document must include a declaration (Schedule 6, paragraphs 18 to 21),
which:
a) States “Contents are fully and accurately described by the proper shipping
name and are classified, packed, marked and labelled, and are in all respects in
proper condition for transport by road according to applicable international and
national regulations.”
b) Has provision for a dated, authorised signature (a facsimile signature is
acceptable).
Under regulation 42, empty packages that have previously contained radioactive material may be
transported as an excepted package only if:
1) The re-used package is in a well-maintained condition and is securely closed.
2) Contamination, when averaged over any area of 300 cm2 of any part of the surface,
does not exceed 40 Bq/cm2.
3) Any label(s) that may have been displayed in conformity with the labeling requirements
of the regulations are no longer visible.
Recommendations
1) Make sure that your company’s Dispatch department is equipped with the means of
marking cartons containing ICSDs with the mandatory “UN2911” marking. This must
be legible and durable.
2) The text specified for a “transport document”, together with the declaration and
provision for authorization should be added to the company’s specific shipping
documents.
3) Individuals within the company involved with shipping should be authorized to sign the
declaration printed on the shipping documents.
4) Arrange to have a double-sided sheet printed with “WARNING – RADIOACTIVE
MATERIAL” printed on it. The radioactive trefoil may be included on this sheet. This
should be placed in the bottom and at the top of any carton containing ionisation
detectors.
4 TRANSPORT OF ICSDS IN A VEHICLE
Requirement
In Schedule 1, the RAMRoad02 regulations include nuclide specific quantities below which the
transport of radioactive material is exempt from the regulations. For Am241 the activity limit for
an exempt consignment is 10 kBq, therefore the transporter of a single ICSD has duties under
RAMRoad02.
Implications
This means that anyone carrying a single ICSD in a vehicle is subject to the RAMRoad02
regulations.
BFPSA Fact File No. 8 Page 3 of 4
Requirement
When carrying excepted packages, drivers of vehicles, and any assistant present in the
vehicle, must have received general training to enable them to understand the hazards
presented by the goods they are transporting and the actions to be taken in the event of an
emergency.
The Regulations apply to company vehicles, private vehicles, hired vehicles and public
transport vehicles.
Implications
The implications of this legislative requirement are far reaching for BFPSA members; some of
the limitations it imposes are listed below:
a) Sales Managers cannot have samples of ion detectors in their cars unless they comply
with the RAMRoad02 requirements.
b) Technical sales staff cannot have samples of ion detectors in their cars when going on
a site visit unless they comply with the RAMRoad02 requirements.
c) Engineers dealing with third party approvals cannot take samples of ion detectors to
BRE, or any other external laboratory, by car unless they comply with the RAMRoad02
requirements.
d) Staff cannot move ion detectors around in the local area using a company vehicle
unless that vehicle complies with the RAMRoad02 requirements.
e) Sales staff cannot give out samples of ion detectors to customers while they are on the
company premises when it is obvious that the customer will drive off in a non-compliant
vehicle.
f) Sales staff cannot sell ion detectors to customers that come to the company premises
when it is obvious that the customer will drive off in a non-compliant vehicle.
Requirement
In Schedule 7, the ‘Responsibilities of carriers’, the RAMRoad02 Regulations states that
vehicles must be equipped in accordance with the provisions of paragraph 8.1.4 of ADR (the
European Agreement concerning the international Carriage of Dangerous Goods by Road) in
respect of fire fighting equipment.
Implications
1) For vehicle carrying non-excepted packages the vehicle must be equipped as follows:
a. Vehicles of 3.5 tonnes or less must carry one portable dry powder (or equivalent) 2kg
fire extinguisher suitable for fighting a fire in the engine or in the cab, and a second 2
kg extinguisher for other fires.
b. For vehicles greater than 3.5 tonnes but less than 7.5 tonnes, the additional
extinguisher must have a capacity of 6 kg.
c. For vehicles greater than 7.5 tonnes, the second extinguisher must have a capacity of
10 kg.
2) The 1996 Transport Regulations included a clause that allowed the transport of (only)
excepted packages without the needs to carry any fire extinguishers. A UK derogation
was issued for ADR to allow this clause from the 1996 Regulations to be used and
Regulations 5 (4) (d) of the 2002 Transport Regulations (RAMRoad02) allows this
derogation to continue.
Hence, there is no requirement for fire fighting equipment to be carried on vehicles carrying
only excepted packages.
However, it is recommended, for good practice, that a vehicle transporting excepted
packages is equipped with at least one suitable fire extinguisher (although this is not a
mandatory requirement).
BFPSA Fact File No. 8 Page 4 of 4
5 AMENDMENT 2003
The 2003 amendment does not significantly change the 2002 Regulations and the
requirements and recommendations set above continue to apply.
6 HOW TO OBTAIN A COPY OF THE REGULATIONS
Statutory Instruments can be obtained by visiting the HMSO web site at
http://www.legislation.hmso.gov.uk/stat.htm and then by selecting the year and number of the
publication wanted.
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graeme, it must have taken hours to type all that - you really are comitted!
but how can domestic smoke alarms be legally disposed of?
dave bev
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Dave
I was under the same impression as you, in that a household could bin a single smoke alarm.
Do you mean i am committed or should be??
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Graeme.
I have previously seen the BFPSA site with the transport regs. An interesting point is raised under 'f'. If one of my sales guys cannot sell an ION to somebody who will drive off in a non complient motor, what about the check out dolly from B&Q who sells one to mrs mopp to take home in her Nissan micra? Thats before she chucks it in the bin. I cannot find the original legislation about Ions which either exempts or ignores domestics but we all suspect that the legislation predates them. Thus the question is.... What status do domestic ions have and can you sell em, stack em and bin them legally? I think I need committing!!
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I would have thought that if it did apply to domestic that something would have been done by now.
-
IONISATION CHAMBER SMOKE DETECTORS &
THE RADIOACTIVE MATERIAL (ROAD TRANSPORT)
REGULATIONS 2002
1 BACKGROUND
Statutory Instrument 2002 No. 1093, The Radioactive Material (Road Transport)
Regulations 2002, introduced new regulations pertinent to the transport of
radioactive materials. These regulations, which are commonly known as
RAMRoad02, came into force on 7th June 2002. The 2002 regulations were
amended, with effect from 22nd August 2003, by Statutory Instrument 2003 No.
1867, The Radioactive Material (Road Transport) (Amendment) Regulations 2003.
The introduction of the 2002 Regulations revokes the 1996 Regulations.
International Regulations
Statutory Instrument 2002 No. 1093 implements the international agreement on the
Regulations for the Safe Transport of Radioactive Material (1996 Edition (Revised))
published by the International Atomic Energy Authority (“IAEA1996”). It also covers
the European Agreement concerning the international carriage of dangerous goods
by road (“ADR”) with any amendment up to 1st July 2001 and the Council Directives
96/29/EURATOM and Commission Directive 2001/7/EC.
2 INTRODUCTION
The regulations covered by RAMRoad02 affect many BFPSA members who either
manufacture or use ionization chamber smoke detectors (ICSDs). In order to raise
the awareness of the changes and the implications that the new regulations have on
the way that companies operate their businesses, this document summarises the
key requirements that apply to the Fire Detection and Alarm Industry and what
companies have to do to comply with the requirements for packaging ICSDs and
transporting them.
3 PACKAGING REQUIREMENTS OF RAMROAD02
Requirements
Under regulation 41, ion detectors in packages (i.e. a box or a pallet of boxes if
bound together) whose total Am241 activity is less than 1GBq (or less than 30,000
ion detectors at 33.3kBq each) can be transported as ‘excepted packages’. Under
this regulation, the dose rate on any surface must not exceed 5μSv/h. The following
conditions also apply to excepted packages:
1) Each package must be legibly and durably marked on the outside of the
packaging with an identification of either or both the consignor or consignee
(Schedule 6).
2) The outside of the package must be marked with “UN2911” but does not
require an indication of the presence of radioactive material within (no trefoil
need be present).
3) The package must however include a warning, visible when the package is
opened, to the effect that it contains radioactive material.
BFPSA Fact File No. 8 Page 2 of 4
4) The package must be accompanied by a signed “transport document”, (Schedule 6,
paragraph 17), which:
a) Includes a heading or reference to The Radioactive Material (Road Transport)
Regulations 2002;
b) Lists the consignors name and address, and provides an emergency telephone
number;
c) Lists the consignees name and address;
d) Includes the UN class and UN number and proper shipping name assigned to
the material transported, i.e. “Class 7, UN2911 RADIOACTIVE MATERIAL,
EXCEPTED PACKAGE – INSTRUMENTS”.
5) The transport document must include a declaration (Schedule 6, paragraphs 18 to 21),
which:
a) States “Contents are fully and accurately described by the proper shipping
name and are classified, packed, marked and labelled, and are in all respects in
proper condition for transport by road according to applicable international and
national regulations.”
b) Has provision for a dated, authorised signature (a facsimile signature is
acceptable).
Under regulation 42, empty packages that have previously contained radioactive material may be
transported as an excepted package only if:
1) The re-used package is in a well-maintained condition and is securely closed.
2) Contamination, when averaged over any area of 300 cm2 of any part of the surface,
does not exceed 40 Bq/cm2.
3) Any label(s) that may have been displayed in conformity with the labeling requirements
of the regulations are no longer visible.
Recommendations
1) Make sure that your company’s Dispatch department is equipped with the means of
marking cartons containing ICSDs with the mandatory “UN2911” marking. This must
be legible and durable.
2) The text specified for a “transport document”, together with the declaration and
provision for authorization should be added to the company’s specific shipping
documents.
3) Individuals within the company involved with shipping should be authorized to sign the
declaration printed on the shipping documents.
4) Arrange to have a double-sided sheet printed with “WARNING – RADIOACTIVE
MATERIAL” printed on it. The radioactive trefoil may be included on this sheet. This
should be placed in the bottom and at the top of any carton containing ionisation
detectors.
4 TRANSPORT OF ICSDS IN A VEHICLE
Requirement
In Schedule 1, the RAMRoad02 regulations include nuclide specific quantities below which the
transport of radioactive material is exempt from the regulations. For Am241 the activity limit for
an exempt consignment is 10 kBq, therefore the transporter of a single ICSD has duties under
RAMRoad02.
Implications
This means that anyone carrying a single ICSD in a vehicle is subject to the RAMRoad02
regulations.
BFPSA Fact File No. 8 Page 3 of 4
Requirement
When carrying excepted packages, drivers of vehicles, and any assistant present in the
vehicle, must have received general training to enable them to understand the hazards
presented by the goods they are transporting and the actions to be taken in the event of an
emergency.
The Regulations apply to company vehicles, private vehicles, hired vehicles and public
transport vehicles.
Implications
The implications of this legislative requirement are far reaching for BFPSA members; some of
the limitations it imposes are listed below:
a) Sales Managers cannot have samples of ion detectors in their cars unless they comply
with the RAMRoad02 requirements.
b) Technical sales staff cannot have samples of ion detectors in their cars when going on
a site visit unless they comply with the RAMRoad02 requirements.
c) Engineers dealing with third party approvals cannot take samples of ion detectors to
BRE, or any other external laboratory, by car unless they comply with the RAMRoad02
requirements.
d) Staff cannot move ion detectors around in the local area using a company vehicle
unless that vehicle complies with the RAMRoad02 requirements.
e) Sales staff cannot give out samples of ion detectors to customers while they are on the
company premises when it is obvious that the customer will drive off in a non-compliant
vehicle.
f) Sales staff cannot sell ion detectors to customers that come to the company premises
when it is obvious that the customer will drive off in a non-compliant vehicle.
Requirement
In Schedule 7, the ‘Responsibilities of carriers’, the RAMRoad02 Regulations states that
vehicles must be equipped in accordance with the provisions of paragraph 8.1.4 of ADR (the
European Agreement concerning the international Carriage of Dangerous Goods by Road) in
respect of fire fighting equipment.
Implications
1) For vehicle carrying non-excepted packages the vehicle must be equipped as follows:
a. Vehicles of 3.5 tonnes or less must carry one portable dry powder (or equivalent) 2kg
fire extinguisher suitable for fighting a fire in the engine or in the cab, and a second 2
kg extinguisher for other fires.
b. For vehicles greater than 3.5 tonnes but less than 7.5 tonnes, the additional
extinguisher must have a capacity of 6 kg.
c. For vehicles greater than 7.5 tonnes, the second extinguisher must have a capacity of
10 kg.
2) The 1996 Transport Regulations included a clause that allowed the transport of (only)
excepted packages without the needs to carry any fire extinguishers. A UK derogation
was issued for ADR to allow this clause from the 1996 Regulations to be used and
Regulations 5 (4) (d) of the 2002 Transport Regulations (RAMRoad02) allows this
derogation to continue.
Hence, there is no requirement for fire fighting equipment to be carried on vehicles carrying
only excepted packages.
However, it is recommended, for good practice, that a vehicle transporting excepted
packages is equipped with at least one suitable fire extinguisher (although this is not a
mandatory requirement).
BFPSA Fact File No. 8 Page 4 of 4
5 AMENDMENT 2003
The 2003 amendment does not significantly change the 2002 Regulations and the
requirements and recommendations set above continue to apply.
6 HOW TO OBTAIN A COPY OF THE REGULATIONS
Statutory Instruments can be obtained by visiting the HMSO web site at
http://www.legislation.hmso.gov.uk/stat.htm and then by selecting the year and number of the
publication wanted.
Could you repeat that???Give me the idiot's guide or the buzzards guide - whichever is easier!Am I not permitted to carry them as spares and,if I am,what should I have in place to accomodate this?
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get a sticker for the van and a fire extinguisher.
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and a big white suit like the ones off of ET