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Regulation and monitoring of the transport
of radioactive substances
Transport comprises all operations andconditions associated
withmovementsofradioactivesubstances,suchaspackaging
design, manufacture, maintenance and repair, as well as
the preparation, shipment, loading, carriage, including
storage in transit, unloading and reception at the final
destination of the radioactive substance consignments
and packages (see chapter 11).
The safety of transport of radioactive substances is ensured
by three main factors:
•
primarily, the robustness of package design and the
quality of package construction;
•
the reliability of transport and of certain special vehicle
equipment;
•
anefficient emergency response in the event of anaccident.
Regulation and monitoring of activities comprising
a risk of exposure to ionising radiation
InFrance, ASN fulfils this role by drafting andmonitoring
technical regulations concerning radiationprotection (see
chapter 3, point 1).
The scope of ASN’s regulatory role in radiationprotection
covers all the activities that use ionising radiation. ASN
exercises this duty,where applicable, jointlywithother State
services such as the Labour Inspectorate, the Inspectorate
for Installations Classified on Environmental Protection
Grounds (ICPE), the departments of theMinistry ofHealth
and the FrenchNational Agency forMedicines andHealth
Products Safety (ANSM). This actiondirectly concerns either
the users of ionising radiation sources, or organisations
approved to carry out technical inspections on these users.
Themethods of regulating the radiationprotectionplayers
are presented in table 2.
Regulating the application of Labour Law
in the nuclear power plants
Labour inspection in the NPPs has been ensured from
the outset by the administration tasked with technical
oversight under the authorityof theMinister responsible for
Labour; the competence of ASN is nowcodified inArticle
R. 8111-11 of the Labour Code. The nineteen NPPs in
operation, the nine reactors undergoing decommissioning
and the EPR reactor under construction at Flamanville
are the responsibility of the ASN labour inspectorate.
The regulation of safety, radiation protection and labour
inspection very often covers common topics, such as
worksite organisation or the conditions of use of outside
contractors (see chapter 12).
The ASN labour inspectors have four essential duties:
1. checking application of all aspects of labour legislation
(health, occupational safety and work conditions,
occupational accident inquiries, quality of employment,
collective labour relations);
2. advising and informing the employers, employees and
personnel representatives about their rights, duties and
labour legislation;
3. informing the administrationof changes in theworking
environment and any shortcomings in the legislation;
4. facilitating conciliation between the parties.
The ASN labour inspectors also have powers of decision
concerning authorisation applications (firing of personnel
representatives, waivers to regulations in terms of work
or rest times, health and safety).
These duties are based on international standards
(International Labour Organisation (ILO) Convention
No. 81) andnational regulations. ASNcarries themout in
liaisonwith the otherGovernment departments concerned,
mainly the departments of the Ministry responsible for
Labour.
ASN has set up an organisation enabling it to deal with
these issues. The action of the ASN labour inspectors
(6.2 full-time equivalent – FTE) in the field has increased
markedly since 2009, particularly during reactor outages,
with inspection visits, advisory roles at themeetings of the
Committee for Health, Safety and Working Conditions
(CHSCT) and the Inter-company Committee on Safety
TABLE 2:
Methods of ASN regulation of the various radiation protection players
REVIEW/
AUTORISATION
INSPECTION
OPENNESS AND
COOPERATION
Users of ionising
radiation sources
• Review of the dossiers
required by the Public
Health Code
(Articles R. 1333-1
to R. 1333-54)
• Pre-commissioning
inspection
• Registration
of notification or delivery
of the authorisation
• Radiation protection
inspection
(Article L. 1333-17 of
the Public Health Code)
• Jointly with the
professional
organisations, drafting
of guides of good
practices for users
of ionising radiation
Bodies approved
for radiation
protection
inspections
• Review of application
files for approval to
perform the inspections
specified in
Article R. 1333-95
of the Public Health Code
and Articles R. 4451-29
to R. 4452-34
of the Labour Code
• Organisation audit
• Delivery of approval
• Second level
inspection:
-- in-depth inspections
at head office and
in the branches
of the organisations
-- unannounced field
inspections
• Jointly with the
professional
organisations, drafting
of rules of good practices
for performance
of radiation protection
inspections
138
CHAPTER 04:
REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION
ASN report on the state of nuclear safety and radiation protection in France in 2015