The inspectors also noted that the efforts made by the companies to train newly-arrived classified workers had been maintained. Consequently, this information was duly dispensed to the new staff in more than 94% of the inspected facilities concerned in 2021. However, the periodic refreshing of this training and its content require further improvements. Conversely, ASN still considers that the deviations observed in cordoning off the work zones on worksites (found in slightly more than one inspection in four) are a cause for concern. ASN underlines that the lack of preparation and cooperation between the ordering customers and the radiography contractors before starting temporary worksites (particularly the failure to draw up a precise prevention plan) is one of the causes of these deviations. ASN points out that the work area must be cordoned off before the work begins and, in all events, before the radiography equipment is installed, that the cordoning off must be contin– uous and that it is essential to have warning lights in sufficient quantity. To ascertain that cordoning off ensures compliance with the regulatory dose rate values, it is vital to take at least one measurement and to record the result(s). Zoning and cordoning off effectively constitute the main safety barrier in worksite configurations, particularly to prevent unintended exposures. Consequently, ASN remains extremely vigilant regarding this point, which is systematically checked during worksite inspections; moreover, penal enforcement actions have already been proposed for serious breaches. The recurrence of the deviations observed in the last few years in cordoning off the work zone induced ASN to address a circular letter to the profession as a whole in 2021, asking for tightened vigilance in this respect. ASN moreover took advantage of the inspections of worksites using gamma radiography devices to conduct a verification campaign of the carriers’ ADR class 7 certificates (certificate necessary for the carriage of these devices) and the CAMARIs (see above) of the operators on the worksite. At the end of the year, these documents were compared with the databases of the bodies that issued them. This verification campaign was part of the antifraud actions implemented by ASN for several years now to check the veracity of the documents presented by the licensees. No attempted falsification of documents was detected. ASN also notes disparities in the quality of the technical files it has to examine for inspection preparation or follow-up, and those received for license applications. The contractors must in particular be more attentive to the reports establishing the conformity of their facilities with the appropriate technical baseline requirements. ASN still detects errors too frequently, particularly when production of these reports has been subcontracted, and these errors sometimes lead to nonconformities. Furthermore, the inspections carried out in 2021 show that in a quarter of the cases the X-ray radiography lighted signalling systems were not properly installed or verified. Lastly, the protection of ionising radiation sources against malicious acts (see box page 252) must be further improved. For example, the individual authorisations for access to sources were correctly drawn up in just over half the inspected sites, the policy for protection against malicious acts was established in less than half the inspected sites, and sensitive information was identified and controlled in less than a third of the inspected sites. With regard to application of the principles of justification and optimisation, the long-term reflections undertaken by the nondestructive testing professionals have resulted in guidelines which aim to promote the use of alternative methods to industrial radiography. The work is continuing within the professional bodies, in particular with the updating of the construction and maintenance codes for industrial equipment, in order to promote the use of non-ionising inspection methods. Moreover, France has a good network of fixed industrial radiography facilities, thereby enabling 70% of the professionals to propose services in exposure bunkers (of which 97 can be used for gamma radiography). ASN considers that the risks of incidents and the workers’ occupational exposure are generally well controlled by the licensees when radiography is performed in a bunker complying with the applicable regulations. Despite the availability of such facilities, ASN still observes too often that parts that undergo radiography on worksites, particularly those scheduled at night in workshops, could have been easily moved to a bunker. Apart from optimising doses for the workers, it would also eliminate the risk of having to temporarily shut down the workshop in the event of an incident preventing the radioactive source of the gamma ray projector from returning to the safe position. ASN considers that the ordering customers have a key role to play to improve radiation protection in industrial radiography, by favouring industrial radiography services in facilities that have a bunker. Enhancing the awareness of all the players is therefore a priority. The regional initiatives to establish charters of good practices in industrial radiography implemented for several years now at the instigation of ASN and the labour inspectorate, particularly in areas corresponding to the former regions of Provence-AlpesCôte d’Azur, Haute-Normandie, Rhône-Alpes, Nord-Pas-deCalais, Bretagne and Pays de la Loire, allow regular exchanges between the various stakeholders. The ASN regional divisions and other regional administrations concerned also regularly organise regional awareness-raising and discussion symposia for which the actors of this professional branch show a real interest. Lastly, in 2021 as in the last few years, no cases of overexposure of industrial radiography operators were reported to ASN, even if several significant events linked to loss of source control (source “jamming”) did occur during the use of gamma ray projectors. These events were correctly diagnosed by the operators and the persons concerned did not undertake any inappropriate or prohibited operations. ASN draws that attention of companies having gamma radiography inspections carried out in their fa– cilities to the consequences of the radioactive source getting jammed outside the gamma ray projector, and especially the setting up of an exclusion zone for the time necessary to defin– itively place the source in safe condition, which can often be several days. 3.2 Industrial irradiators 3.2.1 The devices used Industrial irradiation is used for sterilising medical equipment, pharmaceutical or cosmetic products and for the conservation of foodstuffs. It is also used to voluntarily modify the properties of materials, such as for the hardening of polymers. These consumer product irradiation techniques can be authorised because, after being treated, these products display no residual artificial radioactivity (the products are sterilised by passing through radiation without themselves being “activated” by the treatment). Industrial irradiators often use cobalt-60 sources, whose activity can be very high and exceed 250,000 terabecquerels (TBq). Some of these installations are classified as BNIs (see chapter 12). In many sectors, X-ray generators are gradually replacing high-activity sealed sources for the irradiation of products (see point 1.3.1). 248 ASN Report on the state of nuclear safety and radiation protection in France in 2021 08 – SOURCES OF IONISING RADIATION AND THEIR INDUSTRIAL, VETERINARY AND RESEARCH APPLICATIONS
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