RPA 2000 Guidance Document No

RPA 2000

THE Competence Certification Schemes

GUIDANCE DOCUMENTS - Document GD2

Consequences of the failure of applicants to meet timescales for

the renewal of certification

Delays in the assessment process are all too often caused by certificate holders who submit late renewal applications. The Board has decided that more specific guidance is required to spell out the potentially serious consequences of applicants failing to observe the RPA 2000 Operating Procedures. Four actual situations have been identified and these are described below, together with the consequences that will be enforced in the future. Where an actual situation varies somewhat from those identified, the Assessment Secretary will use similar principles in reaching his decision.

A. Summary

Put in the simplest terms, applicants must be personally responsible for their own actions which, in the present context, mean the timely submission of their application for the renewal of their certification.

About six months prior to expiry of a current certificate, RPA 2000 will normally provide a reminder of the need to prepare a renewal application and to submit this to RPA 2000 not later than 3 months before that expiry date. No further reminder will be provided and, if the application is not received, the current certificate holder will simply be contacted when the certificate has expired and informed that, legally, he/she is no longer able to undertake RPA duties within meaning of IRR99.

Clearly extenuating circumstances may need to be taken into consideration, for example medical conditions, and the Assessment Secretary is given the discretion to make due allowances where appropriate. However, an all too frequent reason given is a simple failure to ‘get round to the job’ and it is respectfully pointed out to potential applicants that they need to give priority to their RPA certification because their job may depend on it. Indeed, it has been suggested that a person’s ability to act as an RPA might be questioned if that person cannot even adequately schedule his/her own RPA renewal application. So, please, do not test the Assessment Secretary’s patience by citing poor personal organisational ability as an extenuating circumstance – you are likely to be disappointed by his decision.

B. Guidance - the four identified situations and their consequences

1.  An application for renewal is received by RPA 2000 less than 3 months before the date of expiry of the current certificate, without any explanation for the late application.

Actions and consequences:

Every effort will be made to complete the assessment before the expiry date. If this cannot be achieved, for whatever reason, the current certificate will not be extended and the potential applicant will be informed that, legally, he/she is no longer to able to undertake RPA duties. If granted, the renewed RPA certificate will become valid from the date of notification by the Administration Secretary.

2.  An application for renewal is received by RPA 2000 less than 3 months before, but within 1 month of, the date of expiry of the current certificate and is accompanied by an explanation of extenuating circumstances that have delayed the application.

Actions and consequences:

Every effort will be made to complete the assessment before the expiry date. If this cannot be achieved then, at the discretion of the Assessment Secretary, the validity of the current certificate may be extended to allow the renewal assessment to be completed.

3.  No application for renewal or any communication regarding renewal is received by RPA 2000 during the period of validity of the current certificate.

Actions and consequences:

The current certificate will not be extended and the applicant will have already been informed that, legally, he/she is no longer to able to undertake RPA duties.

The current RPA certificate can still be renewed provided that a suitable RCS renewal application (and fee) is received not later than 6 months after expiry of the previous certificate. No explanation is required for the late application. If granted, the renewed RPA certificate will become valid from the date of notification by the Administration Secretary.

Once 6 months have elapsed from the date of expiry of the current certificate, the only route to further RPA certification is by means of a full portfolio as for an initial application.

4.  No application for renewal or any communication regarding renewal is received by RPA 2000 during the period of validity of the current certificate, but within 6 months after expiry of the previous certificate, the applicant provides details of extenuating circumstances for not having been able to contact RPA 2000 sooner.

Actions and consequences:

The current certificate will not be extended and the applicant will have already been told that, legally, he/she is no longer to able to undertake RPA duties.

At the discretion of the Assessment Secretary, the RPA certificate can still be renewed provided that a suitable RCS renewal application is received not later than 12 months after expiry of the previous certificate. If granted, the renewed RPA certificate will become valid from the date of notification by the Administration Secretary.

Once 12 months have elapsed from the date of expiry of the current certificate, the only route to further RPA certification is by means of a full portfolio as for an initial application.

For completeness the relevant section from the RPA 2000 Operating Procedures is reproduced in the Appendix to this document.

A P Hudson

Secretary to RPA 2000

11 January 2011.

APPENDIX to RPA 2000 GUIDANCE DOCUMENT GD2

Extract from RPA 2000 Operating Procedures (Document G1)

5.11 Applications for renewal of certification

NOTE that further guidance on this topic and on the consequences of the failure of applicants to meet timescales for the renewal of certification can be found in RPA 2000 Guidance Document No.2.

5.11.1. Applicants are clearly responsible for the timing of their renewal applications, but to assist them, the Administration Secretary will:

–  aim to notify Certificate holders about six months before the date of expiry of Certificates and advise them to visit the RPA 2000 Website for the latest information on renewal of certification;

–  notify Certificate holders of the expiry of certification soon after the expiry date.

5.11.2. Provided that an application is received no more than six months nor less than three months before the date of expiry of the current Certificate, the renewed Certificate will be dated so as to be contiguous with the expiring Certificate.

5.11.3. Where an application is received more than six months prior to the date of expiry of the current Certificate, the renewed Certificate will commence at the date on which it is signed.

5.11.4. In both of the above cases, the Administration Secretary, in consultation with the Assessment Secretary, can extend the validity of the current Certificate by up to six months in extenuating circumstances.

5.11.5. Applications for renewal of certification received less than three months prior to expiry of the Certificate cannot normally have their validity extended, although it may be possible to take special circumstances into account. In the case of late applications, RPA 2000 will endeavour to complete the Assessment prior to the expiry date, but without any guarantee.

5.11.6. In the event of there being a gap between the expiry date and the date of application for renewal, the Assessment Secretary will reach a judgment on whether the Applicant can be accepted for renewal of certification, or whether the Applicant needs to apply for a fresh Certificate. This judgment will be based on factors such as the duration of the gap and the nature of the radiation protection work being done prior to the gap.