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2.1.7 Radioactive resources management rules

The general radioactive source management rules are

contained in section 4 of Chapter III of Title III of Book III

of the first part of the Public Health Code. These rules

are as follows:

No personmay transfer or acquire radioactive sources

without a license.

Prior registration with IRSN is compulsory for the

purchase, distribution, import andexport of radionuclides

as sealed or unsealed sources, or of products or devices

containing them; this prior registrationmakes it possible

to track the sources from their entry onto the market

until the end of their life. ASN resolution 2015-DC-

0521 of 8th September 2015 concerning themonitoring

and registration procedures for radionuclides in the

form of radioactive sources and products or devices

containing them, clarified the regulatory framework

with regard to the procedures for this registration of

movements and for the monitoring rules concerning

radionuclides in the form of radioactive sources (see

chapter 10).

Each establishment is required to ensure the traceability

of radionuclides in the formof sealed or unsealed sources

and of products or devices that contain them.

ASN must be notified in the event of loss or theft of

radioactive sources.

Users of sealed sources are obliged to have the expired,

damaged or end-of-life sources taken back by the

supplier, who is obliged to recover them.

On this latter point, Decree 2015-231 of 27th February

concerning the management of used sealed sources,

which came into force on 1st July 2015, modified

Articles R.1333-52 and R.1337-14 of the Public Health

Code, in order to enable those in possession of sources

to have the used sealed radioactive sources that have

expired or reached the end of their service life recovered

not only by their initial supplier, but also by any other

authorised supplier of radioactive sources or, as a final

resort, by Andra. The spirit of this modification is to

address the difficulties experienced by those in possession

of sources with regard to locating the original suppliers,

the cost of recovery and the monopoly enjoyed by certain

suppliers.

The conditions of implementation and payment of the

financial guarantees incumbent on the source suppliers

must be defined by an order from theMinisters responsible

for Health and Finance (Articles R. 1333-53 and

R. 1333-54-2 of the Public Health Code). In the absence

of such an order, the particular licensing conditions

established by the CIREA (Interministerial Commission

on Artificial Radioelements) in 1990 are taken up as

requirements in the licenses and are consequently

applicable to the licensees.

2.2 Protection of persons exposed

for medical and forensic purposes

Radiation protection for individuals exposed for medical

purposes is based on two principles mentioned in

paragraphs 1 and 2 of Article L. 1333-1 of the Public

Health Code respectively: justification of the procedures

and optimisation of exposure, which are under the

responsibility of both the practitioners prescribing

medical imaging examinations entailing exposure to

ionising radiation and the practitioners carrying out these

procedures. These principles cover all the diagnostic

and therapeutic applications of ionising radiation,

including radiological examinations requested for

screening, occupational health, sports medicine and

forensic purposes.

Inmedical imaging (see chapter 9), the final responsibility

for exposure lies with the practitioners performing the

exams. The rules applicable for the radiation protection

of patients set out in the Public Health Code are different

from those established for the protection of professionals,

set out in the Labour Code, even if the competence of

the physicians and professionals involved in delivering

the dose must cover both domains.

2.2.1 Justification of practices

Awritten exchange of information between the prescribing

practitioner and the practitioner carrying out the procedure

exposing the patient should provide justification of

the benefit of the exposure for each procedure. This

“individual” justification is required for each procedure.

Articles R. 1333-70 and R. 1333-71 of the Public Health

Code respectively require the publication of “prescription

of routine procedures and examinations” guides (also

called

“indication guides”

) and “performance of procedures”

guides (called

“procedure guides”

).

2.2.2 Optimisation of exposure

Optimisation inmedical imaging (radiology and nuclear

medicine) consists in delivering the lowest possible dose

compatible with obtaining a quality image that provides

the diagnostic information being sought. Optimisation

in therapy (external radiotherapy, brachytherapy and

nuclear medicine) consists in delivering the prescribed

dose to the tumour to destroy cancerous cells while

limiting the dose to healthy tissues to the strict minimum.

Standardised guides for conducting procedures using

ionising radiation have been prepared and are regularly

updated by health professionals, or are currently being

prepared, to facilitate practical application of the

optimisation principle (table 1).

103

CHAPTER 03:

REGULATIONS

ASN report on the state of nuclear safety and radiation protection in France in 2015