Postal Threat Assessments
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Many organisations use security X-ray scanners to screen mail, parcels, baggage and other items entering their premises. These systems play an important role in helping businesses, government departments, educational establishments and critical infrastructure sites identify potential threats before they reach staff or visitors.
However, because security X-ray scanners generate ionising radiation, their use is subject to legal requirements. In the UK, these requirements are covered by the Ionising Radiations Regulations 2017 (IRR17).
For many organisations, IRR17 can seem complicated at first. Terms such as Radiation Protection Adviser (RPA), Radiation Protection Supervisor (RPS), Local Rules and risk assessments are often unfamiliar, particularly when purchasing an X-ray scanner for the first time.
The good news is that compliance does not need to be difficult. With the correct advice, training and procedures in place, security X-ray scanners can be operated safely and effectively while meeting the requirements of the regulations.
In this guide, we explain what IRR17 is, why it applies to security X-ray equipment and what UK businesses need to know before installing and operating an X-ray scanner.
Does IRR17 Apply to Security X-Ray Scanners?
- Does IRR17 apply to security X-Ray scanners?
- Fully Enclosed Cabinet Systems
- Open-Ended Tunnel Systems
- Why does IRR17 matter?
- What does IRR17 mean for my organisation?
- What is Radiation Protection Adviser (RPA)?
- What is a Radiation Protection Supervisor (RPS)?
- RPA vs RPS – What is the difference?
- Registering security X-Ray equipment with the HSE
- Who is legally responsible for IRR17 compliance?
- What happens when you purchase a security X-Ray scanner?
- How My Group Security can help
What is IRR17?
IRR17 stands for the Ionising Radiations Regulations 2017.
The regulations were introduced to protect employees, contractors, visitors and members of the public from unnecessary exposure to ionising radiation in the workplace.
IRR17 applies to organisations undertaking work involving:
- Radiation generating equipment, including X-ray scanners
- Radioactive materials
- Naturally occurring radioactive substances in certain industries
The regulations came into force on 1 January 2018 and are enforced by the Health and Safety Executive (HSE).
For businesses operating security X-ray scanners, IRR17 establishes the framework for ensuring equipment is installed, operated and maintained safely.
Rather than preventing the use of X-ray equipment, the regulations are designed to ensure radiation exposure is kept As Low As Reasonably Practicable (ALARP).
Does IRR17 apply to security X-Ray scanners?
Yes.
Any organisation operating a security X-ray scanner that generates ionising radiation must consider its responsibilities under IRR17.
This includes equipment used for:
- Mail screening
- Parcel screening
- Baggage screening
- Visitor and security screening
- Goods inspection
The exact requirements may vary depending on the type of equipment being used and the findings of the organisation’s radiation risk assessment.
Fully Enclosed Cabinet Systems
Some security X-ray scanners are designed as fully enclosed cabinet systems.
Examples include cabinet mail screening scanners such as the MR10, MR15 and MR40.
These systems feature:
- A fully enclosed inspection chamber
- Shielded cabinet construction
- Safety interlocks preventing access during scanning
- Contained radiation generation during normal operation
Because the inspection area is completely enclosed, these systems generally present a lower radiation exposure risk during everyday operation.
Open-Ended Tunnel Systems
Many parcel, baggage and mailroom X-ray scanners use an open-ended tunnel design.
These systems feature:
- A shielded inspection tunnel
- Entry and exit openings for continuous item screening
- Lead-lined protective curtains
- Internal shielding designed to contain radiation within the tunnel
Although the X-ray beam remains contained within the scanner during normal operation, additional considerations may be required during installation, radiation surveys and risk assessments due to the design of the inspection tunnel.
Throughout this article, the terms “fully enclosed cabinet systems” and “open-ended tunnel systems” refer specifically to security X-ray screening equipment. Different terminology may be used in medical, industrial and scientific radiation applications.
Why does IRR17 matter?
While modern equipment is designed to operate safely, employers still have legal responsibilities.
IRR17 requires organisations to consider how radiation risks will be managed and controlled throughout the lifetime of the equipment.
This includes:
- Assessing potential radiation risks
- Providing suitable operator training
- Establishing safe working procedures
- Appointing appropriate radiation safety personnel
- Maintaining equipment correctly
- Seeking specialist advice where required
The responsibility for compliance ultimately remains with the employer operating the equipment.
What does IRR17 mean for my organisation?
Every organisation is different, but most businesses operating security X-ray equipment will need to address several key areas.
Radiation Risk Assessment
Before equipment is installed or used, a suitable radiation risk assessment should be completed.
The assessment should consider:
- Who may be exposed to radiation
- Normal operating conditions
- Maintenance activities
- Potential equipment faults
- Emergency situations
- Measures used to reduce risk
The risk assessment forms the foundation of the organisation’s radiation protection arrangements.
Local Rules
Many organisations will require written Local Rules.
Local Rules provide practical guidance on the safe operation of the equipment and may include:
- Operator responsibilities
- Safe working procedures
- Emergency arrangements
- Access controls
- Contact details for radiation safety personnel
Local Rules help ensure that all operators follow a consistent approach to safety.
Training
Anyone operating or supervising security X-ray equipment should receive appropriate training.
Training may cover:
- Safe operation of the scanner
- Radiation awareness
- Local Rules
- Emergency procedures
- Reporting requirements
Regular refresher training may also be recommended depending on the organisation and the advice provided by its Radiation Protection Adviser.
What is a Radiation Protection Adviser (RPA)?
One of the first terms many organisations encounter when researching IRR17 is Radiation Protection Adviser, often shortened to RPA.
An RPA is a suitably qualified radiation safety specialist who provides expert advice on the safe use of ionising radiation and compliance with IRR17.
For organisations operating security X-ray scanners, the RPA plays an important role in helping employers understand their legal responsibilities and implement appropriate radiation protection measures.
An RPA may provide advice on:
- Radiation risk assessments
- Security X-ray scanner installations
- Local Rules
- Radiation surveys
- Staff training requirements
- Changes to working practices
- Ongoing compliance with IRR17
In most cases, the RPA will be an independent external consultant with specialist knowledge of radiation safety and the regulations that apply to ionising radiation equipment.
While an RPA provides advice and guidance, responsibility for complying with IRR17 remains with the employer operating the equipment.
What is a Radiation Protection Supervisor (RPS)?
Whilst the RPA provides specialist advice, the Radiation Protection Supervisor (RPS) helps ensure that safe working practices are followed within the organisation.
The RPS is usually an employee appointed by the employer to oversee day-to-day radiation safety arrangements.
Depending on the organisation, the RPS may be a:
- Facilities Manager
- Security Manager
- Mailroom Manager
- Health and Safety Manager
- Operations Manager
The RPS helps ensure that:
- Local Rules are followed
- Operators work safely
- Radiation safety procedures are maintained
- Concerns are reported and addressed
- Staff understand their responsibilities
The RPS is not expected to be a radiation expert. Instead, they act as the organisation’s local point of contact for radiation safety and help ensure that the advice provided by the RPA is implemented in practice.
For most businesses operating security X-ray equipment, appointing an internal member of staff as the RPS is both practical and cost-effective, as they are already familiar with the organisation, its procedures and the personnel operating the equipment.
RPA vs RPS – What is the difference?
The roles of the RPA and RPS are often confused, particularly by organisations purchasing their first security X-ray scanner.
The simplest way to understand the difference is:
- The RPA advises.
- The RPS supervises.
The Radiation Protection Adviser provides expert guidance on compliance with IRR17 and radiation safety requirements.
The Radiation Protection Supervisor helps ensure that operators and managers follow the procedures, Local Rules and safe working practices established by the organisation.
Radiation Protection Adviser (RPA)
- Usually an external consultant
- Radiation safety specialist
- Provides expert advice
- Advises on risk assessments and Local Rules
- Supports the employer
Radiation Protection Supervisor (RPS)
- Usually an employee
- Internal supervisor
- Oversees day-to-day compliance
- Helps ensure Local Rules are followed
- Represents the employer on site
Both roles are important and help organisations maintain safe and compliant working environments when using security X-ray equipment.
Registering security X-Ray equipment with the HSE
IRR17 introduced a requirement for employers to notify, register or seek consent from the Health and Safety Executive (HSE) before undertaking certain types of work involving ionising radiation.
For organisations operating security X-ray scanners, registration with the HSE is often required before the equipment is brought into service.
The registration process is completed online and is designed to ensure that employers have considered their radiation protection responsibilities before beginning work with ionising radiation.
As part of the registration process, organisations should ensure they have:
- Considered their responsibilities under IRR17
- Obtained appropriate radiation protection advice
- Implemented suitable safety arrangements
- Identified who will oversee radiation safety within the organisation
The requirements can vary depending on the type of equipment being used and the activities being undertaken. Businesses should therefore seek advice from their appointed RPA before registering.
Who is legally responsible for IRR17 compliance?
One of the most common misconceptions surrounding IRR17 is that responsibility sits with the RPA, the RPS or the equipment supplier.
In reality, responsibility for compliance remains with the employer operating the security X-ray equipment.
Whilst the RPA provides specialist advice and the RPS helps supervise day-to-day arrangements, neither role transfers legal responsibility away from the organisation.
The employer is responsible for ensuring that:
- Radiation risks are properly assessed
- Appropriate training is provided
- Local Rules are established where required
- Suitable radiation protection measures are implemented
- Equipment is maintained and tested
- Advice is obtained from a competent RPA
- Staff follow safe working procedures
For this reason, organisations should view compliance as an ongoing responsibility rather than a one-off exercise completed when the equipment is installed.
With appropriate planning, training and support, compliance with IRR17 is typically straightforward and forms part of a wider commitment to workplace safety.
What happens when you purchase a security X-Ray scanner?
For many organisations, purchasing a security X-ray scanner is the first time they have encountered IRR17 and the requirements associated with ionising radiation equipment.
Whilst the regulations can appear daunting at first, the process is usually straightforward when planned correctly and supported by experienced suppliers and advisers.
The exact requirements will vary depending on the type of equipment being installed and the advice provided by the appointed Radiation Protection Adviser (RPA), but a typical installation process may include:
Before recommending any equipment, My Group Security will normally undertake a site survey to understand your environment, operational requirements and existing security procedures.
As part of this process, we may also carry out a Postal Threat Assessment. This helps organisations identify the types of threats they may be exposed to and determine whether additional mail screening measures are required.
A Postal Threat Assessment considers factors such as:
- The nature of your organisation
- The types of mail and parcels received
- Existing security procedures
- Potential threat levels
- Mail handling processes
Understanding the risks facing an organisation is an important first step in determining the most appropriate screening procedures and security equipment.
You can learn more about Postal Threat Assessments in our dedicated article:
Postal Threat Assessments: Identifying and Reducing Mailroom Risks
Before the equipment enters service, organisations should obtain advice from a suitably qualified Radiation Protection Adviser (RPA).
The RPA can provide guidance on matters such as:
- Risk assessments
- Local Rules
- Radiation surveys
- Staff training requirements
- Ongoing compliance arrangements
Many organisations appoint an internal member of staff to act as the Radiation Protection Supervisor (RPS).
This individual helps oversee day-to-day compliance and acts as the organisation’s point of contact for radiation safety matters.
Once installed, the equipment may be subject to radiation testing and verification to confirm it is operating safely and in accordance with the manufacturer’s specifications.
This helps provide reassurance that shielding, safety systems and radiation levels meet the required standards.
Operators should receive appropriate training covering:
- Safe operation of the equipment
- Radiation awareness
- Local Rules
- Emergency procedures
- Reporting processes
Training helps ensure staff are confident in both using the equipment and understanding their responsibilities.
How My Group Security can help
At My Group Security, we understand that purchasing a security X-ray scanner is about much more than selecting the right equipment.
Many organisations are unfamiliar with IRR17, Radiation Protection Advisers, Radiation Protection Supervisors and the regulatory requirements associated with operating X-ray equipment. As part of our consultative approach, we help guide customers through the process and explain the steps required before equipment enters service.
This often starts with a site survey and Postal Threat Assessment, helping organisations understand their risks before any equipment recommendations are made.
Depending on the project, we can also assist with:
- Understanding IRR17 requirements
- Introducing customers to experienced Radiation Protection Advisers
- Coordinating installation requirements
- Arranging operator training
- Supporting the implementation of Local Rules
- Providing ongoing support after installation
Our aim is to make the process as straightforward as possible, helping organisations improve their mailroom and security screening procedures whilst ensuring they understand the practical steps required to operate X-ray equipment safely and compliantly.
Frequently asked questions
IRR17 stands for the Ionising Radiations Regulations 2017. The regulations are designed to protect employees, contractors, visitors and members of the public from unnecessary exposure to ionising radiation in the workplace.
The regulations apply to organisations working with radiation-generating equipment, including security X-ray scanners, and set out the requirements for managing radiation risks safely.
Yes,
IRR17 applies to organisations operating security X-ray equipment that generates ionising radiation.
This can include:
- Mail screening scanners
- Parcel screening scanners
- Baggage screening scanners
- Visitor screening systems
The exact requirements will depend on the type of equipment being used and the findings of the organisation’s radiation risk assessment.
In many cases, employers operating security X-ray equipment will need to register with the Health and Safety Executive (HSE) before commencing work involving ionising radiation.
The registration process is designed to ensure organisations have considered their responsibilities under IRR17 and have appropriate safety arrangements in place.
As requirements can vary depending on the equipment and its intended use, organisations should seek advice from their Radiation Protection Adviser (RPA).
A Radiation Protection Adviser (RPA) is a suitably qualified radiation safety specialist who provides expert advice on compliance with IRR17.
An RPA may advise on:
- Radiation risk assessments
- Local Rules
- Radiation surveys
- Staff training requirements
- Equipment installations
- Ongoing compliance arrangements
Most organisations operating security X-ray equipment will use an independent external consultant to fulfil the role of RPA.
A Radiation Protection Supervisor (RPS) is appointed by the employer to help supervise day-to-day radiation safety arrangements.
The RPS is typically an employee who understands the organisation’s procedures and helps ensure that operators follow Local Rules and safe working practices.
In many organisations, the RPS may be a Facilities Manager, Security Manager, Mailroom Manager or Health and Safety Manager.
The simplest way to understand the difference is:
- The RPA advises.
- The RPS supervises.
The Radiation Protection Adviser provides specialist guidance on compliance, radiation safety and legal requirements.
The Radiation Protection Supervisor helps ensure that safe working procedures and Local Rules are followed within the organisation on a day-to-day basis.
Both roles are important, but responsibility for compliance remains with the employer.
The employer operating the security X-ray equipment is legally responsible for complying with IRR17.
Whilst the RPA provides advice and the RPS helps supervise safe working practices, neither role transfers legal responsibility away from the organisation.
Employers are responsible for ensuring that:
- Radiation risks are assessed
- Appropriate training is provided
- Equipment is maintained correctly
- Local Rules are implemented where required
- Staff follow safe working procedures
Local Rules are written procedures that explain how radiation-related work should be carried out safely within an organisation.
Depending on the application, Local Rules may include:
- Operator responsibilities
- Safe operating procedures
- Emergency arrangements
- Access controls
- Contact details for radiation safety personnel
Local Rules help ensure consistency and provide clear guidance for employees working with security X-ray equipment.
Modern security X-ray scanners are designed with multiple safety features to minimise radiation exposure.
These may include:
- Shielded cabinets or tunnels
- Lead-lined protective curtains
- Safety interlocks
- Radiation monitoring during testing and installation
When equipment is correctly installed, maintained and operated in accordance with the manufacturer’s instructions and IRR17 requirements, operator exposure is typically extremely low.
Security X-ray scanners generally fall into two categories.
Cabinet X-ray scanners are fully enclosed systems where the inspection chamber is contained within a shielded cabinet. Examples include mail screening scanners such as the MR10, MR15 and MR40.
Conveyor X-ray scanners use an open-ended tunnel design that allows mail, parcels, baggage or other items to pass through the machine for continuous screening.
Both types of equipment are designed to operate safely, but the installation requirements, radiation surveys and risk assessments may differ depending on the design of the system.
Further Information
This article provides a practical overview of IRR17 and its relevance to security X-ray equipment.
For the official regulations and guidance, visit:
Ionising Radiations Regulations 2017 (IRR17)
Health and Safety Executive (HSE) guidance on ionising radiation legislation
If your organisation is considering the purchase of a security X-ray scanner and would like guidance on site surveys, Postal Threat Assessments, operator training or the practical requirements associated with IRR17, the team at My Group Security will be happy to help.
