Order of 24 June 2020, on which ASN issued an opinion (opinion 2020-AV-0353 of 11 June 2020). The Order of 29 November 2019 amended also applies to the transport of category A, B and C sources, whether individually or in batches. The main requirements of this Order aim, by adopting a graded approach based on categories A, B, C (and D for two items), to have the licensee put in place physical barriers and equipment, along with a policy and an internal organisation to protect sources against malicious acts. These technical and organisational provisions are intended to: ∙ prevent or delay the theft of radioactive sources through access control measures, reinforcement of physical barriers and their openings (doors, windows, etc.), alarms and crossing-detection; ∙ 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; ∙ raise awareness, inform, and regularly train the personnel on this topic; ∙ 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 accompanied the publishing of the Order by actions in the regions at professional events or by holding ad hoc meetings with professionals concerned. This initiative had been suspended due to the Covid-19 pandemic. It was resumed during 2021 and by spring 2022 all the regions had been able to organise a presentation of this type. To facilitate the application of this Order, a working group had started, at the same time as drafting the Order of 29 November 2019 amended, preparing a joint guide to be issued by ASN/SHFDS (Service of the Defence and Security High Official) of the MTE, for persons/entities responsible for nuclear activities and for the ASN and SHFDS inspectors. This guide should provide for a common understanding of the requirements of the Order by the professionals and inspectors alike. It provides recommendations and numerous examples. Detailing certain elements of the appendices of the Order, it is subject to targeted and controlled distribution (dispatch in double envelope with acknowledgement of receipt). To supplement the information for professionals, a brochure intended for persons/entities responsible for nuclear activities who are in possession of category D sources only (for which the number of regulatory obligations is limited) has been prepared and made available in each of the ASN regional divisions. This brochure is also available on asn.fr. 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% 70% 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 correspond to the IAEA category 1 sources. The Public Health Code category B sources correspond to: – the IAEA category 2 sources, – the IAEA category 3 sources contained in a mobile or portable device. The Public Health Code 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 2022 247 08 • 08 • Sources of ionising radiation and their industrial, veterinary and research applications 01 07 13 AP 04 10 06 12 14 03 09 05 11 02
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