ASN Report 2017

317 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 11  - Transport of radioactive substances 2.4.2 Package and vehicle signage So that the workers can be informed of the level of risk involved in each package and so that they can protect themselves effectively, the regulations require that the packages be labelled. There are three types of labels, corresponding to different dose levels in contact and at 1m from the package. The personnel working in proximity to the packages are thus visually informed of those which lead to the highest dose rates and can thus limit the time they spend close to them and can put them as far away as possible (for example by loading them towards the rear of the vehicle). The packages containing fissile materials must also carry a special label. This is to ensure that these packages are kept apart to prevent the triggering of a nuclear chain reaction. The special label enables compliance with this prescription to be easily verified. Finally, the markings on packages must comprise their type, the address of the consignor or consignee and an identification number. This enables delivery errors to be avoided and allows packages to be identified if lost. The vehicles carrying packages of radioactive substances must also have specific markings. Like all vehicles carrying dangerous goods, they carry an orange-coloured plate at the front and back. They must also have a placard with the radiation trefoil and the word “RADIOACTIVE”. The purpose of these vehicle placards is to provide the emergency services with the necessary information in the event of an accident. 2.4.3 Responsibilities of the different transport players The regulations define the responsibilities of the various parties involved during the lifetime of a package, from its design up to the actual shipment. These responsibilities entail special requirements. Therefore: ཛྷ ཛྷ The package model designer shall have designed and sized the packaging in accordance with the intended conditions of use and the regulations. It must obtain an ASN certificate (or in certain cases a certificate from a foreign authority) for type B or fissile packages containing UF 6 ). ཛྷ ཛྷ The manufacturer must produce packaging in accordance with the description given by the package designer. ཛྷ ཛྷ The consignor is responsible for providing the carrier with a package complying with the requirements of the regulations. It must in particular ensure that the material is authorised for transport, verify that the package is appropriate for its content, use a package that is approved (if necessary) and in good condition, carry out dose rate and contamination measurements and label the package. ཛྷ ཛྷ The loader is responsible for loading the package onto the vehicle and for stowing it in accordance with the consignor’s specific instructions and the rules of professional good practice. ཛྷ ཛྷ The carrier is responsible for carriage of the shipment to its destination. It must notably check the good condition of the vehicle, the presence of the on-board equipment (extinguishers, driver’s personal protection equipment, etc.), compliance with the dose rate limits around the vehicle and the positioning of the orange plates and placards. ཛྷ ཛྷ The transport may be organised by the forwarding agent. They are responsible, on behalf of the consignor or the consignee, for obtaining all the necessary authorisations and for sending the various notifications. The forwarding agent also selects the means of transport, the carrier and the itinerary, in compliance with the regulatory requirements. ཛྷ ཛྷ The consignee is under the obligation not to postpone acceptance of the goods, without imperative reason and, after unloading, to verify that the prescriptions concerning it have been satisfied. It must more specifically take dose rate measurements on the package after receipt in order to detect any problems that may have occurred during shipment. ཛྷ ཛྷ The package owner must set up a maintenance system in conformity with that described in the safety file and the approval certificate in order to guarantee that the elements important for safety are maintained in good condition All the transport stakeholders must set up a quality assurance system, which consists of a range of provisions for guaranteeing FOCUS Steps by ASN to improve how radiation protection regulatory requirements are taken into account The inspections carried out by ASN in recent years show that certain transport stakeholders do not take adequate account of the risk of exposure of workers and the public to ionising radiation. However, transport activities can have considerable radiation protection implications, in particular for workers. The individual monitoring of exposure to ionising radiation shows that drivers carrying radiopharmaceutical products are more exposed than the average worker in other activity sectors, with annual doses that can reach 14 millisieverts (mSv). This represents a significant fraction of the regulatory limit set at 20 mSv/year. The regulatory provisions designed to protect the public, workers and the environment stem from a variety of sources: the specific regulations governing the transport of radioactive substances, the Labour Code and the Public Health Code. Reconciling these various texts may lead to difficulties with interpretation. In order to promote coherent oversight of radiation protection, ASN and the General Directorate for Labour issued a joint document in 2017 intended for radiation protection and labour inspectors, specifying how the various texts are interconnected. On the basis of this document, ASN prepared a draft guide in 2017 intended for transport professionals which aims to recall the various regulatory requirements, specifying how they are interconnected when this can lead to difficulties, and which presents ASN’s recommendations for their correct implementation. This draft guide was submitted for public consultation in November  2017; it will be published on the ASN website in 2018.