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X-ray body scanners
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Authority: HMP Lowdham Grange IMB
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TITLE: X-ray body scanners
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MESSAGE 1 [outgoing]
HEADER: Paul W Sullivan
21 June 2022
Delivered
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Dear HMP Lowdham Grange IMB,
In your latest report you mention the continued and consistent use of X-ray body scanners. As you will be aware the scanners can only be used where there is credible evidence or intelligence that a person has something concealed internally.
Given the very tight restriction on the use of the scanners could you please:
1: Tell me how many scans were carried out in your reporting year.
2: How many actual men were scanned during this period.
3: What checks you are doing to ensure the very strict criteria for scanning prisoners is followed, as laid out in the Policy Framework.
Yours faithfully,
Paul Sullivan
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MESSAGE 2 [incoming]
HEADER: IMB,
HMP Lowdham Grange IMB
12 July 2022
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Dear Mr Sullivan
Please find attached a response to your recent Freedom of Information
request.
Yours sincerely,
IMB Secretariat
The Independent Monitoring Boards and Lay Observer Secretariat
[1]www.imb.org.uk | [2]www.layobservers.org
[3][IMG][4][IMG]
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MESSAGE 3 [outgoing]
HEADER: Paul W Sullivan
17 July 2022
Delivered
--------------------------------------------------------------------------------
Dear IMB,
Thank you for your reply. I am concerned that you do not check on the correct and lawful use of X-ray scanners on prisoners at your jail since my understanding was that part of your job was monitoring to ensure the safe care of prisoners at the prison, and that they are treated lawfully. If prisoners are scanned outside the lawful limits set then they are being treated unlawfully, and their health/lives being potentially put at risk.
Yours sincerely,
Paul W Sullivan
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ATTACHMENT: 2022.12.04_FOI_Paul_Sullivan_IMB_response.pdf
TEXT_FILE: 2022.12.04_FOI_Paul_Sullivan_IMB_response.pdf.txt
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--- PDF page 1 ---
Barbara Morgan
Chair of the IMB at HMP Lowdham Grange
Old Epperstone Road
Lowdham
Nottingham
NG14 7DA
Monitoring fairness and respect for people in custody
Paul Sullivan
By email: request-872506-6fc9ec68@whatdotheyknow.com
12 July 2022
Dear Paul Sullivan,
Freedom of Information Act (FOIA) Request
Thank you for your request dated 21 June 2022 in which you asked for the following information
from the Independent Monitoring Board (IMB) at HMP Lowdham Grange:
In your latest report you mention the continued and consistent use of X-ray body
scanners. As you will be aware the scanners can only be used where there is credible
evidence or intelligence that a person has something concealed internally.
Given the very tight restriction on the use of the scanners could you please:
1: Tell me how many scans were carried out in your reporting year.
2: How many actual men were scanned during this period.
3: What checks you are doing to ensure the very strict criteria for scanning prisoners is
followed, as laid out in the Policy Framework.
Your request has been handled under the FOIA.
For ease, I have included responses below to each of your questions.
1: Tell me how many scans were carried out in your reporting year.
2: How many actual men were scanned during this period.
This information is not held by the Board. This is because we are not the appropriate authority to
contact on this matter. The FOIA does not oblige a public authority to create information to
answer a request if the requested information is not held. The duty is to only provide the
recorded information held. We recommend that you contact the prison directly as they may hold
the information requested:
HMP Lowdham Grange
Old Epperstone Road
Lowdham
Nottingham
NG14 7DA
Tel: 0115 966 9200
You may also consider emailing lowdhamgrange.violencereduction@serco.com if you have a
concern about the safety of a prisoner’s safety. They may also be able to direct your FOI request
to an appropriate contact at Serco.
--- PDF page 2 ---
3: What checks you are doing to ensure the very strict criteria for scanning prisoners is
followed, as laid out in the Policy Framework.
The Board does not perform checks as such; however, the Board monitors activity within the
prison on a structured basis. Such monitoring is neither continuous nor exhaustive, being based
upon a scheme of visits and observations split between all areas of the prison and aspects of
prison life. Some data used by the Board’s Annual Report is empirical while other information
gathered is anecdotal. Fact-based reporting normally relies upon whole data sets collated by the
prison operator (in this case, Serco).
You may nevertheless find the MoJ’s policy document, ‘Use of X-Ray Body Scanners (Adult
Male Prisons)’, dated 18 May 2020, to be helpful. This document outlines the regulation of,
safeguarding, and monitoring responsibility for the use of X-Ray Body Scanners. This document
is attached at Annex A.
If you are not satisfied with this response you have the right to request an internal review by
responding in writing to the address at the top of this letter within two months of the date of this
response.
You do have the right to ask the Information Commissioner’s Office (ICO) to investigate any
aspect of your complaint. However, please note that the ICO is likely to expect internal
complaints procedures to have been exhausted before beginning their investigation.
You can contact the Information Commissioner’s Office at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Internet address: https://www.ico.gov.uk/Global/contact_us.aspx
Yours sincerely
Barbara Morgan
Chair of the IMB at HMP Lowdham Grange
--- PDF page 3 ---
Annex A
--- PDF page 4 ---
Policy name: Use of X-Ray Body Scanners (Adult Male Prisons).
Issue Date: 18 May 2020
Implementation Date: 18 May 2020
Replaces the following documents (e.g. PSIs, PSOs, and Custodial Service Specs) which are
hereby cancelled: None
Introduces amendments to the following documents: None
Action required by:
HMPPS HQ
Governors
Public Sector Prisons
Heads of Group
Contracted Prisons
Contract Managers in Probation Trusts
National Probation Service
Community Rehabilitation Companies
(CRCs)
HMPPS Rehabilitation Contract
Services Team
HMPPS-run Immigration Removal
Centres (IRCs)
Other providers of Probation and
Community Services
Under 18 Young Offender Institutions
Mandatory Actions:
All groups referenced above must adhere to the Requirements section of this Policy Framework,
which contains all mandatory actions.
For Information:
This Policy Framework details the minimum mandatory requirements which are needed for prisons
to purchase, install and operate a legal and effective regime of X-ray body scanning prisoners who
are believed to be engaged in concealing contraband internally.
This Policy Framework relates to Adult Male Prisoners only (all prisoners over 18).
Governors1 of Public Sector Prisons and Directors of Contracted Prisons must ensure that any new
local policies that they develop because of this Policy Framework are compliant with relevant
legislation, including the Public Sector Equality Duty (Equality Act, 2010) and all relevant legislation
outlined in this policy. All actions are mandatory for both Public Sector Prisons and Contracted
Prisons unless specifically detailed otherwise.
Throughout this Policy Framework, the general term prison(s) will refer to describe Public Sector
Prisons and Contracted Prisons, unless there is a specific need to distinguish between the two.
The definition of the term ‘intelligence’, used within this Policy Framework, is the same as the
definition within the Intelligence, Collection, Analysis and Dissemination Policy Framework.
1 In this document the term Governor also applies to Directors of Contracted Prisons
--- PDF page 5 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
2
Policy Framework
Audit/monitoring:
In Public Sector Prisons, Prison Group Directors (PGDs) will monitor compliance with requirements
set out within the Policy Framework in their prisons using the auditing and monitoring tools described
in this framework.
In Contracted Prisons monitoring of compliance will be through the standard contract management
processes.
Health and Safety Assurance and monitoring for Public Sector Prisons is undertaken through Health
and Safety monitoring and assurance within the Health and Safety function, using the health and
safety audit and reporting tool compliance checklist. The Health and Safety processes may be
different for Contracted Prisons and therefore, Contracted Prisons must have their own Health and
Safety arrangements which ensure, so far as is reasonably practicable, the health, safety and welfare
at work of all employees using the X-ray body scanners.
The prison service maintenance group for Public Sector Prisons will undertake statutory mandatory
compliance audits (SMC) to ensure both Public Sector Prisons and Contracted Prisons meet
legislative duties in relation to the maintenance of the x-ray body scanner equipment.
Quality Assurance for Public Sector Prisons and Contracted Prisons is provided by HMPPS
Operational and Systems Assurance Group (OSAG) through the Security Audit.
HMPPS Security Order and Counter Terrorism Directorate (SOCT) will provide assurance for Public
Sector Prisons and Contracted Prisons of monitoring the recording of the X-ray body scan data on
NOMIS.
External inspections can be conducted by the Health and Safety Executive (HSE), the Home Office
and/or the Border Force. Annex A sets out the legal basis for inspections and the enforcement
actions that could be taken.
Resource Impact:
There will be a resource impact due to the additional task of scanning a prisoner and manually
entering the scan information on NOMIS (to ensure a record is kept of the scan, justification and
dosage). The prison will also need to appoint trained Radiation Protection Supervisor(s) at Custodial
Manager (CM) grade or above in Public Sector Prisons if they do not already have them. Directors
of Contracted Prisons must appoint a competent and trained RPS. However, we recognise that this
additional capability has resource implications and must be balanced against the potential, if used
effectively, to reduce the risk of contraband being smuggled by prisoners and the consequent effect
on security and good order, which we know has a significantly negative impact on staff time.
Contact: Security Procedures Team, Directorate of Security, Order and Counter Terrorism (SOCT)
Email: HMPPSbodyscannersupport@justice.gov.uk
Address: 102 Petty France, London, SW1H 9AJ
Deputy/Group Director sign-off: Lorna Shore, Security Investment Programme Director
Approved by OPS for publication: Michelle Jarman-Howe and Sonia Flynn, Joint Chairs,
Operational Policy Sub-board, May 2020
--- PDF page 6 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
3
Policy Framework
Contents
Purpose……………………………………………………………………………………………………….5
Constraints...................................................................................................................................... 5
Evidence ......................................................................................................................................... 5
Outcomes ....................................................................................................................................... 5
Requirements ................................................................................................................................. 7
Radiation Protection Advisory (RPA) services ................................................................................. 7
Staff working with radiation ............................................................................................................. 7
Procurement ................................................................................................................................... 8
Prior to Installation .......................................................................................................................... 8
Installation....................................................................................................................................... 8
RPA Radiation Safety Survey Inspection ........................................................................................ 9
Maintenance / Servicing .................................................................................................................. 9
Prison owned assessment/s and checks ......................................................................................... 9
Local Rules ................................................................................................................................... 11
The RPA Radiation Protection Book ............................................................................................. 11
The Role of the Radiation Protection Supervisor during and after Installation ............................... 11
Accidents and Overexposure ........................................................................................................ 13
Training ......................................................................................................................................... 13
Internal Audits and Assurance ...................................................................................................... 14
Equalities Assurance Monitoring ................................................................................................... 14
Data Protection and Record Keeping ............................................................................................ 15
Identifying prisoners who may be scanned.................................................................................... 15
Prisoners with Protected Characteristics ....................................................................................... 17
Preparing for a Scan ..................................................................................................................... 17
Conducting a Scan ........................................................................................................................ 18
Refusing a Scan / Sabotaging a Scan ........................................................................................... 19
Recording of the Scan .................................................................................................................. 19
Image Interpretation – Outcomes .................................................................................................. 19
Annex A: Enforcement Regime under Part 7A and Part 8 of The Justification of Practices Involving
Ionising Radiation Regulations 2004 (as amended) ...................................................................... 22
Annex B: HMPPS and Privately Contracted Prisons Requirements for Practices for Deploying and
Operating X-Ray Body Scanners that utilise Ionising Radiation for Non-Medical Purposes in
Prisons. ......................................................................................................................................... 24
Annex C: Overview of Site Survey and Location of the X-ray Body Scanner, Radiation Protection
Adviser (RPA) and RPA Radiation Protection Book. ..................................................................... 27
Annex D: LOCAL RULES .............................................................................................................. 29
--- PDF page 7 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
4
Policy Framework
Annex E: Radiological Protection Supervisor appointment letter ................................................... 33
Annex F: Information Notice for Staff and Prisoners ...................................................................... 34
Annex G: Process for adding NOMIS Body Scan entry. ................................................................ 36
--- PDF page 8 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
5
Policy Framework
1.
Purpose
1.1
This Policy Framework provides end-to-end instruction and guidance on the procurement,
installation and use of X-ray body scanners in Adult male prisons to detect if prisoners are
attempting to conceal contraband internally. The mandatory requirements in this document
set out the minimum required for a prison to be compliant with legislation and HMPPS’s
Requirements for Practice for Prisons.
2.
Constraints
2.1
This Policy Framework does not replace or change any of the requirements set out in PSI
07/2016 Searching of the Person and an X-ray body scan must not be used as an alternative
to a full or rub down search. Governors must therefore ensure that the use of all X-ray body
scanners are consistent with both this Policy Framework and the policy on the use of
technical search aids more generally, as set out in PSI 07/2016 Searching of the Person:
ensuring that processes and arrangements for their use are reflected in the Local Searching
Strategy.
3.
Evidence
3.1
Some prisoners attempt to intentionally undermine HMPPS’s security search methodologies
by hiding contraband inside their bodies. HMPPS has a duty to protect prisoners, those
working in or visiting prisons, as well as the public, by taking steps to prevent the importation
and supply of drugs and other contraband into prisons.
3.2
HMPPS’s Security, Order and Counter Terrorism (SOCT) Directorate has, with prisons,
conducted technical tests of the X-ray body scanner equipment for its effectiveness in
confirming whether a prisoner suspected of internally concealing contraband is doing so or
not. If used as part of a searching strategy and with a trained, professional staff group, X-
ray body scanning technology can provide an effective means of confirming the intelligence
or reasonable suspicion that a prisoner is attempting to conceal contraband internally.
3.3
The principal pieces of legislation relevant to the use of X-ray body scanners are the
Justification of Practices Involving Ionising Radiation Regulations 2004 (as amended)
(JOPIIRR), the Ionising Radiation Regulations 2017 and Health and Safety Work At Work
Act 1974.
3.4
The Justification of Practices Involving Ionising Radiation Regulations 2004 (as amended)
require that any use of X-ray technology is approved by the “Justifying Authority”. For
HMPPS, the Justifying Authority is the Secretary of State for the Home Office. Approval from
the Justifying Authority has been issued on the condition that a set of Requirements for
Practice for Prisons are complied with. The mandatory requirements set out in this Policy
Framework translate the actions that are necessary to comply with the Requirements for
Practice (which can be viewed in full at Annex B).
4.
Outcomes
4.1
By following the mandatory actions within this Policy Framework, it is expected that prisons
can:
•
Improve the capability to detect contraband smuggled by way of internal concealment.
•
Contribute to a reduction of drugs and other contraband being smuggled into or out
of a prison.
--- PDF page 9 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
6
Policy Framework
•
Contribute to a reduction in the risks posed by contraband being smuggled into or out
of a prison.
•
Reduce the risk that concealed items may cause harm to the prisoner.
•
Deter exploitation of vulnerable prisoners to convey concealed items.
•
Provide the basis for legal compliance to manage the safety and other health risks
associated with the use of ionising radiation (X-ray).
5.
Requirements
5.1
Adherence to this Policy Framework will ensure that scanning regimes are compliant with the
relevant pieces of legislation. Unlawful use at an individual prison may result in enforcement
action against HMPPS by the Justifying Authority. It is therefore imperative that all prisons
comply with the requirements set out in this document.
5.2
The Home Office is responsible for ensuring there is an inspection regime in place for
HMPPS’ use of X-ray body scanners. If it is found that a prison(s) are breaching the
Requirements for Practice or are non-compliant with The Justification of Practices Involving
Ionising Radiation Regulations 2004, the Home Office can withdraw the Approval or serve a
contravention notice. Failure to comply with a contravention notice is a criminal offence on
the part of the individual failing to comply. If the Approval is withdrawn, none of HMPPS’ X-
ray body scanners can be used.
5.3
If the Requirements for Practice are not complied with, there is a possibility of warning notices
being served by the Justifying Authority under regulation 21E(5). The Governor must respond
to these warning notices by complying with the specified steps within the specified time
frame. If not, the Justifying Authority may withdraw HMPPS’ approval to use X-ray body
scanners if a warning notice is not complied with in the specified time frame.
5.4
Exposure to ionising radiation (above and beyond exposure that occurs naturally in day to
day life) carries a risk to health. Ionising radiation (such as X-ray) can pass through, and
potentially change, the structure of cells. This is why all cases of exposure to ionising
radiation through the use of an X-ray body scanner must be fully justified (the benefit to the
individual or society from exposing a prisoner to radiation must outweigh the health risks to
that individual) and be proportionate. Full compliance with the mandatory actions in this policy
framework allows HMPPS to manage these health risks.
5.5
Only prisoners can be X-ray body scanned, and they must only be scanned: where there is
intelligence or reasonable suspicion that they are internally concealing contraband; where
there is no other means of detecting the suspected contraband (for example full or rub down
search); and evidence that conducting a scan will not cause that individual to exceed HMPPS’
maximum annual dose constraint per individual of 700 microsieverts (µSv) per calendar year.
This calculation must include any doses received at other establishments. (For reference, if
every X-ray body scan was 6 µSv, the total maximum number of scans a prisoner could have
in the calendar year would be 116.) Adherence to this Policy Framework will ensure that all
mandatory steps are taken to ensure that every X-ray body scan can be justified and
proportionate in line with the Requirements for Practice.
5.6
The following persons must not be X-ray body scanned:
•
Visitors
•
Staff
•
Prisoners with female reproductive organs
•
Any prisoner with a ‘Do not X-ray Body Scan’ Alert
--- PDF page 10 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
7
Policy Framework
Radiation Protection Advisory (RPA) services
5.7
HMPPS has a contract with a national radiological service provider to deliver the Radiation
Protection Advisory (RPA) services for the Radiation Safety Survey inspections, Radiation
Protection Supervisor (RPS) training and Local Radiation Advice. These services are a legal
requirement for HMPPS to operate X-ray equipment.
5.8
Radiation Safety Survey inspections are paid for centrally and then re-charged to local prison
business units upon completion; RPS training and Local Radiation Advice is paid for locally
by prisons direct with the supplier. There is a national programme of work scheduled for each
prison on an annual basis and local RPS’ shall be responsible for ensuring this work is carried
out as part of their role. Further information about the role of the RPA is detailed at Annex C.
Staff working with radiation
5.9
No staff working with radiation are regarded as classified persons as defined in the Ionising
Radiation Regulations 2017. There is no requirement for staff to wear personal dose monitors
because:
•
doses likely to be received under normal working, and in the event of an accident,
have been assessed as part of the Ionising Radiation Risk Assessment and are
considered to be low with a minimal risk;
•
the dose levels around the equipment are checked annually by the RPA during the
Radiation Safety Survey inspection and are also checked by the service engineer as
part of a planned preventative maintenance programme;
•
staff, visitors and other prisoners must remain outside the Controlled Area whilst the
machine is in operation; and
•
the Ionising Radiation Regulations 2017 recommends a dose investigation level (DIL)
is established. The employer (HMPPS), in consultation with the RPA has
recommended a DIL of 1mSv. However, considering the assessment of doses carried
out in the Ionising Radiation Risk Assessment and provided the Local Rules (which
are detailed later in this Policy Framework) are complied with, the DIL is unlikely to be
exceeded.
5.10
Measurements of environmental dose rates will be performed during maintenance servicing
and annually by the RPA Radiation Safety Survey inspection to verify that the DIL remains
appropriate. Governors must ensure these measurements are retained for 2 years in
accordance with Regulation 19(8) and Regulation 20(5)(c) of the Ionising Radiation
Regulations 2017. The records must include:
(a) in relation to areas designated on the basis of external radiation, an indication of the
nature and quality of the radiation in question;
(b) in relation to areas designated on the basis of internal radiation, an indication, where
appropriate, of the nature, physical and chemical states of the radioactive contamination.
5.11
There is no requirement for any change in working conditions for pregnant staff due to
radiation dose. Contracted Prisons should clarify their own arrangements for their staff.
5.12
However, staff members, if they have a doctor’s certificate, do not have to be X-ray body
scanner operators or work where there is X-ray body scanner equipment.
--- PDF page 11 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
8
Policy Framework
Procurement
5.13
Public Sector Prisons must not purchase X-ray body scanner equipment without the
agreement of SOCT and outside of the current MOJ contract. Therefore, the prison Governor
must ensure that the acquisition and installation of an X-ray body scanner is conducted in
cooperation with Commercial Contract Management Directorate and SOCT. This is to ensure
that the equipment is effective and represents value for money and that prisons are offered
appropriate support to plan for its use. In many cases, SOCT will be in contact with prisons
at the beginning of the process and a collective decision will have been made as to the need
to procure the equipment. Where this is not the case, prisons must inform SOCT via the
mailbox on the front of this Policy Framework that they seek to acquire an X-ray body scanner
and appropriate support and advice will be provided.
5.14
Contracted Prisons, in the absence of an agreed arrangement, are responsible for the
purchasing and funding of their own X-ray body scanners. However, it is strongly
recommended that they look at the specifications of equipment used in Public Sector Prisons
to ensure that they source effective equipment which complies with legislative requirements
and HMPPS’ Requirements for Practice.
Prior to Installation
5.15
Contracted Prisons must ensure that the HSE are notified of any ionising radiation equipment
and its use. If in doubt as to the HSE registration status, Contracted Prisons should seek the
advice of their appointed RPA regarding the requirements for HSE registration. Individual
notification for Public Sector Prisons is not required as this as this is undertaken centrally by
the Ministry of Justice.
5.16
Prior to installation, the X-ray Body Scanner Advisor in SOCT will co-ordinate a site survey
for the supplier to assess a suitable location in the prison for the X-ray body scanner and will
normally be present at the survey to confirm suitability of its location. The Governor must
ensure the manager of the area where the X-ray body scanner is being installed (most likely
reception), and relevant facilities management staff, are also in attendance for the survey to
seek the agreement of all key parties. Further information about the site survey is detailed at
Annex C.
5.17
Prior to the installation of an X-ray body scanner, and/or any adjustments to the fabric of the
building to accommodate the equipment, a qualified RPA must be consulted to advise on the
suitability of the proposed location for the X-ray body scanner. Furthermore, Governors must
ensure compliance with the manufacturers’ instructions on safe use, including ensuring that
the machines are positioned and operated in accordance with the manufacturers’ guidelines.
Installation
Supplier Installation and Critical Examination
5.18
The supplier – after installation but before initial use, or if the equipment is re-located, or
following replacement of any component that directly affects radiation exposure – will
undertake a ‘Critical Examination’ to ensure that:
•
the safety features and warning systems operate correctly;
•
the equipment provides sufficient protection for all persons against exposure to
radiation;
•
potential doses received by operators and others in the vicinity of the equipment are
as low as reasonably practicable; and
•
those being scanned do not receive a dose in excess of the equipment specification or
Requirements for Practice as agreed with the Justifying Authority.
--- PDF page 12 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
9
Policy Framework
5.19
The supplier of the X-ray body scanner, in consultation with the RPA, must agree the
maximum individual dosage (up to maximum set level of 6 µSv (microsieverts) per scan for
each machine, annual dose constraints and the maximum number of scans permissible
within the annual dose constraint.
5.20
The installer shall provide a written report on the outcome of the Critical Examination together
with adequate information about the proper use, testing and maintenance of the X-ray body
scanner. The RPS must ensure this report is kept in the RPA book and that any
recommended requirements are undertaken during the daily operator and weekly checks (the
RPS role and the RPA book are described below).
RPA Radiation Safety Survey Inspection
5.21
The RPA must carry out a Radiation Safety Survey inspection(s) of the X-ray body scanner
to ensure that the machine is not operating outside of the authorised parameters and the
equipment specification. These Radiation Safety Survey Inspection(s) will be undertaken:
•
when first installed and prior to use;
•
annually;
•
if the equipment is re-located; or
•
following the replacement of any component that directly affects radiation exposure.
5.22
The Radiation Safety Survey inspections by the RPA will form part of the review process and
ensure the X-ray body scanner is calibrated correctly.
5.23
An RPA Radiation Safety Survey Report will arrive shortly after the inspection. However, the
RPA on the day of the safety inspection will give a verbal confirmation that the machine is
safe to operate or otherwise. If the RPA is satisfied on the day that the machine is operating
safely, and the prison meets the requirements of this Policy Framework, the prison may
commence X-ray body scan operations.
5.24
The Radiation Safety Survey inspection will include the radiation dosage check, which must
be carried out by the RPA, which, as a minimum, must be conducted annually.
Maintenance / Servicing
5.25
The Governor must ensure the satisfactory operation of suitable maintenance contracts for
all X-ray body scanner equipment are in place.
5.26
The Governor must ensure the X-ray body scanner equipment is maintained in line with the
manufacturers recommended maintenance schedule of two preventative maintenance visits
per year.
5.27
A written maintenance report will be provided on all maintenance / services undertaken. The
RPS must ensure these reports are kept in the RPA book (the RPS role and the RPA book
are described below).
Prison owned assessment/s and checks
5.28
In addition to the ‘Critical Assessment’ undertaken by the X-ray body scanner installer and
the Radiation Safety Survey Inspection(s) undertaken by the RPA, the Governor needs to
ensure the following assessments are undertaken by the prison:
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•
Initial Ionising Radiation Risk Assessment;
•
Health and safety risk assessment; and
•
Daily and Weekly Checks.
Ionising Radiation Risk Assessment
5.29
In accordance with HMPPS’ Requirements for Practice and Regulation 8 of the Ionising
Radiation Regulations 2017 (IRR17), before equipment is put into use every prison must
undergo an initial Ionising Radiation Risk Assessment of the potential risk of exposure to
radiation for staff operating the machines and any bystanders, as well as prisoners suspected
of concealing contraband internally. The purpose of the assessment is to identify the
measures required to restrict exposure during normal operations and in the event of an
accident. In particular all hazards with the potential to cause a radiation accident must be
identified. Measures must be implemented to prevent any such accident or limit the
consequence should such an accident occur.
5.30
The Head of Function responsible for the X-ray body scanner in the establishment must
ensure the Ionising Radiation risk assessment is undertaken, before the X-ray body scanner
machine is first used, and updated whenever there is a change in practice, following
relocation or an accident. The Head of Function will ensure that a suitable and sufficient risk
assessment is completed, maintained and reviewed. When completing the risk assessment,
the Head of Function may wish to involve the establishment’s Health and Safety Advisor(s)
and HMPPS X-ray Body Scanner Advisor for specialist advice and support, the RPS,
operators of the equipment and where necessary the RPA. The risk assessment template
will be provided when the X-ray body scanner is installed (if procured through SOCT); or it
can be requested via the email address on the front of this Policy Framework.
5.31
The Governor must ensure that any measures identified by the Ionising Radiation Risk
Assessment, as being required to restrict exposure, must be implemented.
Health and safety risk assessment
5.32
In addition, the Governor must conduct a Health and Safety risk assessment of:
•
the risks employees may be exposed to at work; and
•
the risks prisoners and other people who come to prison may be exposed to,
as a result of the use of the X-ray body scanner for the purposes of identifying the
preventative and protective measures to comply with the requirements and prohibitions
imposed upon him/her by or under the relevant statutory provisions described in PSI
37/2015 NOMS Health and Safety (HS) Arrangements for Risk Assessment, and implement
any measures identified and record all significant findings. This risk assessment must be
undertaken in respect of each site where the X-ray body scanner is deployed in conjunction
with/supported by the RPA. The risk assessment must be undertaken before the X-ray
body scanner is used (for the first time). Once the X-ray body scanner is in operation, the
recording and the maintenance of the risk assessment must be kept up to date when there
is a significant change in the matters to which it relates.
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Daily and Weekly Checks
5.33
The X-ray body scan operator must undertake a daily safety check before the X-ray body
scanner machine is used.
5.34
The RPS must undertake a weekly safety check. These checks are to be both recorded in
the Radiation Protection Book (described below).
5.35
The daily and weekly check must include:
•
ensuring the warning light and emergency stop button are working correctly; and
•
checking any other recommended manufacturer or engineer requirements.
Local Rules
5.36
The Governor must ensure a copy of the Local Rules are displayed in a clearly visible
location near the machine. The template is set out at Annex D and the prison must fill in
section 2 and 3.
5.37
In accordance with sections 18 and 19 of the Ionising Radiation Regulations 2017 the Local
Rules must also:
•
set out the names of the Radiation Protection Supervisor(s) (RPS);
•
describe the Controlled Area; and
•
set out the arrangements to ensure:
o an employee or a non-classified outside worker aged 18 years or over does not
receive in any calendar year a cumulative dose of ionising radiation which would
require that person to be designated as a classified person; and
o any other person does not receive in any calendar year a dose of ionising radiation
exceeding the relevant dose limit.
Further details of these requirements are described in more detail below.
The RPA Radiation Protection Book
5.38
The RPS must ensure each X-ray body scanner machine has an RPA Radiation Protection
Book. This is to be kept in a secure location near the machine and be easily accessible for
inspection by the RPA. Details of what must be included in this are contained at Annex C.
The Role of the Radiation Protection Supervisor during and after Installation
5.39
The prison Governor must appoint in writing a sufficient number of trained members of staff
as the RPS(s) for the X-ray body scanner operations. The RPS therefore must be someone
with sufficient authority (minimum Custodial Manager (CM) grade) in Public Sector Prisons
to supervise this task and who regularly works in the area of the X-ray body scanner. In
Contracted Prisons, the Director must appoint sufficient competent staff. An individually
named RPS must be appointed for each area where X-ray body scanner equipment is used.
A template appointment letter is provided at Annex E.
5.40
The number of staff appointed as an RPS must take into consideration any periods of
absence (annual leave, sickness, detached duty), although there must always be one
identified person who holds the overall responsibility for the RPS role for each X-ray body
scanner machine. A fully trained RPS must be appointed before the machine is operated.
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5.41
It is the responsibility of the RPS to ensure that the X-ray body scanner operation is compliant
with the requirements of the Ionising Radiation Regulations 2017, the Requirements for
Practice and the Local Rules for the operation of the X-ray body scanner machine.
5.42
The RPS must ensure that the ‘Local Rules’ (Annex D) clearly describe the operating
procedures, to restrict any exposure of people in the Controlled Area around the X-ray body
scanner and are appropriate to the radiation risk and the nature of the operations undertaken
in that area.
5.43
In relation to the Controlled Area, the RPS must ensure:
•
There is a yellow and black taped demarcation area around the X-ray body scanner
equipment which identifies the space as a Controlled Area so that there is a physically
demarcated area or, where this is not reasonably practicable, delineated by some
other suitable means. The positioning of this tape will be undertaken by the machine
installers and then later confirmed as correct by the RPA as part of the Radiation
Safety Survey inspection. The RPS must ensure yellow and black tape is replaced
appropriately to ensure it always clearly demarks the Controlled Area.
•
That a radiation symbol (Trefoil) is displayed on the entrance/s of the area where the
X-ray body scanner is installed, and that there are suitable and sufficient signs
displayed in suitable positions warning that the Controlled Area has been designated
and indicating the nature of the radiation sources and the risks arising from such
sources.
•
The Controlled Area must be strictly controlled so that no staff, visitors or other
prisoners enter this area when the machine is in operation and therefore would be
exposed to radiation.
5.44
The RPS must take all reasonable steps to ensure that the Local Rules are observed and
are brought to the attention of those staff and other persons who may be affected by them.
The RPS must also ensure all X-ray body scan operators sign a register to evidence their
understanding and compliance. This register must be kept in the RPA book.
5.45
The RPS will need to ensure the prison fully complies with the central Requirements for
Practice and must highlight any deviations from this Policy Framework by email, within 24
hours, to HMPPS HQ policy holders of this Policy Framework via the email contact on page
one of this document.
5.46
The Governor must ensure that the Staff and Prisoner Information sheet provided at Annex
F is displayed on the wall near the X-ray body scanner and be accessible to prisoners being
scanned, and any staff and visitors in the area. This information sheet must also be provided
to prisoners in induction packs. The suitably appointed person must ensure as detailed in
PSI 32/2011 Ensuring Equality that information is appropriately conveyed to prisoners with
protected characteristics, including those with physical or learning disabilities and those who
do not speak English. This Policy Framework must also be made available to prisoners
should they wish to read it.
5.47
The RPS must also:
•
ensure that the installer’s Critical Examination and the RPA’s Radiation Safety
Survey(s) are undertaken;
•
ensure operator daily and weekly checks are carried out and the findings recorded
and maintained in the RPA Radiation Protection Book for audit purposes;
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•
ensure the RPA Radiation Protection Book is kept up to date, in a secure location
near the machine and be easily accessible for inspection by the RPA;
•
ensure arrangements are made for the appropriate operational training of all staff who
work with the equipment;
•
ensure that arrangements have been made for the supervision of contractors, visitors
and other persons who may come into contact with the X-ray body scanner
equipment;
•
be the principal point of contact for liaison with the RPA;
•
on behalf of the Governor, ensure that any remedial action is taken to address any
concerns or recommendations made by the RPA during a Radiation Safety Survey
inspection and recorded in good time according to the recommendation in the RPA
report;
•
liaise with maintenance personnel for any defaults, faulty equipment and maintenance
visits and hold copies of all maintenance/service reports; and
•
ensure an internal monitoring process is in place to ensure that X-ray body scan data
is recorded in accordance with the Policy Framework requirements for data recording,
outlined in 5.60 -5.64.
Accidents and Overexposure
5.48
If it is suspected that any person (employee or other) may have received a radiation dose
above the dose investigation level (1 miliseivert), the RPA must be contacted, by the RPS,
for further advice. The RPA will decide whether further investigation is required. The RPA will
advise on the matters to be considered as part of the investigation and on the conduct and
outcome of that investigation. The RPS must also inform SOCT via the email address on the
front of this Policy Framework within 24 hours of the incident occurring.
Training
5.49
The Governor must ensure that staff who undertake the RPS role complete the RPS training
before the RPS appointment confirmation. To receive a certificate evidencing completion of
the training the staff member will have had to demonstrate sufficient knowledge and
competency in radiation matters and have completed the full training course. RPS training
(including refresher training) must be sourced from HMPPS’ contracted RPA. RPS refresher
training must take place within a 5-year period or when there is a change in practice or
technology, and a training record must be held at each prison establishment and on the
national database via SOP.
5.50
The Governor must ensure that staff operating the X-ray body scanner equipment complete
mandatory training in machine operation and basic radiation awareness before they operate
the X-ray body scanner equipment. This training will include how to operate the machine and
the health and safety risks to both the operator, other members of staff and the prisoner.
Additionally, staff should undertake image interpretation training provided by HMPPS
Learning and Development Group. The record of this training needs to be held at each prison
establishment and on the national database via SOP.
5.51
Post installation of the X-ray body scanner, the Governor must ensure that a minimum of two
members of staff are identified to attend a Workshop for Trainers which will enable the prison
to deliver the local operator radiation awareness training and image interpretation training.
Workshop for Trainers is available through HMPPS Learning & Development. Contracted
Prisons will be able to purchase this training from HMPPS Learning & Development.
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5.52
The RPS must ensure that only staff trained in machine operation and basic radiation
awareness use the X-ray body scanner machine and there must be a sufficient number of
trained staff to ensure the equipment can be operated when required.
Internal Audits and Assurance
5.53
Any failure identified during the internal audits will either be reported to the PGD or HMPPS
HQ policy holders (depending on the audit); the HMPPS SOCT Senior Business Owner
(Head of Security Counter Measures) may also be informed for further action. Non-
compliance may also be reported to the Justifying Authority (Secretary of State for the Home
Office) which could result in the withdrawal of HMPPS’ authorisation to use X-ray body
scanners in all prisons. Compliance with the requirements is therefore vital.
Health and Safety Audit
5.54
Health and Safety Assurance and monitoring for Public Sector Prisons will be undertaken
through Health and Safety monitoring and assurance within the Health and Safety function,
using the health and safety audit and reporting tool compliance checklist. This audit will be
used to monitor compliance with the Ionising Radiation Regulations 2017.
5.55
The Health and Safety processes may be different for Contracted Prisons and therefore,
Contracted Prisons must have their own Health and Safety arrangements which ensure, so
far as is reasonably practicable, the health, safety and welfare at work of all employees using
the X-ray body scanners.
Prison Service Maintenance Group Audit
5.56
The prison service maintenance group will undertake statutory mandatory compliance audits
(SMC) to ensure both Public Sector Prisons and Contracted Prisons meet the Ionising
Radiation Regulations 2017 legislative duties in relation to the maintenance of equipment.
HMPPS Operational and Systems Assurance Group (OSAG) Security Audit
5.57
For both Public Sector Prisons and Contracted Prisons, the Quality Assurance audit will be
undertaken OSAG as part of the prison’s Security Audit. This audit will ensure that systems
of control and mandatory actions, in line with this Policy Framework, are in place, including
the monitoring of individual radiation dosage, justification for X-ray body scanner use and
good record keeping.
HMPPS (SOCT) Data Monitoring Assurance
5.58
HMPPS (SOCT) will provide monitoring assurance on the recording of the X-ray body scan
data on NOMIS. The prison Governor must ensure that the prison complies with all
management information and performance data requests for data around the use of the X-
ray body scanner.
Equalities Assurance Monitoring
5.59
The Governor must ensure that the use of the X-ray body scanner on any particular prisoner
group with a protected characteristic is regularly monitored and addressed where identified.
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Data Protection and Record Keeping
5.60
The Governor must ensure there is a local data retention policy that reflects the data retention
requirements below.
5.61
The date, dosage and justification (either intelligence or reasonable suspicion) for each scan
must be recorded on HMPPS’ case management system NOMIS. Annex G details how these
details are to be recorded on NOMIS. Justification decisions for the use of the X-ray body
scanner on an individual must be recorded as an Intelligence Report or on the monthly
security minutes (described in 5.66-5.67); and will form part of the history for the justification
of why a particular prisoner was selected to be X-ray body scanned in that instance.
5.62
The X-ray body scan image and associated data recorded on the X-ray body scanner
machine must be deleted within 24 - 36 months after the scan has been undertaken unless
there is an on-going complaint or litigation from the relevant prisoner. This timeframe is based
on the potential need for the image, data, auditing purposes and enables the prison to
undertake a 12-month data deletion once per year.
5.63
If a hard copy of an X-ray body scan image is necessary/requested for the purpose of
adjudication, segregation decisions, or ongoing complaint or litigation, the X-ray body scan
can be printed, but must be destroyed after a decision has been made, or no longer needed
for a complaint or litigation. Before it is destroyed, the hard copy of the image must be kept
in a sealed envelope and kept with the paperwork (segregation paperwork / adjudication
paperwork / complaint or any other relevant paperwork relating specifically to the X-body
body scan or process)
5.64
X-ray body scan images may be retained for training purposes. Any image that is used for
training purposes must be anonymised. If it is possible to identify an individual from the
image, it must not be used for training purposes.
5.65
The Governor must ensure an internal monitoring process is in place to ensure that X-ray
body scan data is recorded in accordance with the requirements above.
Identifying prisoners who may be scanned
5.66
Prisons can X-ray body scan a prisoner without obtaining the prisoners consent2.
5.67
Prisoners must not be selected for X-ray body scanning on a random basis.
5.68
All cases of exposure to ionising radiation through the use of an X-ray body scanner must
be:
•
fully justified in accordance with The Justification of Practices Involving Ionising
Radiation Regulations 2004. This means that the exposure may only occur when the
benefit to the individual or society outweighs the health detriment that may be caused
to the individual;
•
necessary for the prevention and detection of crime or disorder and/or connected to:
prison security, prison order or prison discipline, or protecting the safety of prisoners,
visitors or prison staff; and
•
proportionate.
2 See Regulation 21G of The Justification of Practices Involving Ionising Radiation 2004
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5.69
To demonstrate that a scan is justified all five points below must be met:
•
intelligence or reasonable suspicion suggests that the prisoner is internally concealing
contraband;
•
there are no other means of detecting the suspected contraband (for example, a full
or rub down search);
•
it is necessary to reduce the risks posed by contraband being smuggled into or out of
a prison and that these risks outweigh the health detriment caused by exposure to
radiation;
•
there are no other circumstances of the prisoner, the intelligence or the reasonable
suspicion, which would make the exposure disproportionate; and
•
there is evidence that the scan will not cause that individual to exceed the maximum
annual dosage constraint of 700 µSv per individual in the current calendar year. The
X-ray body scan operator must check the prisoner’s NOMIS record to ensure the
dosage constraints have not been met. If records are missing, the prisoner must not
be scanned until it is confirmed that they have not exceeded the dosage constraint.
5.70
Use of the X-ray body scanner must be led by intelligence or reasonable suspicion. For
example, the action for an X-ray body scan could have come from:
•
direct communications from the Security Department that the individual is likely to be
internally concealing an item;
•
agreed action at the monthly security meeting;
•
direct communications from Police, Courts or other law enforcement agencies that
the individual is likely to be internally concealing contraband;
•
reasonable suspicion during or following a visit that the individual is likely to be
internally concealing contraband; or
•
reasonable suspicion that the individual is likely to be internally concealing an item
which could be based on information on the prisoner’s Prisoner Escort Record (PER)
or pre-sentence interview, report or behavioural indicators.
5.71
Any decisions relating to the use of the X-ray body scanner on individuals or groups must be
recorded as an Intelligence Report or on the monthly security minutes as described below;
and will form part of the history for the justification of why a particular prisoner was selected
to be X-ray body scanned in that instance. Monthly security meeting minutes or direct written
communications from the Security Department or other agencies are a sufficient record of
the justification used. Where intelligence is used as the justification, the format and route for
sharing intelligence is by an intelligence assessment provided by the prison intelligence unit
via secure email, as per local process. It should not include the evaluation code.
5.72
In some circumstances a prisoner may be part of a group of prisoners where there is
intelligence or reasonable suspicion for that group to be X-ray body scanned. However, the
prison must still be satisfied that each individual scan is justified and proportionate as
described in 5.69.
5.73
There are no health reasons why a prisoner should not be scanned, except as provided in
paragraph 5.76. A prisoner can still have an X-ray body scan if they have had or are
undergoing medical procedures (this includes any form of medical X-ray / radiotherapy).
5.74
If the prisoner reaches the 700 microserverts yearly annual maximum dosage, the member
of staff who is first made aware of this, must ensure a ‘Do not X-ray body scan’ NOMIS Alert
is added to NOMIS (for the remainder of the calendar year). This NOMIS Alert can then be
removed at the start of a new calendar year (1st January).
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Prisoners with Protected Characteristics
5.75
In line with other government agencies (such as Border Force and the NHS) there is no
requirement for the X-ray body scan operator to be the same sex as the prisoner being
scanned and this is because images are only X-ray quality. Privacy concerns are mitigated
by the fact that the prisoner is not naked. However, the X-ray body scan image could reveal
some physical detail of the prisoner being scanned. If the prisoner objects to a female staff
member undertaking and interpreting the scan, the prison should, where possible, facilitate
a male member of staff to interpret the scan (depending on the prison’s operational
capability). This is at the discretion of the prison. Any objections or concerns should be
considered on an individual basis based on the specific circumstances.
5.76
A pragmatic and considerate approach should be applied to scanning prisoners with
disabilities as it may not always be possible to conduct a scan. If a prisoner is unable to stand
unaided they should not be scanned. If the prisoner is unable to stand unaided, a ‘Do not X-
ray body scan’ alert should be added to NOMIS. The staff member who becomes aware of
this is responsible for putting the NOMIS alert on the system.
5.77
Transgender women and post-operative transgender men who no longer have female
reproductive organs can be scanned.
5.78
Due to the potential harm to a foetus, a prisoner may not be scanned if they have female
reproductive organs; this risk may arise in relation to pre-operative transgender men who
consequently must not be scanned. However, staff must be careful not to reveal that the
prisoner is transgender. A ‘Do not X-ray body scan’ alert must be put on NOMIS (at the
earliest point) for all pre-operative transgender men. The staff member who becomes aware
of this is then responsible for putting the NOMIS alert on the system. All staff should provide
the prisoner with sight of Annex F before scanning, so that a prisoner understands they
should not be scanned if they have female reproductive organs and has the opportunity to
make the prison aware.
5.79
Staff should refer to the Transgender Policy Framework for further information. A Local
Transgender Case Board should be held at establishment level within 14 days of someone
identifying as transgender. This should include the creation of a voluntary agreement, which
should cover agreements with regard to searching. It is appropriate that a sensitive
discussion would take place alongside a wider conversation concerning the prisoner’s
particular needs before a scan is undertaken.
5.80
The Governor must ensure that information is communicated (verbally and in writing) to
prisoners before they are scanned on the purpose of the scan and associated health and
safety implications. That information must be appropriately conveyed to prisoners with
protected characteristics, including those with physical or learning disabilities and those who
do not speak English (PSI 32/2011 Ensuring Equality). An example of a Staff and Prisoner
information sheet is provided at Annex F.
Preparing for a Scan
5.81
Before conducting a scan, the following steps must have been taken:
•
You must have assessed that a scan is justified and proportionate (section
5.69).
▪ All cases of exposure to ionising radiation through the use of an X-ray body
scanner must be fully justified, proportionate and the individual or societal benefit
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of the exposure must outweigh any potential health risks. The justification for any
scan must be recorded, in all cases, on NOMIS.
•
You must check the prisoner can be scanned by checking NOMIS alerts. If there
is a ‘Do not X-ray body scan’ the prisoner cannot be scanned.
▪ Some prisoners cannot be X-ray body scanned and therefore, NOMIS must be
checked.
•
You must check the prisoner record on NOMIS to ensure that a further scan
would not exceed the cumulative dosage limit of 700 µSv per individual per
calendar year.
▪ Every instance of exposure from an X-ray body scanner in the current calendar
year must be calculated using the information available on NOMIS. If records are
missing, the prisoner must not be scanned until it is confirmed that they have not
exceeded the dosage constraint.
•
You must explain the process for X-ray body scanning to the prisoner.
▪ If the justification for a scan remains, the prisoner must be provided with a
reasonable level of information about the use of X-ray body scanners and the
proposed radiation exposure. Template information sheets are provided at Annex
F.
▪ The information must be appropriately conveyed to prisoners with protected
characteristics, including those with physical or learning disabilities and those who
do not speak English.
•
You must have provided the prisoner with an opportunity to hand over any
contraband.
▪ Before conducting a scan, the prisoner must be asked if they are in possession of
an unauthorised item. In doing so, they must be offered the opportunity to privately
hand over any internally concealed items, in line with PSI 07/2016 Searching of
the Person and relevant hygiene procedures. If the prisoner hands over items, the
justification and proportionality of the scan must be reassessed.
•
You must ensure the prisoner is able to physically undertake a scan (for
example the prisoner is able to stand for the duration of the scan).
Conducting a Scan
5.82
Staff working with radiation are not regarded as classified persons. There is no requirement
for staff to wear personal dose monitors as the dose levels around the equipment are checked
regularly as described in 5.9 – 5.10.
5.83
With the exception of the prisoner being scanned, all other persons must remain outside of
the yellow and black demarked Controlled Area around the X-ray body scanner. The
Controlled Area must be strictly controlled so that no staff, visitors or other prisoners enter
this area when the machine is in operation and therefore would be exposed to radiation.
5.84
Trained X-ray body scan operators must be familiar with the operating instructions for the
specific X-ray body scanner in use at the prison and must explain to the prisoner the process
so they know what is going to happen and how the scan will be conducted.
5.85
The prisoner must be provided with a clear verbal instruction of how they must stand for the
operator to take an image. To ensure the operator can take a good image, it is important that
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Policy Framework
the prisoner remains still during the scan. The prisoner should put one hand on the rail and
the other by their side to improve the imaging.
5.86
Following the scan and subsequent interpretation of the image, local operating procedures
must provide clear instruction as to where and how the prisoner will be safely located during
this period.
5.87
In the event that the image is unclear, the operator may want to seek assistance from another
trained member of staff. If the operator concludes that the image is unclear, another scan
could be considered if it continues to be justified.
Refusing a Scan / Sabotaging a Scan
5.88
If a prisoner refuses to be scanned, or intentionally moves to distort the image, it may be
appropriate to charge the prisoner with an offence against prison discipline under Rule 51(22)
Prison Rules 1999/Rule 55(25) Young Offender Institution Rules 2000 (see PSI 05/2018
Prisoner Discipline Procedures (Adjudications) for further detail), or have their incentive level
downgraded and in accordance with the Prison’s Incentive Scheme.
5.89
If staff believe that this is the case, they should consider whether it is necessary to manage
the prisoner, in terms of risk to self, as if they do have an internally concealed item (as below).
5.90
Prisoners may be subject to more than one scan per day, provided that each scan is justified
and proportionate.
5.91
Prisoners must not be restrained in order to be X-ray body scanned.
Recording of the Scan
5.92
The date, dosage and justification (either intelligence or reasonable suspicion) of each scan
must be recorded on NOMIS. This must be recorded as soon as practical after the scan is
conducted. The NOMIS record must also record whether or not any suspected contraband
was detected by the scan. Annex G details how these details are to be recorded on NOMIS.
5.93
Any scan that indicates a positive detection of contraband and there is a ‘find’, must be
recorded on the Incident Reporting System (IRS) as a contraband find. All reports must
include details of what the contraband is (if known) and must record the method of detection.
Image Interpretation – Outcomes
Image shows no contraband being internally concealed
5.94
If the operator concludes that the scan image indicates that the prisoner is not internally
concealing contraband, this information must be recorded on NOMIS and the prisoner should
be processed in line with the local operating procedures.
5.95
If an X-ray body scan of a prisoner shows a negative scan image (no internal concealed
contraband identified), but the prisoner has been seen by staff or another person to internally
conceal an item, then the X-ray body scan operator must be mindful that the image could
have been misinterpreted, or not have shown on the X-ray scan. Therefore, the prison, using
the information and reasonable suspicion, may decide to manage the prisoner in terms of
risk to self, as if they do have an internally concealed item (as below).
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Image shows contraband being internally concealed
5.96
If the operator concludes that the scan image indicates that the prisoner is internally
concealing contraband, this information must be relayed to healthcare as soon as possible
in case the internally concealed item may cause a risk to the prisoner. Information must
include what the item could be (for example, drugs / mobile phone / weapon), enabling
healthcare to manage the health risks to the prisoner (please refer to PSI 07/2016 Searching
of the Person).
5.97
The prisoner must be informed that the image taken by the X-ray body scanner indicates that
they are internally concealing contraband. If the item is accessible the prisoner must be asked
to hand over the contraband. A private area should be made available for this purpose as is
set out in PSI 07/2016 Searching of the Person.
5.98
Staff who handle items that the prisoner has removed from the anal, genital or oral area must
comply with PSI 07/2016 Searching of the Person. They must take appropriate hygiene and
health precautions and clinical waste procedures should be followed. Staff must wear single
use disposable gloves (which are disposed of through clinical waste) with access to hand
washing facilities. Any items found or handed over must be retained in evidence and
appropriately marked, transported, stored and dealt with in line with PSI 08/2016 Dealing with
Evidence.
5.99
Similarly, where prisoners are asked to remove, or do remove, items from their anal, genital
or oral areas, they must be provided with single use disposable gloves (which are disposed
of through clinical waste) and have access to hand washing facilities.
5.100 If the prisoner agrees, a member of healthcare should be asked to observe the physical
condition of the prisoner both before and after removal of the contraband. A private area
should be made available for this purpose.
5.101 In the event that the prisoner refuses to hand over the item, staff must consider whether it is
appropriate to give a direct order to hand over the contraband (the item needs to be
accessible for the order to be reasonable). In doing so, staff must consider that the prisoner’s
failure to comply with a lawful order may constitute an offence against prison discipline.
5.102 If the prisoner refuses or is unable to remove or pass a suspected item the prison must
consider the risks presented by that prisoner to themselves and/or others. In all cases the
prison must consider the location and observation requirements of the prisoner. This could
include use of segregation and/or ACCT, if applicable, locating the prisoner in healthcare, or
sending the prisoner for outside medical intervention. This decision should be made in
conjunction with the advice from healthcare.
5.103 If the prisoner has an unknown internally concealed item, a competent operational manager
/ Duty Director needs to ensure that a defensible decision is made on any actions taken/not
taken and recorded on NOMIS. This could include location of the prisoner and requirements
for observations (and frequency). If the prisoner is to be segregated, authority to do so must
first be sought from a competent operational manager / Duty Director. Segregation must be
consistent with PSO 1700 Segregation under Rule 45 (YOI Rule 49) Good Order or Discipline
(GOoD) and should be for the shortest period of time consistent with the reason for
segregation in the first place.
5.104 Any continued use of segregation must be in line with PSO 1700 Segregation and is only
likely to be justified and proportionate for as long as the risk remains that the prisoner has
internally concealed contraband.
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5.105 If the prisoner states they are no longer concealing contraband and has passed it or removed
it, staff may then consider whether a further scan is justified and proportionate in accordance
with this Policy Framework.
5.106 The prison must consider whether the case should be referred to the police in accordance
with the Crime in Prison Referral Agreement and/or for adjudication.
5.107 If an internally concealed contraband item is detected, for adjudication purposes a
photograph (in this case an X-ray body scan image) can be accepted as evidence. For such
cases, it may be appropriate to lay a charge under Prison Rule 51(12) / YOI Rule 55(13);
please refer to PSI 05/2018 Prisoner Discipline Procedures (Adjudications) for more
information.
5.108 Prisoners will still be required to be transferred between establishments, or to attend court or
medical appointments. The knowledge that the prisoner has an internally concealed item
does not automatically mean the prisoner cannot be transferred. The competent operational
manager / Duty Director should ensure that an individual risk assessment is undertaken and
consider what measures can be applied to mitigate the risk. Options for additional security
measures on escort include, but are not limited to: use of prison or specialised contractor
vehicles, additional number of prison escort staff, application of restraints (which must be
separately risk assessed on an individual basis), notification of details of the escort to police
and, if justified and proportionate, a request for police escort.
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Annex A
Enforcement Regime under Part 7A and Part 8 of The Justification of Practices Involving
Ionising Radiation Regulations 2004 (as amended)
Regulation 21E and Requirements for the Practice for HMPPS – it is a specific requirement for
prison staff to comply with the Requirements for Practice in carrying out the X-ray body scanning
practice in prisons under rule 21E(3).
Warning Notices – if the Requirements for Practice are not complied with, there is a possibility of
warning notices being served by the Justifying Authority under regulation 21E(5). It is essential you
respond to these notices by complying with the specified steps within the specified time frame the
Justifying Authority may withdraw HMPPS’ approval to use x-ray body scanners if a warning notice
is not complied with in the specified time frame.
Consent – under regulation 21G, the requirement to obtain prior consent before conducting a scan
does not apply to scans conducted by law enforcement officials. This term is defined to include:
(a) A governor of a prison
(b) An officer of a prison
(c) A person working at a prison who is authorised by the governor of the prison to exercise powers
of search
(d) A director of a contracted out prison
(e) A prisoner custody officer of a contracted out prison
(f) A worker at a contracted out prison who is authorised by the director of the contracted out prison
to carry out restricted activities.
Contravention Notices in Regulation 22 – the Justifying Authority (Home Office) may serve a
contravention notice if it appears that a prison has breached the Requirements for Practice, that
dose constraints have been exceeded, that prisons have failed to provide a reasonable level of
information to prisoners before scanning them). The contravention notice would specify the steps
that must be taken within a specified period. It is the prisons responsibility to comply with the steps
set out in the contravention notice within the specified time period.
Inspection – Regulation 23A. The Justifying Authority must establish an inspection regime to
monitor whether prisons have breached the Regulations or failed to comply with the Requirements
for Practice. The findings from each inspection would be communicated to the prison. Prisons are
obliged to cooperate with inspections in any way that is required of them by officials of the Justifying
Authority.
Enforcement Powers – Regulation 23 and Schedule 1. The Justifying Authority’s enforcement
powers include the following: power to enter the prison, investigate, examine items, take photos,
measurements and recordings and take samples. The Justifying Authority may require that the
scanner and any part of the prison is left undisturbed or require the X-ray body scanner to be
dismantled and taken away for testing. The powers also includes the powers to require staff with
relevant information to answer questions, to require the production of records of scans, to inspect
records, to take copies of records, and to require staff to provide assistance with their investigation.
Offences – Regulation 24. It is a criminal offence to fail to comply with a requirement in a
contravention notice, without reasonable excuse or to provide false, misleading or reckless
information, statements or materials. It is also a criminal offence to obstruct the justifying authority
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when it is exercising its enforcement powers, which would include obstructing officials of the
Justifying Authority when they were carrying out their inspection via their powers of entry, refusing
or failing to provide them with facilities, assistance or information or preventing someone from
answering their questions. The offence is triable either way. A person found guilty on summary
conviction can be liable to a fine or to imprisonment for up to three months or both. A person found
guilty on conviction on indictment can be liable to a fine or to imprisonment for up to two ears or both.
Application to the crown of the criminal offences – Regulation 25A. The crown is not criminally
liable for contravention of the provisions in the Regulations. However, individual crown servants can
be liable for the criminal offences, as can private prison staff. In practice, this means that whilst
HMPPS cannot be prosecuted, private prison providers and individual prison staff in private or public
prisons can be. In relation to HMPPS, the High Court could also declare unlawful any act or omission
by a public sector prison which would have constituted a criminal offence were it not for the crown
immunity provision.
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Annex B
HMPPS and Privately Contracted Prisons Requirements for Practices for Deploying and
Operating X-Ray Body Scanners that utilise Ionising Radiation for Non-Medical Purposes in
Prisons.
•
HMPPS and Privately Contracted prisons using non-medical X-ray machines3 must consider
the potential radiation risk to staff and other persons as well as prisoners suspected of
smuggling contraband internally. A risk assessment, in accordance with the requirements of
the Ionising Radiations Regulations 2017 (IRR17), must be undertaken in respect of each
site where scanners are deployed. Additional risk assessments under regulation 3 of the
Management of Health and Safety at Work Regulations 1999 may also be required.
•
If there is a change to agreed practices or new prisons adopting non-medical X-ray
machines, HMPPS and Contracted Prison Providers must review the local risk assessment
or set one in place if none exists.
•
The use of non-medical X-ray machines by HMPPS and Contracted Prison Providers is
subject to the requirements of the IRR17. As such, expert advice on compliance from a
Radiation Protection Adviser is required.
•
Before initial use after installation or following relocation, non-medical X-ray machines must
have their radiation performance measured by the equipment installer to ensure:
•
potential doses received by operators and others in the vicinity of the equipment of the
equipment are as low as reasonably practicable;
•
those being scanned do not receive a dose in excess of the equipment specification or the
Requirement for Practice as agreed with the Justifying Authority.
•
HMPPS and Contracted Prison Providers must comply with manufacturers’ instructions on
safe use of the non-medical X-ray machines and must ensure that the machines are
positioned and operated in accordance with manufacturers’ guidelines. HMPPS or
Contracted Prison Providers must consult their RPA when installing this type of equipment
for the first time, or when moving it within the establishment.
•
HMPPS and Contracted Prison Providers must undertake risk-assessments in consultation
with a Radiation Protection Adviser and carry out routine image quality testing to ensure the
dose per scan remains within the limits of the equipment specification and the Requirements
for Practice as agreed with the Justifying Authority. This may also be undertaken by the
equipment supplier under a service management contract.
•
HMPPS and Contracted Prison Providers must comply with HMPPS instructions on the use
of the non-medical X-ray equipment, must comply fully with any mandatory
requirements/control measures and undertake any remedial action needed as directed by
the Justifying Authority.
•
HMPPS and Contracted Prison Providers must provide Local Rules, specific to each site, as
required by IRR17.
•
Governors/Directors must appoint a competent and trained member of staff as the Radiation
Protection Supervisor (RPS) for each area of the prison where a non-medical X-ray scanner
3 “Non-medical” is a term generally accepted in the radiation protection community to differentiate the type of units
used by HMPPS and Contracted Prison Providers from standard medical X-ray units, e.g. a hospital chest X-ray.
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is used. The RPS must ensure that the radiation operation is controlled in accordance with
Local Rules and compliant with legislative requirements identified by the Radiation Protection
Adviser.
•
Only staff trained in the operation of non-medical X-ray body scanners may operate these
machines as part of their designated duties. Training will include operating the machine and
the health and safety risks to both the operator and the subject. Staff may only operate the
equipment as part of their designated duties and in line with instructions provided. In the case
of any change in practice and/or technology, Governors/Directors must ensure operators are
appropriately trained to use the equipment.
•
Any prisoner who may be subject to a scan using ionising radiation must be provided with
appropriate and relevant guidance to ensure that they are aware of the purpose of the scan
and associated health and safety implications. As a minimum, information notices must be
displayed in the location of the scanner and provided verbally before each scan. Information
should also be included in prisoner induction packs, provided on entry to the prison.
•
HMPPS and Contracted Prison Providers must undertake an annual review with each prison,
in consultation with their RPA, to agree the maximum individual dosage (up to maximum set
level of 6 µSv (microsieverts) per scan for each machine, annual dose constraints and the
maximum number of scans permissible within the annual dose constraint. This will be
informed by the technical specifications of the machine, as well as an assessment of local
intelligence and operational requirements at each prison.
•
The manufacturers and installers of X-ray scanners, in consultation with their RPA, must
ensure that the machine does not exceed a maximum individual dosage of 6 µSv
(microsieverts) when operating at maximum power.
•
HMPPS and Contracted Prison Providers must, in consultation with their RPA, ensure that
regular performance checks are undertaken on X-ray body scanners to ensure that the
equipment continues to operate within the specified limits.
•
Each scan must only be conducted where there is intelligence or reasonable grounds to
suspect that an item is being concealed by a person internally. The intelligence can be
HMPPS owned intelligence and/or intelligence received from external agencies, either linked
to specific prisoners or cohorts. A person must not be scanned routinely or on a random
basis.
•
HMPPS and Contracted Prison Providers must ensure non-medical X-ray machines are used
only when it is necessary and proportionate to do so for the prevention and detection of crime
or disorder and / or connected to: prison security, prison order or prison discipline, or
protecting the safety of prisoners, visitors or prison staff.
•
Each individual scan / exposure to ionising radiation must be justified and appropriate records
must be kept for each scan in accordance with HMPPS national guidance. As part of these
records, establishments must demonstrate that the operational / security and societal
benefits of exposure outweigh the anticipated health risks to the individual. A scan should
only be conducted when the balancing exercise has resulted in this conclusion.
•
All non-medical scans must be conducted in accordance with the procedural instructions set
out in national HMPPS guidance.
•
No person must exceed the maximum number of scans. This includes any scans conducted
at another prison.
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•
HMPPS and Contracted Prison Providers must ensure that records are kept of each non-
medical scan and are able to share these records with other prisons to ensure that no
individual exceeds the agreed annual dosage constraint. This requirement is in addition to
any system inherent in individual scanners which raises an alert if an individual is
approaching annual exposure limits.
•
HMPPS and Contracted Prison Providers must consult with their RPA with regards to staff
exposure (operating positions and similar) and must comply with their advice.
•
Any action undertaken as a result of a non-medical scan must be appropriate and
proportionate, taking into account national HMPPS guidance, the Prison Act 1952, Prison
Rules 1999, the Offender Management Act 2007 and the potential threat identified as a result
of the scan.
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Annex C
Overview of Site Survey and Location of the X-ray Body Scanner, Radiation Protection
Adviser (RPA) and RPA Radiation Protection Book
Site Survey and Location of the X-ray Body Scanner
A site survey by the supplier should be completed to capture the following:
•
Assess the working environment for the health and safety of both staff and prisoners.
•
Assess the security of the equipment in the proposed location and the potential for prisoner
indiscipline or damage.
•
Assess the radiation protection impact Controlled Area
In doing so, it should capture the below information:
•
Access / route for delivery of equipment and manual handling requirements.
•
Risks to the equipment or staff installing equipment at time of installation.
•
Description of area of deployment.
•
Diagram and photographs of area.
•
Diagram / description of radiation protection impact Controlled Area.
•
Detailed measurements of location of equipment in relation to surrounding areas.
•
Security of the equipment and potential for prisoner indiscipline or damage.
•
Where and what signage is required.
The X-ray body scanner is a large piece of equipment and will need a suitable and safe area to be
installed with space around it for a Controlled Area to be cordoned off. Any windows in the selected
area should also be considered as the radiation can affect people walking outside the window if they
are within the vicinity. Although the location must be operationally effective for the prison, safety
must take priority and the location must comply with the Ionising Radiation Regulations 2017. Trefoil
signage must be displayed in and around the Controlled Area at points of entry to this area.
Radiation Protection Adviser (RPA)
HMPPS has appointed a Radiation Protection Advisor under contract. Details of the current provider
are available from Commercial Contracts Management Directorate (CCMD). The RPA is responsible
for:
•
Delivering the Radiation Protection Advisory (RPA) services for the Radiation Safety Survey
inspections, Radiation Protection Supervisor (RPS) training and Local Radiation Advice.
•
Providing HMPPS with general advice on radiation protection for staff and others who may
be affected, including advice on compliance with relevant statutory requirements and new
developments in radiation safety.
•
Giving specific advice on radiation protection of staff and others to each prison where security
X-ray equipment is used.
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•
Advising on the completion of the assessments of the risks to staff from ionising radiation
and on the control measures that must be implemented to eliminate or reduce the risk.
•
Visiting each prison where security X-ray equipment is used at a frequency determined by
the RPA as appropriate for type and use of equipment. These visits will include an inspection
and survey of X-ray body scanner equipment and reviews of radiation safety.
•
Compiling a report following each visit identifying any problems, the remedial work that needs
to be done to rectify any identified problems and a time scale for completing the work.
•
Providing information for the RPA Radiation Protection Book for each establishment
•
Undertaking of Radiation Safety Survey of new equipment. Giving advice when requested on
new equipment and facilities.
•
Providing training for RPS(s) as required.
•
Advise on Local Rules.
•
Providing advice on remedial action and undertaking investigations and dose assessments
as appropriate, in the event of any accident or potential exposure involving radiation of staff
or others.
•
Providing HMPPS with regular reports describing the work carried out within the scope of the
RPA contract and identifying any trends or concerns.
Radiation Protection Book
The RPS will compile and maintain the Radiation Protection Book. The book will include:
•
A description of each item of equipment and its location.
•
Names, addresses and contact numbers for all persons having a radiation protection role in the
use of X-ray body scanner equipment.
•
The training schedule for all persons involved in the work with the equipment.
•
RPS appointment letters from the Governor
•
Signed log of all operators who have signed to state they have read and understood the local
rules.
•
Risk assessments.
•
A description of the designated Controlled Area.
•
The Local Rules for radiation safety, including contingency plans.
•
Copies of the RPA’s reports and any other relevant correspondence.
•
Results of the daily and weekly checks.
•
Critical Examination reports provided by the Supplier
•
Maintenance and service reports provided by the service engineer.
•
Fault log.
•
Operator daily checks
•
RPS weekly checks
•
Register of X-ray body scan operators’ signatures to confirm they have read, undertook and will
adhere to the Local Rules.
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LOCAL RULES
Annex D
Ionising Radiations Regulations 2017
Low dose X-ray body scanner systems
1
INTRODUCTION
These Local Rules are issued under the Ionising Radiations Regulations 2017 and Approved Code
and are the means of complying with these regulations for work with X-ray body scanner equipment.
The Radiation Employer is HM Prison and Probation Service.
Equipment, Serial Number and Location
2
RADIATION PROTECTION SUPERVISOR (RPS)
The Radiation Protection Supervisor is responsible for supervising the work with radiation in
accordance with these Local Rules.
The Radiation Protection Supervisor (s) for this area is/are:
3
RADIATION PROTECTION ADVISOR (RPA)
Radiation protection services are provided by:
The Radiation Protection Advisor is:
4
DESIGNATION OF STAFF, PERSONAL MONITORING AND DOSE INVESTIGATION
LEVEL
Staff working with radiation are not regarded as classified persons. There is no requirement for
staff to wear personal dose monitors as the dose levels around the equipment are checked regularly.
A dose investigation level (DIL) of 1mSv is recommended. However, provided these Local Rules are
complied with the DIL is unlikely to be exceeded. Measurements of environmental dose rates will be
performed during servicing and annually by the radiation protection service to verify that the DIL
remains appropriate.
There is no requirement for any change in working conditions for pregnant staff due to radiation
dose.
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5
DESIGNATION OF CONTROLLED AND SUPERVISED AREAS
In accordance with IRR17 certain areas are designated as Controlled or Supervised Areas. These
areas exist as long as the X-ray body scanner equipment is connected to the mains supply at
the console.
5.1
Controlled Areas
A Controlled Area shall exist whenever the x-ray body scanner is connected to the mains electricity
supply and switched on. The extent of the Controlled Area is demarcated by the yellow and black
tape and the fixed barriers (walls, doors etc…).
A Controlled Area shall cease to exist when the x-ray body scanner is disconnected from the mains
electricity supply.
5.2
Access to Controlled Areas
i) Only the prisoner undergoing scanning should be in the Controlled Area when X-ray
body scans are produced.
ii)
Engineers and physicists may access the Controlled Area during scanning for test
purposes only, but must not stand on the scanning platform when the X-ray beam is
on. In these circumstances control of the x-ray equipment and responsibility for
radiation protection shall be handed over to the engineer or physicist. Handing over
control and responsibility of the area shall be by a formal written procedure the
reciprocal of which shall be followed when the control and responsibility is handed back
to the prison.
6
OPERATING PROCEDURES
All employees, contractors and visitors must comply with these Local Rules and co-operate in their
implementation.
The X-ray body scanner equipment mains must be switched off when it is not in use.
6.1
Radiation Protection Supervisors
The Radiation Protection Supervisors must:
i) Oversee the use of the X-ray body scanner equipment to ensure it is in accordance
with these Local Rules.
ii)
Ensure the records in the Radiation Protection Book are kept up to date.
iii)
Report any concerns about radiation safety and/or safety features to the RPA and the
Head of Function responsible for the X-ray body scanner equipment.
iv)
RPS to call out maintenance supplier for any damage to any X-ray body scanner
equipment safety features.
6.2
Employees Operating Radiation Equipment
i) Only authorised, trained employees or contractors may operate the X-ray body
scanner equipment. These people must be listed in the local Radiological Protection
Book.
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ii)
Employees and contractors must receive appropriate training before operating X-ray
body scanner equipment
iii)
Unsupervised equipment must be isolated from the mains supply at the console.
iv)
The login and password to start the equipment must not be left near the unit.
v)
Employees, contractors or members of the public, with the exception of the person
being scanned, must not access the Controlled Area when the system is producing X-
ray body scans. Access must be prevented with the use of a barrier (exception for dose-
rate checks during testing).
vi)
Any damage to any X-ray body scanner equipment safety features or radiation safety
concerns must be reported immediately to the RPS. .
vii)
Persons must not interfere with any safety devices or attempt to repair any part of the
X-ray equipment unless authorised to do so.
6.3
Cleaning Personnel
i) Cleaning personnel may only clean around X-ray body scanner equipment at times
previously arranged by local management or the RPS.
6.4
Visitors / Service Engineers / Physicists
i) All visitors must comply with verbal and/or written instructions issued by the authorised
operator of the equipment.
ii)
The RPS (or nominated deputy) shall formally handover the control of the x-ray
equipment and hence responsibility for radiation protection to the visiting service
engineer or physicist using a handover form either provided by the prison or provided
by the service engineer/physicist.
iii)
Any maintenance personnel who are employees of the prison shall work to these local
rules. Any visiting service engineer or physicist to whom the equipment and controlled
area are handed over shall work to their employer’s local rules and risk assessment.
They must make the RPS aware of the Local Rules and radiation risk assessment that
will be in operation before starting any work. Once the work is finished the x-ray
equipment and controlled area shall be formally handed back to the RPS (or nominated
deputy).
iv)
Any service engineer or physicist who carries out a temporary modification to an X-ray
body scanning unit which affects its output or quality must:
a)
Attach to the equipment an appropriate warning notice.
b)
Inform the RPS in writing if the modification is of a permanent nature.
7
CONTINGENCY PLANS
i)
If an X-ray body scanner inspection needs to be aborted for any reason, for example non-
termination of X-rays, the operator must terminate the inspection as follows:
a)
Depress the EMERGENCY STOP button to close the machine down completely and
switch off.
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b)
Report the incident to the RPS and the Head of Function responsible for the X-ray
body scanner equipment, or if not available the Duty Governor.
ii)
If the emergency action was due to an equipment fault, the RPS, or equivalent grade must
ensure that the equipment is not used until the necessary repair work has been successfully
completed. Should the RPS not be available then notification shall be made to the next senior
member of staff with managerial responsibility (e.g. head of function or local governor for the
area) who shall initiate the process for having the equipment repaired.
iii)
Any service engineer who making repairs under this Contingency Plans must be provided
with details of the nature of the fault/problem and any hazards that are thought to exist.
Written confirmation that the equipment has been repaired and is safe to use must be
provided before the equipment is returned to routine use.
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Radiological Protection Supervisor appointment letter
Annex E
HMP xxxxx
Date xxxxxx
Radiological Protection Supervisor
[Name of RPS],
I hereby appoint you Radiation Protection Supervisor (RPS) for HMP XXXXXX.
The RPS is responsible for helping HMP XXXXX to ensure the radiological safety of all personnel
within the workplace. In addition, your duties as RPS are as follows:
▪
To ensure that HMP XXXXX activities are compliant with The Ionising Radiations Regulations
2017 (IRR17);
▪
To maintain an inventory of x-ray equipment on the premises and to update the RPA of any
changes in the equipment inventory.
▪
To liaise with maintenance personal for any defaults, faulty equipment and maintenance visits
and hold copies of all maintenance/service reports.
▪
Ensuring that Local Rules are available and are being complied with.
▪
Ensure arrangements are made for the appropriate operational training of all staff who work with
the equipment.
▪
Ensuring that arrangements have been made for the supervision of contractors, visitors and other
persons who may come into contact with the X-ray body scanning equipment.
▪
Ensure daily operator checks are made before use and recorded in the Radiation Protection
Book for audit purposes.
▪
Ensuring that the weekly checks on the correct operation of the safety features (warning lights,
emergency stop buttons) are carried out and the findings recorded in the Radiation Protection
Book for audit purposes.
▪
Maintaining the RPA Radiation Protection Book.
▪
Maintain the signed register of X-ray body scan operators confirming they have read, undertook
and will adhere to the Local Rules.
▪
Ensuring that remedial action required as the result of an RPA safety inspection is completed
and recorded in good time.
▪
On behalf of the prison Governor to ensure that action is taken to address any concerns or
recommendations made by the RPA during a safety inspection.
Name: ……… (Person issuing the letter)
Position: Governing Governor
Signature………….………………….….
Date:
Name………(RPS)
Position:
I accept the appointment as RPS for HMP
XXXXX
Signature………….………………….….
Date:
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Information Notice for Staff and Prisoners
Annex F
What is an X-ray body scanner?
An X-ray body scanner machine uses ionising radiation to provide high resolution and real time body
view images.
Is it safe?
The X-ray body scanner does omit, during a scan, a low dose amount of radiation which could impact
health. However, HMPPS’ full compliance with the mandatory actions in the Policy Framework
ensures compliance with The Ionising Radiation Regulations 2017. Therefore, no person being
scanned will be exposed to a radiation level which exceeds the legal limits.
When is it used?
Scans are only undertaken when it is assessed as necessary and proportionate in order to prevent,
detect or investigate crime, to maintain prison security, good order and discipline and there is
intelligence or reasonable suspicion that the person is internally concealing an item.
What is it used for?
It is used to detect contraband ingested or internally concealed within body cavities that may cause
harm or threats to the person being scanned or other people within the prison.
Some of the items that it can identify are:
•
metallic and non-metallic weapons
•
explosives
•
drugs
•
mobile phones, USB’s and SIM cards
•
jewellery, gems and precious metals.
What is the justification for its use & the prison’s responsibilities?
Prisons are authorised to conduct these scans under the Justification of Practices Involving Ionising
Radiation 2004 (as amended 2018) and the approval for use held by HMPPS.
The X-ray body scanner will be used in addition to other searching procedures in accordance with
PSI 07/2016 Searching of the Person.
Prisons must consider the requirement for a scan, weighing up the societal benefit, against any
potential health risks caused by the X-ray machine. Every scan must be justified and proportionate,
which means:
•
There must there must be intelligence or reasonable suspicion that a prisoner is concealing items
inside themselves;
•
There is evidence that the scan will not cause that individual to exceed the maximum annual
dosage constraint of 700 µSv per individual in the current calendar year.
•
There are no other means of detecting the suspected contraband (for example full or rub down
search).
Prisons are required to operate under strict guidelines and safeguards to ensure that the risks to
health are minimal for the person being scanned and others operating and in the vicinity of the
scanner.
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Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
35
Policy Framework
Instructions and Information for prisoners being scanned:
•
If you have female reproductive organs you must not be scanned. You should make the prison
aware at this point before scanning if you do have female reproductive organs.
•
Comply with the instructions / orders given by the officer (refusing a scan may be considered as
a failure to comply with a lawful order which may constitute an offence against prison discipline).
•
Answer the officer’s questions in a truthful and honest manner. Before a scan, you will be asked
if you are in possession of an unauthorised item and given the opportunity to hand over any
internally concealed items in privacy.
•
There is no legal requirement for prison staff to obtain consent from those being scanned before
conducting a scan. If you refuse to be scanned, you may be subject to disciplinary action under
Prison Rule 51/YOI Prison Rule 55 for disobeying a lawful order.
•
It is important that you stay still and do not twist or turn during the scan. If you move you may be
subject to another scan and/or disciplinary action under Prison Rule 51/YOI Prison Rule 55 for
disobeying a lawful order may be taken.
•
The machine produces an internal image (it is not a graphic image). You should talk to staff if
you have any concerns.
•
Action may be taken if contraband is believed to be internally concealed. This may include
disciplinary action under Prison Rule 51/ YOI Prison Rule 55 for having an unauthorised article
in your possession, located in segregation, or healthcare, or sent outside for medical intervention.
•
If you have any concerns about your health because you are internally concealing contraband
please ask to see healthcare.
•
The internal complaints process should be used if you wish to raise any concerns about the way
in which the scan was conducted.
•
Please note female staff work in this establishment and the X-ray body scan image may be taken
and/or subsequently viewed by female members of staff. If you have any concerns please talk
to staff before the scan is undertaken.
•
Anonymised scan images may be used for training and/or research purposes.
For more information regarding the X-Ray Body Scanners please refer to the Use of X-Ray
Body Scanners (Adult Male Prisons). The Policy Framework which should be made available
in the prison Library.
--- PDF page 39 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
36
Policy Framework
Process for adding NOMIS Body Scan entry
Annex G
The current approach set out in this Annex is an interim solution until the new NOMIS method of
recording can be put in place, when this Annex will then be updated.
Step 1:
Select ‘Offender Personal Details’ and ‘Personal Care Needs’ as per the arrow below
Step 2:
In ‘Care type’ tab select ‘Prisoner X-Ray Body Scan’ as per the arrow below, press OK.
Step 3:
Under ‘Sub Type’ select the dosage of ‘Body Scan’ that was used, in this example it was
5.5µSv as per the arrow below, press OK.
--- PDF page 40 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
37
Policy Framework
Step 4:
In the Description tab, type in the reason for the scan, examples of this could be:
•
Intelligence
•
Reasonable Suspicion
The date will automatically come up, if this needs to change to a past date, manually
change.
Step 5:
Under the ‘Status’ tab select ‘Ongoing’ as per the arrow below, press OK.
That entry is now complete.
--- PDF page 41 ---
Use of X-ray Body Scanners (Adult Male Prisons)
Issue Date: 18 May 2020
38
Policy Framework
If another scan is undertaken, add in another entry, as the example below.