ASN Report 2020

makes it possible to decide on whether to implement dosimetry to measure the dose received by the workers, if it is anticipated that it could exceed 1 mSv/year. Finally, all the transport players must be trained in the risks linked to radiation, so that they are conscious of the nature of the risks, as well as how to protect themselves and how to protect others. The workers involved in the transport of radioactive substances are also subject to the provisions of the Labour Code concerning protection against ionising radiation. On 29 March 2018, ASN published Guide No. 29 to help carriers meet their regulatory obligations relative to the radiation protection of workers and the general public. ASN intends to begin updating this guide in 2021, to take account of the new provisions of the Labour Code and the Health Code, and their implementing texts, for example the Order of 23 October 2020 (see box), resulting from Directive 2013/59/Euratom (known as the “BSS” Directive). In 2021, it will continue with measures to educate professionals, dealing more specifically with changes to the regulations. 2.4.2 Package and vehicle marking So that the workers can be informed of the level of risk arising from 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 rate levels in contact and at 1 m 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 display 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 carry a placard with the radiation trefoil and the word “Radioactive”. The purpose of these vehicle markings is to provide the emergency services with the necessary information in the event of an accident. 2.4.3 Responsibilities of the various 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: ∙ 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 . ∙ The manufacturer must produce packaging in accordance with the description given by the package designer. ∙ 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 substance 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. ∙ The transport may be organised by a forwarding agent. The forwarding agent is responsible, on behalf of the consignor or the consignee, for obtaining all the necessary authorisations and for sending the various notifications required by the regulations. The forwarding agent also selects the conveyance, the carrier and the itinerary, in compliance with the regulatory requirements. ∙ 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 good professional practice. ∙ The carrier and, more particularly, the driver, is responsible for carriage of the shipment to its destination. Their duties include checking 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 display of the orange plates and placards. ∙ The consignee is under the obligation not to postpone acceptance of the goods, without imperative reason and, after unloading, to verify that the requirements concerning them have been satisfied. It must more specifically perform dose rate measurements on the package after receipt in order to detect any problems that may have occurred during shipment. ∙ The package owner must set up a maintenance system in conformity with that described in the safety case and the approval certificate in order to guarantee that the elements important for safety are maintained in good condition. All the transport players must set up a quality management system, which consists of a range of provisions for ensuring compliance with the regulatory requirements and providing proof thereof. This for example consists in performing double independent checks on the most important operations, in adopting a system of checklists to ensure that the operators forget nothing, in keeping a trace of all the operations and all the checks performed, etc. The quality management system is a key element in ensuring the reliability of transport operations. The regulations also require that all operators involved in transport receive training appropriate to their functions and responsibilities. This training must in particular cover the steps to be taken in the event of an accident. Creation of a system of authorisation for security reasons Pursuant to Articles L. 1333-8 and R. 1333-146 of the Public Health Code, ASN intends in 2021 to revise its resolution 2015-DC-0503 on the system of notification for companies transporting radioactive substances on French territory, so that the transport operations involving the most highly radioactive sources will be subject to authorisation owing to their security implications. Authorisation will therefore be required for the transport of sealed radioactive sources, or batches of category A, B or C sources, as defined in Annex 13-7 to the Public Health Code. ASN Report on the state of nuclear safety and radiation protection in France in 2020 273 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES 09