ASN Report 2017

92 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 03  - Regulations principle, more particularly in the medical field, in facilities where interventional procedures are carried out. The other existing limits are maintained, in particular: ཛྷ ཛྷ the annual dose set at 20 mSv over 12 consecutive months, except in the case of exemptions granted to take account of exceptional exposure justified beforehand, or emergency professional exposure; ཛྷ ཛྷ the dose limits for pregnant women or more accurately for the unborn child (1 mSv for the period from the declaration of pregnancy up until birth). Risk assessment Risk assessment by the employer is a precondition to determining the prevention measures and means (collective and individual measures, zoning, etc.) and the conditions for employment of workers (classification, dosimetry monitoring of workers). A radiation protection organisation needs to be set up if a zone is restricted, if workers are classified, or if verifications are required. This is a change with respect to the prior situation in which it was mandatory for the workers to be subject to the provisions of the Labour Code concerning the radiation protection of workers when the activity was subject to one of the administrative systems applicable to nuclear activities. Radiation protection advice The employer advisory system is now based on a “radiation protection adviser” who may be, as chosen by the employer: ཛྷ ཛྷ either the Radiation Protection Expert-Officer (RPE-O), an employee of the facility or, failing which, of the contractor, who will continue to hold a certificate issued by a certified organisation; ཛྷ ཛྷ or a Radiation Protection Organisation (OCR) certified according to requirements to be determined in an order. However, the outside RPE-O who intervenes only for activities requiring notification, may continue to exercise these duties for three years. The duties of the RPE-O and the OCR are extended to questions concerning protection of the population and the environment, which is covered by additional provisions in the Public Health Code. In the BNIs, an organisation based on “centres of expertise” grouping together the skills and qualifications necessary for acting as radiation protection adviser, takes the place of the RPE-O or the OCR. This internal organisation is subject to ASN approval within the framework of the existing procedures of the BNI System (Decree 2007-1557 of 2nd November 2007 concerning BNIs and the monitoring of the nuclear safety of the transport of radioactive substances, and was modified for this purpose with the creation of a new Title XII (Articles 63-6 and 63-8)). The procedures for the training and certification of the radiation protection advisers (RPE-O, OCR, centres of expertise) will be defined in a new order to replace the Order of 6th December 2013, concerning the training conditions for the radiation protection expert-officer and for certification of the training organisations. Regulation inspections and checks The inspections performed by the organisations approved by ASN pursuant to the Labour Code are abolished. Initial regulation checks will however be performed by approved organisations at commissioning or in the event of a significant modification. They will concern certain working equipment defined by an order, in the workplace and on vehicles used for radioactive materials transport operations. Periodic checks, for which the conditions will be defined by means of an order, will be carried out by the radiation protection adviser. Radon The monitoring of exposure to radon is extended to all workplaces (basements and ground floors) within the priority zones (only underground environments were hitherto subject to mandatory surveillance). The reference level for radon in the workplace is lowered to 300 Bq/m 3 from 400 Bq/m 3 . In the case of worker exposure exceeding 6 mSv/year, the employer shall set up a radiation protection organisation, “radon” zoning and individual dosimetry monitoring. The use of a specialist organisation is only required when this measurement reveals an exposure situation in excess of 6 mSv/year (organisation approved for radon by ASN or accredited). The results shall be communicated to IRSN when the radon activity concentration exceeds 300 Bq/m 3 after deployment of the prevention measures. Workers in an emergency situation The provisions of the Public Health Code dealing with occupational health and safety in a radiological emergency situation have been transferred in full to the Labour Code, to allow harmonised implementation of the provisions applicable to workers intervening in a radiological emergency FOCUS ASN opinion of 2nd February 2017 on the new provisions concerning radiation protection of workers Although its opinion was on the whole favourable, in its opinion 2017-AV-0286 of 2nd February 2017 on the draft decree for protection of workers against the risks arising from ionising radiation, ASN nonetheless drew attention to the risk of possible confusion regarding the nature of the regulation checks that were to be entrusted to a “radiation protection organisation” given that this same organisation could also be tasked with advising the employer regarding all questions concerning the radiation protection of workers. The decree under preparation takes account of this observation by making a clear separation between the new advisory system and the monitoring (verification) arrangements.