In brief
Radiation safety in industrial radiography and medical imaging has two layers: licensing, dose limits and radiation protection rules come from Nuclear Regulatory Authority (NDK) legislation, while risk assessment, health surveillance and training come from Law No. 6331. On site, the work is managed by the radiation protection officer; radiation workers wear personal dosimeters, radiation areas are classified and marked as controlled and supervised areas, and visitors are not allowed into controlled areas.
Ionising radiation safety: two layers of legislation
Radiographic testing of weld seams in a facility producing pressure vessels and pipelines, X-ray and fluoroscopy in a hospital, panoramic imaging in a dental clinic; in all of these, employees share the same environment with ionising radiation. Ionising radiation safety requires two separate layers of legislation to be applied together in the workplace:
- NDK legislation: Licensing or authorisation of the radiation source, the radiation protection programme, dose limits, dosimetry, radiation areas and the radiation protection officer. The core regulation is the Nuclear Regulatory Authority's Regulation on Authorisations for Radiation Facilities and Radiation Practices (Official Gazette 28.10.2023/32353). In addition, the Regulation on Radiation Protection and Licensing in Industrial Radiography applies to industrial radiography, and the Ministry of Health's Regulation on Radiology Services (Official Gazette 26.04.2022/31821) applies to healthcare facilities.
- Law No. 6331: OHS legislation requires radiation to be dealt with in the risk assessment like any other hazard, along with health surveillance, training, the protection of pregnant and breastfeeding employees, and coordination between employers working in the same area.
These two layers do not replace each other. A workplace with an NDK licence cannot skip radiation in its risk assessment on the grounds that "we have a licence"; nor can the OHS specialist change the NDK's licence conditions on their own. The two need to come together in the same file.
Who is responsible? The radiation protection officer and the radiation worker
The current NDK regulation defines two core roles:
| Role | Basis | Main duty |
|---|---|---|
| Authorised person (licence or permit holder) | Authorisations Reg. Art. 4, 28 | Employing a sufficient number of radiation protection officers, providing measuring devices and dosimeters, arranging training and medical surveillance |
| Radiation protection officer | Authorisations Reg. Art. 4/i, 28/1-b | The person with the qualifications set by the Authority who manages radiation protection practices on site |
| Radiation worker | Authorisations Reg. Art. 4/j | An employee who, by virtue of their duties, may be exposed above the dose limits set for the public |
| Radiographer | Industrial Radiography Reg. Art. 4 | A person who performs exposures under the supervision of the radiation protection officer and holds a certificate of competence from the Authority |
The expression radiation officer, often heard on site, is used in older texts and some sector-specific regulations; the current NDK regulation uses the concept of the "radiation worker". In healthcare facilities, Art. 11/6 of the Regulation on Radiology Services requires at least one person to be appointed as radiation protection officer in every radiology centre, unit and supervised radiology unit.
In industrial radiography, the radiation protection officer is a person with at least a bachelor's degree in the natural sciences or a Level 3 certificate in the radiography method, at least two years of experience in radiation practices and a certificate of competence from the Authority. Their duties include assigning tasks before each job, not permitting any practice where radiation protection is inadequate, ensuring that measuring instruments and personal dosimeters are used, and notifying employees of dosimeter results against signature (Art. 18/b).
The OHS specialist and the radiation protection officer have different roles; having both on the risk assessment team is the most practical way to bring the two layers of legislation together.
Radiation dosimeters: who wears them, and how are results tracked?
A personal dosimeter is a device that measures the dose an employee receives and is read by a dosimetry service at set intervals. The regulations require the following:
- NDK: The authorised person supplies the passive dosimeters to be used by radiation workers classified as category A, ensures they are used correctly and sent to the dosimetry service on time; it also supplies suitable measuring devices and active dosimeters (Art. 28/1-e and i).
- Healthcare facilities: Staff working with ionising radiation sources in controlled areas must wear a personal dosimeter (Radiology Services Reg. Art. 13/1).
- Industrial radiography: A personal dosimeter is provided for every member of staff and at least one radiation measuring instrument for every radiography device; if the Authority recommends it, a pen or alarm dosimeter is also issued (Art. 18/a).
A dosimeter is only meaningful if used correctly. The following rules should be applied on site:
- A dosimeter is personal; it is not given to anyone else or borrowed.
- It is worn throughout work, in the position specified in the instructions; it is not left in the radiation area at the end of the job.
- Reading periods are not missed; dosimeters are sent to the service on time.
- Results are notified to the employee; an unexpected increase should be investigated jointly by the radiation protection officer and the workplace physician.
Under NDK legislation, personal dose and medical surveillance records are kept until the practice is removed from regulatory control (Authorisations Reg. Art. 33); the industrial radiography regulation requires records to be kept for thirty years (Art. 42).
Area arrangements: controlled and supervised areas
Art. 28/1-ı of the Authorisations Regulation requires radiation areas to be classified, marked with warning signs and access to them to be controlled. Art. 22 of the industrial radiography regulation defines areas where 1 mSv per year may be exceeded as radiation areas and divides them into two:
| Area | Definition | In practice |
|---|---|---|
| Controlled area | An area where entry and exit are subject to special control, work follows special rules, and the use of personal dosimeters and measuring instruments is mandatory | Visitors may not enter under any circumstances; entry is limited to authorised employees |
| Supervised area | An area where personal dose measurement is not mandatory but ambient radiation must be monitored | Visitors may enter with the permission of the radiation protection officer, for a set time and accompanied |
For X-ray room safety, the on-site equivalent of this arrangement is: there is a radiation warning sign on the door, a warning light that comes on during exposure makes access control easier, the door is kept closed during exposure and no unauthorised person enters the room. How tasks such as holding the patient during exposure are to be done is set out in the radiation protection officer's written instructions. Lead-equivalent aprons and thyroid shields should be stored hanging rather than folded and checked regularly for tears and cracks. For the general rules on warning signs, see our article on health and safety signs.
The three basic principles of radiation protection apply in both areas: time (work with the source is completed in the shortest possible time), distance (sufficient distance from the source is maintained, as the dose rate falls with the square of the distance) and shielding (when time and distance are not enough, barriers of dense materials such as lead and concrete are used).
Industrial radiography: when exposures are made at your facility
If a metal and machinery business carrying out welded fabrication has its radiographic testing done by a licensed non-destructive testing firm and the exposures are made on its own site, the two employers must work in cooperation and coordination under Art. 23 of Law No. 6331. As the host employer, plan the following:
- Timing: Move open-site exposures, if possible, to outside shift hours or to times when the area can be cleared.
- Work permit: The exposure starts with a written permit under the permit-to-work system; the permit states the boundaries of the area, the duration and the responsible persons.
- Closing off the area: The safety tape and warning signs put up by the radiographer are binding on your employees too. Shift supervisors and forklift operators are informed in advance that the taped-off area must not be entered.
- Documents: The firm's NDK licence, the certificates of competence of the radiation protection officer and radiographers, and the calibration of the measuring device are checked before the exposure.
- Emergency: Art. 40 of the industrial radiography regulation requires the licence holder and the radiation protection officer to prepare a hazard situation plan. If the source does not return to its shielded position, bringing it to a safe position is done only by persons or organisations holding a maintenance and repair licence from the NDK; your employees do not interfere with the source, they clear the area and wait for the responsible person.
For the division of responsibility between employers in the same area, see our article on more than one employer in the same work area.
Health surveillance, pregnancy and risk assessment
Health surveillance for radiation workers draws on two sources. The NDK regulation requires medical surveillance of category A radiation workers to be carried out regularly; the industrial radiography regulation requires haematological, dermatological, psychological and neurological checks of staff on recruitment and at the intervals specified in the licence. The workplace physician assesses dosimeter results together with the health file at pre-employment and periodic examinations; the content and frequency of additional tests are determined according to the relevant legislation and dose records. We plan tests with authorised healthcare providers.
Pregnancy is a situation that needs to be dealt with separately in radiation work. Art. 13/5 of the Regulation on Radiology Services states that the annual dose of pregnant staff may not exceed the annual dose limit set by the NDK for the public; for the general prohibitions concerning pregnant and breastfeeding employees, see our article on pregnant and breastfeeding employees. When a pregnancy is notified, the employee's duties should be reassessed jointly by the workplace physician and the radiation protection officer.
Open a separate section for radiation in the risk assessment and link the NDK licence, radiation protection programme, area classification and dose records to this section. For practice in dental clinics, our article on OHS in dental clinics, and for other topics specific to healthcare facilities, our healthcare facilities page offer guidance. At businesses in Bursa and the surrounding provinces, we deal with radiation risk together with the radiation protection officer under our risk assessment and health surveillance services. You can track dosimeter reading and examination dates with the OHS calendar.
Frequently Asked Questions
Are the radiation worker and the radiation protection officer the same person?
No. A radiation worker is an employee who, by virtue of their duties, may be exposed above the public dose limit. The radiation protection officer is the person with the qualifications set by the NDK who manages radiation protection practices.
Must everyone working in an X-ray room wear a dosimeter?
The Regulation on Radiology Services makes it mandatory for staff working with ionising radiation sources in controlled areas to wear a personal dosimeter. Who falls within this scope is determined by the area classification and the radiation protection programme.
An outside firm performs radiography at our factory; what is our responsibility?
Radiation protection is managed by the licence-holding firm and its officer. You, under Art. 23 of Law No. 6331, ensure coordination, plan the exposure with a work permit, inform your own employees and make sure the taped-off area is not entered.
How long are personal dosimeter records kept?
The Authorisations Regulation requires personal dose and medical surveillance records to be kept until the practice is removed from regulatory control. The industrial radiography regulation requires records to be kept for thirty years.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.