“Do we really need to do all this? We wear the UV specs when we’re in our booth.”
It was a comment that really stood out during our time at the BiNDT Materials Testing 2026 Show.
We were there to talk about UV safety in the workplace, with a particular focus on the use of artificial UV radiation in non-destructive testing (NDT).
And it was a useful reminder of an assumption that exists not just within NDT, but across a range of industries that use artificial UV sources:
If our employees are wearing UV protective eyewear, aren’t we already controlling the risk?
The short answer is: not necessarily.
UV protective eyewear can be an important part of a safe system of work, but putting on a pair of UV safety glasses does not automatically mean that a workplace is compliant with the requirements for controlling artificial optical radiation.
UV is widely used in NDT
Artificial UV is an established part of many NDT processes, particularly fluorescent penetrant inspection and other inspection techniques where UV-A lamps are used to make indications visible.
The challenge is that the level of exposure can vary considerably between workplaces and even between individual working positions.
Factors can include:
- The type and wavelength of UV source being used
- The optical output of the equipment
- The distance between the worker and the source
- The direction of the UV emission, including reflected UV radiation
- The duration and frequency of exposure
- The position of the operator in relation to the inspection area
- Whether other workers can be exposed
- The design of the booth or inspection area
- The use of shielding, screens or other engineering controls
- The effectiveness and suitability of personal protective equipment
This can make it difficult for organisations to simply assume that because a particular process has been used for years, the workplace must therefore be safe and compliant.
What does the law actually require?
In Great Britain, artificial optical radiation is covered by the Control of Artificial Optical Radiation at Work Regulations 2010 (AOR Regulations).
The regulations are intended to protect workers from the health risks associated with hazardous sources of artificial optical radiation. HSE specifically identifies ultraviolet radiation as one of the forms of optical radiation covered by this framework.
The UK regulations implement the requirements of European Directive 2006/25/EC, which established minimum health and safety requirements for workers exposed to risks arising from artificial optical radiation.
Importantly, this isn’t simply about whether someone owns a pair of protective glasses.
The regulations require employers, where there is a reasonably foreseeable risk of adverse health effects from artificial optical radiation, to carry out a suitable and sufficient assessment of that risk.
That assessment must consider, among other things:
- The level, wavelength and duration of exposure
- Applicable exposure limit values
- Employees who may be particularly at risk
- Photosensitising substances
- Indirect effects
- Alternative equipment that could reduce exposure
- Multiple sources of exposure
- Information supplied by equipment manufacturers
Where necessary, exposure must also be measured or calculated.
That’s an important point.
The question isn’t simply “Are our employees wearing UV glasses?”
The question is:
“Have we identified the potential exposure, assessed the risk and implemented appropriate controls to ensure workers are adequately protected?”
The exposure limits matter
The European Directive establishes exposure limit values for artificial optical radiation.
For non-coherent UV radiation, the relevant limits take account of the wavelength and the biological effect of the radiation. For example, the Directive identifies an effective exposure limit for radiation between 180 and 400 nm, covering UV-A, UV-B and UV-C, as well as a separate UV-A exposure value for 315–400 nm.
This is why simply knowing that a lamp is described as a “UV-A lamp” isn’t necessarily enough to determine the risk.
The amount of radiation reaching the worker, the wavelength and the duration of exposure all matter.
A source that is perfectly manageable in one application may present a different exposure scenario when used closer to the operator, for longer periods, or in a different workstation configuration.
So where do UV safety glasses fit in?
They absolutely have a role.
The AOR Regulations specifically require workers to receive information and training covering the proper use of personal protective equipment where appropriate.
But PPE should form part of an overall control strategy rather than being treated as the complete solution.
The regulations identify a range of measures that may be relevant, including:
- Different working methods
- Selection of equipment that emits less optical radiation
- Technical measures to reduce emissions
- Interlocks and shielding
- Suitable maintenance programmes
- Workplace and workstation design
- Limiting the duration and level of exposure
- Personal protective equipment
In other words, engineering and organisational controls can be just as important as PPE.
A pair of UV safety glasses may reduce exposure to the eyes, but it doesn’t necessarily control exposure to the skin.
It doesn’t automatically address UV escaping from a booth.
It doesn’t control exposure to another employee standing nearby.
It doesn’t demonstrate that the exposure limit has been considered.
And it doesn’t tell you whether the eyewear itself is suitable for the specific source and exposure conditions.
“But we’ve always done it this way…”
This is one of the challenges we encounter when talking about UV safety.
A process may have been used for years without an obvious incident.
Workers may have been wearing the same PPE for years.
The equipment may have been supplied by a reputable manufacturer.
And everyone may genuinely believe the process is safe.
None of those things, individually, establishes that the workplace has adequately assessed exposure to artificial UV radiation.
HSE’s guidance makes clear that employers using hazardous artificial optical radiation sources need to ensure the associated risks have been reduced as low as reasonably practicable.
The absence of an incident isn’t necessarily evidence that the exposure assessment is adequate.
Sometimes it simply means that nobody has looked closely enough yet.
The NDT booth isn’t necessarily the whole story
The conversation at the show centred around an operator working inside a booth and wearing UV protective eyewear.
But a UV risk assessment needs to consider the actual exposure scenario, not just the person standing directly in front of the inspection area.
For example, what happens when:
- Someone enters the booth while the UV source is operating?
- Another employee works immediately outside the inspection area?
- A supervisor enters to inspect the work?
- The operator changes position?
- The source is moved closer to the workpiece?
- A different UV lamp is installed?
- The booth configuration changes?
- A reflective component changes the direction of radiation?
- Employees spend significantly longer in the area than originally anticipated?
These are exactly the sorts of questions that can turn a seemingly straightforward UV assessment into a more detailed exposure assessment.
What happens if exposure limits could be exceeded?
The regulations are clear that workers should not be exposed above the applicable exposure limit values.
Where a risk assessment indicates that exposure could exceed those limits, appropriate technical and organisational measures need to be implemented.
Work areas where exposure could exceed the limits may also need to be identified, access restricted where reasonably practicable, and appropriate signs provided.
And if exposure limits are exceeded despite the measures already in place, the employer must take immediate action to reduce exposure below the relevant limits and identify why the exceedance occurred so that measures can be adapted to prevent it happening again.
That’s very different from simply saying:
“Everyone wears UV glasses, so we’re covered.”
What should an NDT organisation be asking?
If your organisation uses artificial UV as part of an NDT process, it is worth asking some fairly straightforward questions:
- Do we know exactly what UV sources we are using?
- Do we know their wavelength and output characteristics?
- Have we assessed the exposure at the actual working positions?
- Have we considered both eye and skin exposure?
- Have we considered the duration and frequency of exposure?
- Have we considered people other than the primary operator?
- Do our engineering controls and shielding adequately restrict exposure?
- Is our PPE appropriate for the specific source and task?
- Can we demonstrate how our exposure compares with the applicable exposure limit values?
- Has the assessment been reviewed following changes to equipment, processes or working arrangements?
If the answer to several of those questions is “I’m not sure”, it may be worth taking another look.
UV safety isn’t about creating unnecessary paperwork
This isn’t about making a straightforward process unnecessarily complicated.
HSE itself recognises that many businesses are already effectively managing artificial optical radiation risks and that further work is primarily expected where hazardous sources are being used and the risks have not already been reduced as far as reasonably practicable.
The objective is much simpler:
- Understand the hazard.
- Understand the exposure.
- Control the risk.
- Protect the worker.
- Be able to demonstrate why the controls are adequate.
Sometimes that assessment may show that the existing arrangements are perfectly adequate.
That’s a good outcome.
But if there is a gap, finding it gives an organisation the opportunity to address it before it becomes an incident, an employee concern or a regulatory issue.
Back to that conversation at the show…
The person who asked, “Do we really need to do all this? We wear the UV specs when we’re in our booth,” wasn’t being unreasonable.
It is a perfectly understandable question.
And perhaps, after reviewing the process, his organisation will find that it already has excellent controls in place.
But perhaps the exercise will identify something that could be improved.
Either outcome is useful.
That’s exactly why we suggested he join one of our free UV safety webinars.
The aim isn’t to create unnecessary concern. It’s to help organisations understand what the legislation requires, how exposure limits apply, and what good UV risk management looks like in practice.
Want to know whether your UV process is adequately controlled?
We’ve put together a free UV Safety in the Workplace webinar covering the legal requirements for operating artificial UV sources, statutory exposure limits, the risks associated with UV exposure and practical examples from industry.
The session is particularly useful for organisations that already use UV equipment, as well as those considering introducing new UV processes.
If you’re responsible for health and safety, NDT, engineering, quality or UV equipment within your organisation, it’s worth taking 45 minutes to find out whether there are any gaps in your current approach.
Register for the free UV Safety in the Workplace webinar.
Because when it comes to workplace UV safety, “we wear the glasses” is a good start — but it isn’t the whole assessment.