∙ protect sensitive information (access limited to duly authorised personnel, promotion of good information technology security practices); ∙ detect an actual or attempted malicious act (theft, in particular) as early as possible; ∙ take action or alert the local law enforcement agencies after preparing their on-site actions. ∙ regularly raise awareness, inform and train the personnel on the subject; ∙ periodically check the effectiveness of the equipment and organise exercises. For obvious reasons of restricting access to sensitive information, some of the provisions of this Order, detailed in its appendices, were not published in the Official Journal. ASN therefore, within its area of competence, sent the relevant appendices by personalised letter to each of the nuclear activity licensees concerned. ASN had also planned to raise awareness on the publishing of the Order by actions in the regions at professional events or by holding ad hoc meetings with professionals concerned. Due to the Covid-19 pandemic, this initiative was suspended after just one event. It was able to be resumed throughout year 2021, and finally two-thirds of the regions have organised such workshops. Alongside the preparation of the Order, and to facilitate its practical implementation, a working group has started preparing a joint ASN/SHFDS (Service of the Defence and Security High Official of the Ministry of Ecological Transition) guide for nuclear activity licensees and for the ASN and SHFDS inspectors. This guide should facilitate common understanding of the requirements of the Order by the professionals and inspectors alike. It will present recommendations for the implementation of these requirements and include numerous examples. As it details certain elements of the appendices to the Order, its circulation will be limited. In the second half of 2020, ASN conducted a targeted consultation of professionals on this draft guide. The comments received were taken into account and the ultimate discussions with the SHFDS of the Ministry of Ecological Transition should enable it to be adopted and distributed in 2022. In addition, assessment of the resistance of the windows and doors that were installed when less importance was given to protecting sources against theft is a subject that will be fully relevant in mid-2022 when the appendices of the Order of 29 November 2019 become applicable. On the basis of work performed by IRSN, an assessment grid has been drawn up and distributed. This document will enable all the professionals concerned to adopt a common methodology. 2.4 Licensing, registration and notification of ionising radiation sources used for industrial, research or veterinary purposes 2.4.1 Integration of the principles of radiation protection in the regulation of non-medical activities With regard to radiation protection, ASN verifies application of the three major principles governing radiation protection which are written into the Public Health Code (Article L. 1333-2), namely justification, optimisation of exposure and dose limitation. Assessment of the expected benefit of a nuclear activity and the corresponding health drawbacks may lead to prohibition of an activity for which the benefit does not seem to outweigh the risk. Either generic prohibition is declared, or the license required for radiation protection purposes is not issued or is not extended. For the existing activities, the elements supporting implementation of the justification principle are recorded in GRAPH Breakdown of high-activity sealed sources according to their category and their oversight authority for protection against malicious acts 5 0 10 20 30 40 50 60 Ministry of Defence Defence and Security High Official (HFDS) ASN ASN and HFDS Category A Category C Category B The sources in category A of the Public Health Code (PHC) correspond to the IAEA category 1 sources. The PCH category B sources correspond to: – the IAEA category 2 sources, and – the IAEA category 3 sources contained in a mobile or portable device. The PHC category C sources correspond to the IAEA category 3 sources not contained in a mobile or portable device. CATEGORISATION OF RADIOACTIVE SOURCES Radioactive sources have been classified by the IAEA since 2011 on the basis of predetermined exposure scenarios, in five categories from 1 to 5, according to their ability to create early harmful effects on human health if they are not managed safely and securely. Category 1 sources are considered extremely dangerous while those in category 5 are considered very unlikely to be dangerous. Sources in categories 1 to 3 are considered dangerous for humans to varying degrees. This categorisation is based solely on the capacity of the sources to produce deterministic effects in certain exposure scenarios and must not under any circumstances be considered as proof that there is no danger in exposure to a category 4 or 5 source, as such exposure could cause stochastic effects in the longer term. The principles of justification and optimisation must therefore be respected in all cases. This IAEA work has been taken up in an Appendix to the Public Health Code amended by Decree 2018‑434 establishing various provisions in the nuclear field. Nevertheless, the IAEA categories 4 and 5 have been grouped together in category D of this Code. ASN Report on the state of nuclear safety and radiation protection in France in 2021 243 08 – SOURCES OF IONISING RADIATION AND THEIR INDUSTRIAL, VETERINARY AND RESEARCH APPLICATIONS 08 07 13 04 10 06 12 14 03 09 05 11 02 AP 01
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