5 // Conclusion and outlook Implementation of the new regulatory framework applicable to nuclear activities In 2021, reinforcing of the graded approach to oversight, based on a classification of the different categories of nuclear activities involving sources of ionising radiation continued, with the entry into effect of resolutions relative to the registration system. For the actual entry into effect of this new system, ASN has developed an on-line registration service on its website, allowing application files to be submitted on line, and widely disseminated information to the professionals. Alongside this, to finalise the overhaul of the systems of the Public Health Code as a whole, ASN will in 2022 start updating the resolutions concerning the content of the application for nuclear activities subject to the licensing system; this update will include, if necessary, the part relating to the supply of devices emitting X-rays. In addition, it will continue its actions to speed up the removal of ICSDs after December 2021. Lastly, ASN will work in collaboration with the DGT on the updating of the regulatory framework concerning the technical design rules and the certification procedures for industrial radiography devices (Article R. 4312-1-3 of the Labour Code). Oversight of the protection of radioactive sources against malicious acts ASN has been designated as the authority to oversee the provisions to protect the radioactive sources against malicious acts in the majority of facilities. Publication of the abovementioned Decree brought into effect the first provisions in this respect in mid-2018: those responsible for nuclear activities must more specifically give individual authorisations for access to the most hazardous sources, including for their transport, and for access to sensitive information. These initial provisions to protect sources against malicious acts have been reinforced with the entry into effect on 1 January 2021 of part of the amended Order of 29 November 2019 which requires company functioning and organization to be adapted to these specific risks. Although these are new regulatory provisions, it is above all and additional risk (just like the cyber security associated with it, from the moment it concerns information necessary for the protection of sources) to be managed and integrated in the corporate culture particularly through measures to raise awareness and inform the personnel. In this respect, the senior management of the companies con– cerned must henceforth determine and formalise a policy of protection against malicious acts implemented by the nuclear activity licensee. The necessary resources, authority and skills must also be delegated to the licensee. On 1 July 2022, the entire Order will enter into force and the technical systems to ensure the physical protection of the sources will have to be in place. This concerns activities within facilities, on worksites (utilisation, possession) and road transport alike. Since 2019, the ASN inspections address the protection of sources against malicious acts with greater emphasis. Inspections devoted entirely to this question began in 2021, will be more numerous in 2022 and should reach “cruising speed” as of 2023, the first full year during which the entire amended Order of 29 November 2019 will be applicable. When examining the nuclear activity licensing applications, ASN ensures that the necessary provisions have been put in place. The required content of the application files has therefore also evolved in recent years to include protection of radioactive sources. ASN has moreover continued the actions initiated to train its personnel in this new duty and has made in-house aids available (inspection guide, license application examination matrices, question-and-answer sheets). In addition to the information that can be provided during inspections, regional workshops were organised to present the Order. A guide written jointly by ASN and the Defence and Security High Official of the Ministry responsible for energy (Ministry of Ecological Transition) presenting recommendations for implementing the requirements regarding the protection of sources against malicious acts is currently being prepared. Lastly, to take account of the last three years of feedback from the examination of the license applications, from the inspections and more broadly from the numerous discussions with the professionals, an update of some of the provisions of the Order is already being considered. ASN Report on the state of nuclear safety and radiation protection in France in 2021 259 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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