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4.3 Unjustified or prohibited
activities
4.3.1 Application of the ban on the intentional
addition of radionuclides in consumer goods
and construction products
The Public Health Code indicates
“that the intentional
addition of radionuclides to consumer goods and construction
products is prohibited”
(Articles R. 1333-2 and 3).
The trading of radioactive stones or decorative objects,
accessories containing sources of tritium such as
watches, key-rings, hunting equipment (sighting
devices), navigation equipment (bearing compasses)
or equipment for river fishing (strike detectors) is
specifically prohibited.
Article R. 1333-4 of this same Code states that waivers
to these prohibitions can, if the advantages they bring
outweigh the health risks they can represent, be granted
by order of the Minister responsible for Health and,
depending on the case, by the Minister responsible
for Consumption or the Minister responsible for
Construction, after consulting ASN and HCSP (French
High Public Health Council). No waiver is possible
for foodstuffs, toys, jewellery and cosmetic products.
ASNconsiders that this systemof waivers to the regulations
must remain very limited. It was implemented for the first
time in 2011 for a waiver request concerning the use of a
neutron analysis device in several cement works (Order
of 18th November 2011 from the Ministers responsible
for Health andConstruction, ASNopinion 2011-AV-0105
of 11th January 2011 and ASNopinion 2011-AV-0124 of
7th July 2011). It was then used in 2014 for light bulbs
containing very small quantities of radioactive substances
(krypton-85, thorium-232 or tritium), servingmainly for
applications requiring very high intensity lighting such as
public places, professional environments, or for certain
vehicles (Order of 12th December 2014 of theMinisters
responsible for Health and Construction, ASN opinion
2014-AV-0211 of 18th September 2014).
A waiver request to allow the addition of radionuclides
(tritium) in certain watches was also refused (Order of
12th December 2014, ASN opinion 2014-AV-0210 of
18th September 2014).
The list of consumer goods and construction products
concerned by an ongoing waiver request or for which
a waiver has been granted is published on the website
of the French High Committee for Transparency and
Information on Nuclear Security (HCTISN).
.
4.3.2 Application of the justification principle
for existing activities
The justification of existing activitiesmust be re-assessed
periodically in the light of current knowledge and
technological changes in accordance with the principle
described in point 4.2.1. If the activities are no longer
justifiedby the benefits they bring, orwith respect to other
non-ionising technologies that bring comparable benefits,
they must be withdrawn from the market. A transitional
period for definitive withdrawal from the market may
be necessary, depending on the technical and economic
context, particularly when a technological substitution
is necessary.
Smoke detectors containing radioactive sources
Devices containing radioactive sources have been used
for several decades to detect smoke in buildings, as part
of firefighting policy. Several types of radionuclides have
been used (americium-241, plutonium-238, nickel-63,
krypton-85). The activity of themost recent sources used
does not exceed 37 kBq, and the structure of the detector,
in normal use, prevents any propagation of radioactive
substances into the environment.
New non-ionising technologies have gradually come to
competewith these devices. Optical devices nowprovide
comparable detectionquality, and can therefore satisfy the
regulatory andnormative fire detection requirements. ASN
therefore considers that smoke detection devices using
radioactive sources areno longer justifiedand that the seven
million ionic smoke detectors installed on 300,000 sites
must be progressively replaced.
The regulatory framework governing their removal was
put in place by the Order of 18th November 2011 and
two ASN resolutions of 21st December 2011.
This regulatory framework aims at:
•
planning the removal operations over ten years;
•
supervising themaintenance or removal operations that
necessitate certain precautions with regard to worker
radiation protection;
•
preventing any uncontrolled removals and organising
the collection operations in order to avoid detectors
being directed to an inappropriate disposal route, or
even simply being abandoned;
•
monitoring the pool of detectors.
Four years after the implementation of the newregulatory
systemfor ionic smoke detector removal andmaintenance
activities, as at 31st December 2015 ASN has delivered
263notificationcertificates and7national licenses (delivered
to industrial groupswith a total of 104 agencies) for ICSD
removal and fire safety systemmaintenance activities.
With regard to the tracking of the pool of ionisation
chamber smoke detectors, in 2015 IRSNput in place, in
collaborationwith ASN, a computerised systemenabling
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CHAPTER 10:
INDUSTRIAL, RESEARCH AND VETERINARY USES AND SOURCE SECURITY
ASN report on the state of nuclear safety and radiation protection in France in 2015