Nevertheless, the inspections have also highlighted areas for improvement on which ASN will remain vigilant: ∙ compliance with the regulations concerning the frequency of technical verifications of radiation devices and associated equipment and the formalised processing of any noncon– formities detected during these checks; ∙ the presence of an unlocking device which can be actuated from inside the rooms in which particle accelerators are used; ∙ the correct functioning of the audio signal associated with the patrol procedure, which aims to confirm that nobody is in the room before authorising the emission of ionising radiation. ∙ the availability of radioactivity measurement devices in suf– ficient quantities for the operators who access these rooms and keeping these devices fit for duty. Lastly, with regard to experience feedback, no Significant Radiation Protection Event (ESR) was reported to ASN in 2021, apart from the recurrent events associated with the use of particle accelerators in shipment security checks. When conducting these checks, the customs services take precautions (such as broadcasting information messages in several languages) to avoid the unjustified irradiation of people who could be hiding in these vehicles (see point 3.3.1). However, despite these precautions, the customs services regularly notify ASN of events relating to the exposure of people hidden in checked vehicles. Although this exposure is unjustified, it nevertheless remains extremely low with effective doses of just a few microsieverts per person. 3.4 Research activities involving unsealed radioactive sources 3.4.1 The devices used In the research sector, as at 31 December 2021, ASN counted 630 licenses and about ten registrations issued under the Public Health Code, of which nearly 90% are issued to public or mixed (public/private) entities. The number of licenses is constantly decreasing, essentially due to the replacement of ionising radiation sources by alternative technologies that do not use 2. Among these inspections, 14 focused exclusively on the use of sealed radioactive sources or X-ray emitting devices. ionising properties. Added to these factors, since 2019, is the transfer of certain nuclear activities from the licensing system to the notification system (see point 2.4.2). This decrease is continuing with the entry into effect in mid-2021 (see point 2.4.3) of the new registration system, which targets in particular the holding/utilisation of unsealed sources, hitherto governed by the licensing system. The complete transitions of research laboratories from the licensing system to the registration system will continue over the coming years, particularly for the laboratories that reduce the quantities of radionuclides handled. These facilities and laboratories use mainly unsealed sources for medical and biomedical research, molecular biology, the agrifood business, the sciences of matter and materials, etc. They can also be suppliers of unsealed sources. They also use sealed sources for performing gas-phase chromatography, liquid scintillation counting or in irradiators. X-ray generators are also used for X-ray fluorescence or X-ray diffraction spectrum analysis. Particle accelerators are used for research into matter or for the production of radionuclides. 3.4.2 The radiation protection situation In 2021, ASN carried out 67 inspections in this sector(2) (compared with 52 inspections per year on average over the 2019‑2021 period). This rise with respect to 2020 (42 inspections) is the consequence of postponing until 2021 the inspections which could not take place in 2020 on account of the Covid‑19 pandemic. Broadly speaking, the actions undertaken over the last few years have brought improvements in the implementation of radiation protection within research laboratories thanks to a growing overall awareness of the radiation exposure risks. Among the areas of progress observed in 2021, ASN underlines the strong involvement of the RPAs, due in particular to the allocation of dedicated means and their interaction with the research teams, thereby allowing better integration of radiation protection. Conversely, the conditions of storage and removal of waste and effluents remain the main difficulties encountered by the research units. This worrying situation is particularly INITIATING TRUSTWORTHINESS CHECKS The Public Health Code stipulates that the person responsible for the nuclear activities shall issue individual authorisations to the people who need access to the sources or to the information protecting them against malicious acts. To do this, the person may request the opinion of the Command Specialised in Nuclear Security (CoSSeN). This service, which has national competence, is part of the Ministry responsible for energy and the Ministry of the Interior; it is attached to the Director General of the National Gendarmerie. The CoSSeN’s opinion is based on an administrative review intended to check that the behaviour of the persons concerned is not, or has not become, incompatible with the functions or duties exercised. This trustworthiness check is based on the review of police databases and, if the persons are mentioned in the said databases, additional verifications. The persons concerned must be informed of this trustworthiness check. The conditions of investigation are governed by the Interior Security Code. This Code also provides the possibility of conducting such trustworthiness checks on the person responsible for a nuclear activity, if the activity requires a license. Performing such checks meets one of the principles of the IAEA Code of Conduct on the Safety and Security of Radioactive Sources. ASN considers that is would be illogical for a person responsible for a nuclear activity to be able to ask the CoSSeN to perform a trustworthiness check on a member of their staff or their subcontractors’ staff without themselves undergoing such a check insofar as they supervise the conditions of exercise of the nuclear activity. At the end of 2020, ASN initiated an experiment in this respect on persons responsible for nuclear activities who are either suppliers of category A, B or C sealed radioactive sources or users of such sources in the Auvergne‑Rhône‑Alpes region. The preparation of this experiment included numerous interchanges with the CoSSeN. Thanks to this experiment, the procedures applicable by all the ASN entities concerned were definitively laid down, and improvements were made to the form used to collect information to be forwarded to the CoSSeN to initiate the check. At the end of 2021, all the trustworthiness checks were being initiated for the existing licenses. As from 2023, these trustworthiness checks will only be carried out again for license renewal applications. License modification applications will not be concerned by this procedure, except when the requested change concerns the nuclear activity licensee. First-time license applications are now systematically subject to a trustworthiness check. ASN Report on the state of nuclear safety and radiation protection in France in 2021 253 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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