When to investigate and notify the enforcing authority

The employer’s responsibilities are set out in Regulations 8(3) and 8(4). As the employer, if you suspect that a SAUE has, or may have occurred, or if you are informed about an incident, you must follow these steps:

  • First, carry out an immediate preliminary investigation. If the preliminary investigation shows beyond reasonable doubt that the incident meets the specified criteria for a SAUE, you must notify the appropriate enforcing authority as soon as possible. 
  • Depending on the circumstances, you need to make the notification no later than 2 weeks after discovering the incident. 
  • Conduct or arrange for a detailed investigation of the circumstances of the exposure and assessment of the dose received.
  • Submit the report of this investigation to the appropriate enforcing authority no later than 12 weeks after the incident was discovered, regardless of the severity of the incident or any complications. This is irrespective of any timeframes of a health board or an employer’s own timeframes for reporting serious incidents. If you cannot submit the report within the expected timeframe, you need to discuss with an inspector from the appropriate enforcing authority as early as possible.

Incidents involving ionising radiation that do not meet the dose threshold and notification criteria for SAUE still need to be investigated and analysed locally under Regulation 8(3). This includes near misses. You must record the analyses of these events, which should consider any thematic reviews and trend analyses.

National taxonomy for incident learning

The value of reporting incidents and near misses and the associated learning is well appreciated. There are national frameworks for:

Radiotherapy

Radiotherapy: learning from errors (gov.uk)

Clinical imaging, magnetic resonance imaging and nuclear medicine

Medical radiation: uses, dose measurements and safety advice (gov.uk)

The objective of these voluntary learning systems is to support services to review their own practice and provide a framework that can be used to share data and learning nationally. The UK Health Security Agency (UKHSA) is responsible for collecting, analysing or publishing findings from this data, and the IR(ME)R enforcing authorities encourage services to use the systems in their investigations of both SAUE incidents and other incidents and near misses that do not meet the notification threshold.

These systems do not replace the existing mandatory responsibility to report to the appropriate authority under regulations such as the Ionising Radiation (Medical Exposure) Regulations (IR(ME)R).