Radiation Protection Officer

The Radiation Protection Officer (Strahlenschutzbeauftragter, SSB) is the qualified person designated under § 70 of the German Radiation Protection Act (StrlSchG) who is responsible for compliance with radiation protection law within a defined scope of decision-making. The SSB supports the Radiation Protection Supervisor (Strahlenschutzverantwortlicher, SSV) under § 69 StrlSchG, who carries personal management responsibility and is named in every licensing or notification procedure. The StrlSchG replaced the former Röntgenverordnung (RoeV) and the old Radiation Protection Ordinance in 2018, consolidating them into a single regime fleshed out by the Strahlenschutzverordnung 2018 (StrlSchV). Together they transpose the EU Basic Safety Standards Directive 2013/59/Euratom into German law.

The task scope flows from §§ 71 to 74 StrlSchG and is specified in §§ 47, 73, 121 StrlSchV. The SSB monitors compliance with the dose limits under § 78 StrlSchG (20 millisievert per year for occupationally exposed persons, 1 millisievert for the general public, 20 mSv eye lens, 500 mSv skin and extremities), drafts the radiation protection instruction (Strahlenschutzanweisung) under § 45 StrlSchV, ensures correct demarcation of radiation areas (supervision, control and exclusion zones) and organises personal dosimetry through an accredited measurement body. The SSB also maintains the radiation passport (Strahlenpass) under § 41 StrlSchV and classifies workers in categories A (above 6 mSv per year possible) and B (1 to 6 mSv) under § 71 StrlSchV.

In practice the SSB is the interface to the competent state authority (Landesamt or Bezirksregierung). The SSB notifies operation of an X-ray facility under § 19 StrlSchG, applies for handling licences for radioactive substances under § 12 StrlSchG and reports occupational doses annually to the radiation protection register at the Federal Office for Radiation Protection (BfS). Where individual exposure exceeds 6 millisievert per year, occupational health surveillance by an authorised physician under § 79 StrlSchG becomes mandatory, with health records retained until the worker reaches 75 years of age or for at least 30 years. Constancy testing under §§ 88, 89 StrlSchV follows DIN 6868 and DIN 6855 standards with modality-specific intervals.

Appointment of the radiation protection officer is mandatory under § 70 Para. 1 StrlSchG for any activity subject to licensing or notification under §§ 12, 19 StrlSchG, unless management exercises the function personally. Appointment is in writing, defines the scope of decision-making, the territorial and temporal coverage and the powers granted, and must be notified to the competent state authority without delay. Multiple SSBs for distinct scopes are permitted and common practice in larger clinics. The works council must be consulted before appointment under § 87 BetrVG where applicable.

Radiation protection expertise (Fachkunde) is governed by § 47 StrlSchV and the Federal Ministry guideline on Fachkunde im Strahlenschutz from 18.06.2004 (last updated 2019). It is divided by application area into expertise groups R1 to R6 for diagnostic and therapeutic X-ray applications (R1 emergency diagnostics, R2 conventional diagnostics, R3 CT, R4 interventional radiology, R5 radiotherapy, R6 nuclear medicine) and S1 to S5 for handling of other radioactive substances and accelerators. Acquiring Fachkunde requires suitable basic training (typically medical licence, engineering degree or radiology assistant), supervised practical experience between 3 and 24 months depending on group, and an accredited Fachkunde course between 8 and 90 teaching units. Course providers include TUEV, DGMP and accredited academic institutes. Under § 47 Para. 3 StrlSchV, Fachkunde must be refreshed at least every 5 years through a recognised refresher course, otherwise it lapses automatically and the SSB ceases to be eligible. Documentation of all qualifications and refreshers must be retained for the duration of the appointment plus five years.