Legality of hobby radiography

James, Tue Apr 12 2011, 07:41PM

I know there are a number of people out there doing hobby radiography, some openly posting their results and others quietly alluding to it. I believe that it's illegal in most parts of the world to do this, and for generally good reasons as it's one of those things that really can cause unseen harm to others if done carelessly. What I'm not sure is where this sort of thing falls. Is it in the category of making drugs or bombs where the authorities are actively trying to stamp it out, or is it the sort of thing where so long as you don't cause any trouble nobody will bother you? Maybe somewhere in between? Is it possible for an ordinary person to do it without breaking the law? I'm lucky to know a veterinary technician in a small clinic so I have occasional access to the real deal, but that's not as intriguing as DIY.
Re: Legality of hobby radiography
uzzors2k, Tue Apr 12 2011, 09:08PM

As long as you don't use an x-ray machine recklessly and wind up hurting yourself, or worse yet other people, who's ever going to complain?

Like all great things that become illegal, it's no problem until idiots start doing it. I imagine it would take several kids giving themselves necrosis before it became a problem to construct an x-ray machine. But at the rate people are jumping on x-ray experiments, that may only be a few years in the future for all I know. I'm less worried about legality than I am about newbies getting themselves hurt. That would be a major blow to this hobby.
Re: Legality of hobby radiography
James, Tue Apr 12 2011, 11:05PM

Who knows, but there's always the chance of being the one guy who somebody decides to make an example of. The way people freak out when they hear "radiation" one may not have to cause any actual harm for someone to throw a fit over it if word gets out. If a neighbor happens to develop cancer I'm not sure how one would ever prove that x ray experiments didn't cause it even if the actual chance is very remote.

You'd need quite a lot of exposure with the sort of equipment a typical hobbyist is likely to acquire to see any immediate injury, but cancer, birth defects and other long term effects can show up years or decades later from much lower doses. I cringe whenever I hear of someone playing with this stuff without at least having a good dosimeter.
Re: Legality of hobby radiography
Ash Small, Wed Apr 13 2011, 01:04PM

The rules in UK state that any device designed to produce ionizing radiation requires a license.

The fusor brigade get around this by saying that the neutrons and x-rays produced are a by-product of the fusion process, and a fusor is not designed for the purpose of producing them.
Re: Legality of hobby radiography
Proud Mary, Wed Apr 13 2011, 03:01PM

Ash Small wrote ...

The rules in UK state that any device designed to produce ionizing radiation requires a license.

Where exactly in the UK Ionising Radiation Regulations 1999 is this "rule" "stated" with respect to X-ray equipment not used in the course of employment?

You can read IRR 1999 paragraph by paragraph, and clause by clause, here: Link2

The Health and Safety Executive's interpretation of IRR 1999 limits their prior permission role to "The use of electrical equipment intended to produce X-rays ("X-ray sets") for: industrial radiography; processing of products; research; or exposure of persons for medical treatment."

see HSE: Prior authorisation for the use of electrical equipment intended to produce X-rays here: Link2

Wouldn't it be sensible to check your facts before being a big Silly Billy and passing on ill-informed gossip implying that some UK members of this forum are criminals?
Re: Legality of hobby radiography
Ash Small, Wed Apr 13 2011, 04:27PM

I (and others) had interpreted this to mean 'any practice' that involves 'The use of electrical equipment intended to produce X-rays', including research.

If you are arguing that hobbyists are not involved in 'research', this sounds a bit dubious (to me) and possibly requires clarification.

EDIT: While I'm sure that the majority of UK radiography hobbyists have no criminal intent, the CPS 'may' consider otherwise. (for example, they 'may' consider hobbyists to be 'self employed'.)

Re: Legality of hobby radiography
plazmatron, Wed Apr 13 2011, 05:38PM

James wrote ...

I believe that it's illegal in most parts of the world to do this........

No it is not. People think it is, but it isn't. Anyone may purchase or own x-ray generating equipment so long as it is compliant. Examples are baggage of letter scanners, and the Tel Atomic Tel-x-ometer.

The IRR clearly states, that ANY vacuum tube operated above 5kV, falls under their regulations. This includes transmitting tubes, some Magnetrons, and CRT's.
Yes, this means your CRT TV or monitor is considered an x-ray generator, and it too must also be compliant.

The legal issue arises, if through will or negligence, you were to expose any living thing to x-rays, at levels greater than the maximum Dose rates specified.
For hobbyists, read: Do not to expose any living thing under any circumstances, including yourself.

James wrote ...

..........and for generally good reasons as it's one of those things that really can cause unseen harm to others if done carelessly.

As can high levels or RF..... Telsa coils, Magnetrons, transmitting equipment, Lasers, etc, all of these things are in fact regulated.



Ash Small wrote ...

The rules in UK state that any device designed to produce ionizing radiation requires a license.

No, they do not. As Stella says the equipment must be compliant with the guidelines set out in the IRR.

For the hobbyist it goes like this:

Running a bare x-ray tube with any persons present, would land you in a lot of trouble. In fact you would be most assuredly jumped on by the powers that be.

Running an unmodified Dental x-ray machine or similar (ie mostly shielded, but with an accessible beam), may cause concern, but so long as you can prove competence you will probably be OK. But personally I would not recommend this.

Running a fully enclosed and interlocked (ie fully compliant, and fully shielded, with an inaccessible beam) x-ray machine is where you ought to be at. So if you own a Tel-x-ometer, or an enclosed x-ray diffraction setup, or a Baggage/parcel scanner, and are competent in its use you are OK.

As for home builds, well, my advice is you make it compliant. Very compliant.

So at least the following:

The tube should be housed in lockable a metal cabinet (2mm of steel, and fully lined with at least 3mm of lead (for up to 50kV )).

To door of the cabinet must have at least one interlock switch, two is preferable. They should cut off the beam in the event of the door opening, and should not allow an immediate restart if the door is re closed.

The equipment must display the international ionising radiation warning sign.

The cabinet should have provided between it and the operator, an interlocked barrier or door, so it cannot be approached without interrupting the beam.

The power supply must display a warning light when switched on, and must display a second warning light when the beam is on. The supply must also incorporate a trapped key switch (ie the key cannot be removed in the "on" position).

This is how compliant my setup is.

Ash Small wrote ...

The fusor brigade get around this by saying that the neutrons and x-rays produced are a by-product of the fusion process, and a fusor is not designed for the purpose of producing them.

Saying your equipment is not designed to produce x-rays is not a get out. The IRR clearly states that any vacuum tube operating in excess of 5kV is considered an x-ray generator. Fusors generate a significant x-ray flux, and Neutron production has its own little chapter as far as ionising radiation goes.

The Fusor brigade 'get round' nothing, they are as liable as anyone running an x-ray machine, if not more so (the human body makes an excellent Neutron moderator). If the government comes knocking, you must be able to prove that reasonable precautions have been taken, and prove operator competence.

Sound like the voice of experience? It is.


Ash Small wrote ...

While I'm sure that the majority of UK radiography hobbyists have no criminal intent, the CPS 'may' consider otherwise. (for example, they 'may' consider hobbyists to be 'self employed'.)

Yes, they will absolutely consider you to be "self employed" if it suits, but you must also have committed an offence for them to prosecute you. So as I said, if you exposed someone by will or negligence, you would be likely up sh*t creek.



Yes x-rays are dangerous, as is any other facet of high voltage, or high energy electronics. For example, Tesla coils have in fact to my knowledge, killed three people in recent times.
Special steps should always be taken to ensure safety, with all aspects of this hobby but there is no reason why it cannot be enjoyed, and remain legal as long as people are sensible.

Les


Re: Legality of hobby radiography
Proud Mary, Wed Apr 13 2011, 06:25PM

I agree with everything Plazmatron has said.

I will add only that some - but not all - of the more onerous HSE ionising radiation regulations are relaxed "at or below 50 kV."

And the good news? HSE regulation only starts at 5 keV, as Les has implied, so now's the time to spring clean all those beryllium windows! cheesey


Re: Legality of hobby radiography
Ash Small, Wed Apr 13 2011, 07:13PM

While I accept that the points that I repeated here that were originally made by members of the UK fusor community may well be erroneous (there is quite a lot of nonsense posted on fusor.net, as regular readers of that forum will be aware) I would like to reiterate that there is nothing to stop the CPS from deciding that a 'radiography hobbyist' 'self employed' and involved in 'research', for which prior authorisation (a license) is required.

How would one go about proving that this was not the case with a 'homebrew' device? (I appreciate that commercially produced letter scanners, etc wouldn't fall into this category)

(Or any vacuum system containing electrodes opersting at more than 5kV, ie ion beam, plasma processing, etc)

There is obviously a 'grey area' here.
Re: Legality of hobby radiography
Proud Mary, Wed Apr 13 2011, 08:04PM

Ash Small wrote ...

I would like to reiterate that there is nothing to stop the CPS from deciding that a 'radiography hobbyist' 'self employed' and involved in 'research', for which prior authorisation (a license) is required.

A case would not originate with CPS but with HSE. You seem to be implying malicious prosecution, which seems to me far fetched.

Ash Small wrote ...

How would one go about proving that this was not the case with a 'homebrew' device?

The manufacturer of the device is irrelevant. What counts is whether, and to what extent, the device and all associated safety equipment including shielding and fail-safe PSU devices comply with IRR 1999 and current HSE guidelines. Having said as much, I should heed Plazmatron's warning that the owner of a 'homebew'
X-ray machine should make themselves doubly sure of its compliance - if it looks like an assemblage of old junk thrown together like a dog's breakfast, its chances may be less than average.

Ash Small wrote ...

There is obviously a 'grey area' here.
There is nothing mysterious about this. At heart, it is no different to an MOT certificate for a motor vehicle, a box-ticking exercise, except that the HSE Radiation Safety Officer may make recomendations on safety improvements, which, if not acted upon, could lead to further action including seizure of the offending apparatus, and prosecution in the last resort. But the HSE accent is very much on helping people keep going in a safer way, rather than looking for flimsy pretexts to take punitive action.

Re: Legality of hobby radiography
Bored Chemist, Wed Apr 13 2011, 08:47PM

HSE is the enforcing authority for the health and safety at work etc act.
If you are not at work, they don't care what you do.
I'm not sure how they view students. (probably with contempt- like the rest of us)
Re: Legality of hobby radiography
Ash Small, Wed Apr 13 2011, 09:02PM

I don't wish to 'imply' anything, PM.

Thanks for clearing up the point about HSE and CPS.

While I have no plans at present to construct a radiography device, I am currently involved in constructing a vacuum system which will incorporate electrostatics, etc. (and will produce some x-rays)

I obviously wish to avoid having my equipment confiscated, or worse, being prosecuted.

The reason I've taken so long to 'fire it up' is because I wish to take ALL the safety precautions I can.

(I'm sure you've read my posts regarding RF generators and magnetrons)

It's reassuring to know that unless I 'nuke' the neighbour's cat (or worse) I won't get prosecuted, as long as I take 'reasonable precautions'.

(incidentally, While 'the powers that be' over at fusor.net have effectively banned discussion of tritium as a fuel in fusors due to the fact that possesion of tritium is controlled in the US, there apparently appears to be nothing to stop those of us who live in the 'free world' from running a fusor on D-T and producing neutrons of 14 MeV)
Re: Legality of hobby radiography
Ash Small, Wed Apr 13 2011, 09:06PM

Bored Chemist wrote ...

HSE is the enforcing authority for the health and safety at work etc act.
If you are not at work, they don't care what you do.
I'm not sure how they view students. (probably with contempt- like the rest of us)


Maybe it's time to 'wind up' the company I set up so I could buy chemicals more easily? (and avoid paying tax on the money I spend on my hobby, but don't tell the taxman smile )
Re: Legality of hobby radiography
Proud Mary, Wed Apr 13 2011, 10:32PM

Ash Small wrote ...

While 'the powers that be' over at fusor.net have effectively banned discussion of tritium as a fuel in fusors due to the fact that possesion of tritium is controlled in the US, there apparently appears to be nothing to stop those of us who live in the 'free world' from running a fusor on D-T and producing neutrons of 14 MeV)

I can't comment on a forum of which I am not a member. I think it possible, however, that what you are describing might constitute a 'radioactive apparatus' within the meaning of the Radioactive Substances Act 1993. Moreover, this use of tritium would not seem to be covered by the Radioactive Substances (Gaseous Tritium Light Devices) Exemption Order 1985, but you should seek clarification from the Radiation Protection Division of the Health Protection Agency - the old NRPB.

Familiarity with The Justification of Practices Involving Ionising Radiation Regulations 2004 (SI 2004 No 1769) Guidance on their application and administration - Version May 2008 would stand you in better stead on current EU law than internet tittle tattle and unsourced opinion.
Re: Legality of hobby radiography
Steve Conner, Thu Apr 14 2011, 10:32AM

plazmatron wrote ...

Sound like the voice of experience? It is.

Does this have anything to do with the disappearance of the hobby X-ray info from your site? :-/
Re: Legality of hobby radiography
plazmatron, Thu Apr 14 2011, 12:27PM

Bored Chemist wrote ...

HSE is the enforcing authority for the health and safety at work etc act.
If you are not at work, they don't care what you do.
I'm not sure how they view students. (probably with contempt- like the rest of us)

They will make an exception where ionising radiation is concerned.


Steve McConner wrote ...

plazmatron wrote ...

Sound like the voice of experience? It is.
Does this have anything to do with the disappearance of the hobby X-ray info from your site? :-/

Well spotted, indeed it does. It was suggested, that having "how-to's" on there was not in my best interests.
So in the interests of staying on the right footing I removed them. Likewise, the "about me" page was re written, since "they" didn't want the inexperienced copying it.

Some bits will make it back. Obviously details of detectors is perfectly OK, as are Scientific/Technical papers etc. But anything that implies unsafe practices should be avoided.

Ultimately, its not really a bad thing, a little professionalism is needed in this particular area, and my site will benefit from being a little less amateurish.


Les

Re: Legality of hobby radiography
Steve Conner, Thu Apr 14 2011, 02:28PM

OK, so if you don't mind sharing, who were "they", the HSE? And how did they get onto you?

I think technically speaking, your use of X-rays would be classed as work, since you sell prints (very nice ones at that smile )
Re: Legality of hobby radiography
plazmatron, Thu Apr 14 2011, 05:33PM

Steve McConner wrote ...

OK, so if you don't mind sharing, who were "they", the HSE? And how did they get onto you?

I think technically speaking, your use of X-rays would be classed as work, since you sell prints (very nice ones at that smile )

They were indeed the HSE. Seemingly someone reported my activities to the local council, who informed them. Not that I have ever been secretive about what I do. In fact a couple of years back, my "happy" neighbour threatened to go to the Police about my activities (that she claimed were illegal), so on the advice of Proud Mary, I took a list of equipment and chemicals along to the Police, The local Pharmacist and my GP.

It would seem that openness is the way to go with these things.

Thanks for your compliment! I do sell prints, but not really often. The HSE accepted that what I do is a hobby, but stated they made an exception as it involves the use of ionising radiation.

The HSE's position on the whole thing is that they do not encourage people to build or use x-ray machines at home. Nor is that fact that mine passed their inspection, any kind of permission for anyone (including me) to do as they please.
They were quite clear that in this case there was no concern with my current activities. Which is to my mind a carefully worded way of saying "if you build another one in the future, it had better be as compliant too",but at the same time they are saying "we are not encouraging you to build one either".


As I alluded in my previous post, the whole thing is self contained, and is compliant above and beyond the recommendations set out in the IRR, and I can assure everyone here, that if it had not been, the HSE could and would, have had it removed, and probably at my cost.

It should be noted, that should you fall foul of any criminal injury proceedings (ie you irradiated a person or animal), the HSE will not defend you, even if they had inspected your setup. Like a vehicle MOT they are saying "on the day we inspected it...."

Their recommendations were to remove the references on my site to any x-ray activity that could be construed as careless or reckless (for example mentioning the fact I radiographed my fingers when I was a kid!).
For now, I have taken down the entire section. As I said, some bits will re-appear after they have been extensively rewritten, however there will be, no "instructions" or ""how to's" on this particular subject, which really, thinking about it, is very wise anyway.



So my stance on the matter has pretty much ended up like theirs. I can not condone anyone building one, nor will I give any instructions on how to do it. However, at the risk of being a nag, you can expect me to point out safety issues, and mistakes, as far as this forum goes.


It is one of those hobbies, that must be done by the book if we expect to continue doing it, but even that is no guarantee. The mere mention of the word "Radiation" is enough to instill fear in most people, and the subject will always be a political hot potato.


Les
Re: Legality of hobby radiography
Proud Mary, Thu Apr 14 2011, 05:56PM

I think the HSE ambiguity and ambivalence Les has described has come about because the possibility of amateur or extra-institutional x-ray use simply didn't occur to radiation policy makers when legislation was drafted.

Good can come of this if it raises standards, and encourages more people to look at the world below 5 keV, where all sorts of challenges and opportunities are sure to await us. smile
Re: Legality of hobby radiography
James, Thu Apr 14 2011, 07:22PM

That's all good info. Anyone have any knowledge of the USA regulations on the subject?

What worries me most is the way people freak out irrationally at the mere mention of "radiation". On the other hand, dental and veterinary x-ray equipment is used all the time in densely populated areas with minimal shielding beyond the machine itself.
Re: Legality of hobby radiography
plazmatron, Thu Apr 14 2011, 08:43PM

James wrote ...

That's all good info. Anyone have any knowledge of the USA regulations on the subject?

That would be the FDA. The link for x-ray apparatus is here: Link2

Ha! look, at the top of the list is TV receivers!

James wrote ...

What worries me most is the way people freak out irrationally at the mere mention of "radiation". On the other hand, dental and veterinary x-ray equipment is used all the time in densely populated areas with minimal shielding beyond the machine itself.

This is very true, I have seen Dental surgeries in the middle of terraced houses in this country too. Fortunately there is plenty of stonework between them.

The FDA's page on cabinet x-ray systems (which I would really recommend, should anyone wish to persue this hobby) is here: Link2

Note that it too doesn't seem to outlaw the construction of such equipment, but it does state in no uncertain terms, that it must be compliant with the standards set out in the Federal regulations (Radiological heath), and as recent events have illustrated, even though we are not manufacturers, compliance can only be a good thing.


Les