regulation limit per square centimetre of skin and were rated level 1 on the INES scale. The fourth event concerned exposure greater than the regulation limit for skin and was rated level 2 on the INES scale (see box). The workers concerned by these events were given care and the radioactive particles responsible for their contamination were removed, in accordance with the procedure applied by EDF. 2.7.2 Assessment of personnel radiation protection ASN monitors compliance with the regulations relative to the protection of workers liable to be exposed to ionising radiation in NPPs. In this respect, ASN is attentive to all the workers on the sites, both EDF personnel and those of contractors. This monitoring is performed during inspections once or twice a year and per NPP, specifically on the topic of radiation protection, and during reactor outages as well as following significant events, or more occasionally in the EDF head office departments and engineering centres. It is also carried out during examination of the worker radiation protection files (significant event re– ports, design, maintenance or modification files, documents implementing the regulations and produced by EDF, etc.). During inspections carried out in 2021, ASN found improve– ments in how radiation protection is addressed on several NPPs. Progress is more particularly to be noted with regard to the dose optimisation approach. Improvements were also made in man– agement of access to and demarcation of red controlled areas, a sensitive process with regard to the high dose equivalent rates liable to be received there (higher than 100 mSv/h). Nonetheless, during inspections carried out on worksites in controlled areas, the ASN inspectors repeatedly found that radiological monitoring equipment was missing and containment means did not conform to the rules in force and they made corrective action requests. Deviations from radiation protection rules, in particular with regard to compliance with contamination checks on exiting controlled or contaminated areas, continue to be observed. EDF must continue to take measures to remedy these deviations. The situation remains a concern in certain NPPs, for which ASN will have to maintain its vigilance. Given the worker significant contamination events which occurred in 2021 and the deviations observed in the field, ASN will in 2022 be continuing its checks on the prevention of the dissemination of radioactive contamination, as well as on procedures for treating contamination victims, in order to verify that the time taken to provide treatment actually enables the workers exposure time to be reduced. 2.8 Labour Law in the Nuclear Power Plants 2.8.1 Oversight of Labour Law in the Nuclear Power Plants ASN is responsible for labour inspectorate duties in the 18 NPPs, the EPR reactor under construction at Flamanville and 11 other installations, most of which are reactors undergoing decommissioning. 800 to 2,000 people work in each NPP. About 24,000 EDF employees and 23,000 employees from outside contractors are thus assigned to these nuclear sites. The role of the labour inspectorate is to ensure that the Labour Code as a whole is applied by the employers, whether EDF or its contractors. The labour inspectorate, which takes part in the integrated vision of oversight sought by ASN, carries out its monitoring work in conjunction with the other activities to monitor and oversee the safety of facilities and radiation protection. Oversight of occupational health and safety regulations Throughout the year 2021, the ASN labour inspectors were called on by the employers, the staff, and the EDF or contractor personnel representatives, regarding the protection measures to be implemented in the workplaces and the conditions for the continuity of their activities on the sites. The labour inspectorate provided considerable support, by supplying information and explanations regarding the Government measures to deal with the Covid-19 pandemic to the employers and the health, safety and working conditions commissions of the social and economic committees. At the same time, action continued concerning the worksites entailing a risk linked to the presence of asbestos, the conformity of the work equipment and, more specifically lifting gear, fire and explosion risks and improved aeration and ventilation conditions in the workplaces. Finally, the labour inspectors systematically initiate an inquiry in the event of a severe accident or severe near-accident. 2.8.2 Assessment of health and safety, professional relations and quality of employment in the Nuclear Power Plants Certain occupational risk situations, such as the risks linked to working equipment and more particularly to lifting gear, explosion and fire risks and electrical risks, are still subjects of concern and must be further improved. This year, particular focus was placed on checks on the electrical installations that EDF is required to carry out in accordance with the Labour Code, with the performance of inspections on this topic in all the NPPs. The various inspections carried out by the labour inspectors brought to light weaknesses in the organisation on the sites for the correct performance of electrical checks or for coordination of these checks between the various EDF entities. The labour inspectorate also still occasionally observes situations in which the risk linked to accidental exposure to any asbestos present is not considered prior to the work. In 2022, progress is still required in the management of joint contractor working (quality of prevention plans, in particular), the use of subcontracting and foreign staff secondment situations. In the second half of 2021, ASN observed a deterioration in the occupational health and safety situation, against the backdrop of a considerable industrial workload. This deterioration led to a rising number of accidents, including numerous “high safety potential” or “near accident” events, the consequences of which could have been significant. The main causes identified were problems with the assessment of risks related to the activities, inappropriate individual behaviours with respect to the basic safety rules and a lack of proficiency in the lock-out of electrical equipment. The labour inspectors issued reminders on compliance with the maximum working hours and the fact that waivers could only be granted for good reason and then only relatively exceptionally. Steps were taken in 2021 regarding the monitoring of notifications and the conditions for the secondment of staff from foreign companies. Several inquiries into the transfer of labour contracts were also carried out when the contractors on the sites were changed. 302 ASN Report on the state of nuclear safety and radiation protection in France in 2021 10 – THE EDF NUCLEAR POWER PLANTS
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