4   PRIORITIES IMPLEMENTED DURING THE YEAR
  4.1 General actions

In 2005, and in addition to its regulatory preparation work, the ASN initiated or continued with several actions of a more general nature designed to improve awareness of the applicable regulations, rationalise the scope of certain licences concerning a given facility, or promote the drafting of guides of good practice by the professionals.

These informative actions include ASN participation in:
– the "National research laboratories radiation protection prevention days" organised by the INSERM (national health and medical research institute);
– the days organised by the COFREND (French confederation of non-destructive testing), specifically dealing with gamma radiography;
– the SFRP (French radiation protection society) days dealing with radioactive sources;
– several meetings held in universities.

These actions enable the ASN to recall the main applicable regulatory requirements, to specify what they expect and to stress practical aspects for facilitating the smooth running of the licensing process. They are also the opportunity for the ASN to obtain direct feedback from the users concerning any constraints and difficulties they are experiencing. With respect to rationalisation of the scope of licensing, we would also mention:
– the continued process to combine the licences of the Pasteur Institute in Paris, with a view to improved internal supervision of the Institute;
– combination of the licences (in particular for gamma radiography) of several companies with a number of facilities in France and operating with internal rules common to the various sites.

When the company organisation so allows, this approach is designed to reduce the number of licences covering all the company's activities and thus shift overall responsibility to the head of the facility.

Finally, concerning the encouragement given to professionals to define guides of good practice for radiation protection in their daily activities, the ASN in July 2005 suggested to the COFREND that consideration be given to justification of gamma radiography work and production of a document detailing the best practices to be observed, both by the client and by the gamma radiography contractors. Gamma radiography is an area in which the radiation protection stakes are high, as incorrect use of the appliances or loss of a gammagraph source are likely to have serious health consequences. This hazard is indeed illustrated by the accident which occurred on 15 December 2005 in Chile, in which a Chilean worker was seriously irradiated and is currently being treated at the Percy hospital in France. In a letter dated 8 September 2005, the COFREND agreed in principle to such actions.

  4.2 Suppliers

In 2005, the ASN carried on with priority action initiated in 2003 about the suppliers of radionuclide sources or appliances containing them and used for industrial or research purposes. These companies have considerable responsibility for the safety of source movements, their traceability, the recovery and the disposal of used or unwanted sources. It is therefore important that their situation with regard to radiation protection rules be transparent and unambiguous and that their activities be duly covered by the licence specified in article R. 1333-27 of the Public Health Code.

During the course of 2005, 35 licences were issued to suppliers and 11 licences were revoked. Several dozen dossiers are also being investigated by the ASN.

In this respect, these dossier investigations can last a long time, given the combination of various negative factors, including:
the problem in identifying the right people to talk to and then obtaining pertinent data about the sources and appliances;
the complexity of the radiation protection analyses for appliances and radionuclide sources;
obtaining specific guarantees to ensure effective recovery of used or unwanted sealed sources.

However, the extensive work currently under way on this type of dossier will ease later examination subsequently when renewing licences or when licence modifications are requested.