Since 2019, when ASN inspects facilities where sealed radioactive sources of category A, B or C are present, whether individually or in batches, it checks compliance with the regulations relative to the protection of sources against malicious acts. National administrative tracking indicators have been put in place. This administrative tracking has been adapted to take account of the gradual entry into effect of the requirements of the Order of 29 November 2019 amended. On 1 January 2021, the number of indicators increased from the initial four to six, all relative to organisation. On 1 January 2022, two indicators were abandoned and replaced by five new indicators concerning the installed technical protection devices. Altogether, the number of inspection items – which depends on the activity – is 10 at the most: the technical devices are more numerous for category A or B sources or batches than for category C; moreover, certain inspection items address transport vehicles which the majority of RNAs do not possess, as they prefer to subcontract transport operations. Notes: 1° Out of all the inspection points, four concern questionnaires stemming from obligations figuring in the non‑published appendices of the Order of 29 November 2019 amended. Consequently, they cannot be addressed in a publication. 2° The changes indicated in the medical sector must be taken with caution as the number of inspections dedicated to malicious acts is relatively small. 3° The aggregate of the responses since 2019 gives some hindsight, but only the first two indicators aggregate five years of results. The others have only been tracked for two or three years. Classification of radioactive sources or batches of sources The findings of 2023 are compared with the aggregated results for the years 2019‑2022 for this indicator and the following one. In 2023, nearly 90% of the inspections performed in industrial facilities raised no comment on this point. None of the remaining facilities had taken any action. This good result for 2023 is an improvement of 33% on the findings made over the 2019‑2022 period. Likewise, 90% of the medical centres inspected in 2023 have classified their sources. The increase in compliant situations in 2023 compared with the previous four years is more than 20%. The number of sites that have not yet classified their sources is therefore low. The situation obligatorily leads to nonconformities, since this evaluation is the basis for determining the technical provisions of the protection plan against malicious acts which is applicable since 1 July 2022. Nominative authorisations These are delivered by the nuclear activity licensee to allow access to the sources, their carriage, or access to the information relating to the means or measures that protect them. In the industrial facilities inspected in 2023, 60% duly issued the necessary authorisations. This result is identical to last year, but represents an improvement of 40% with respect to what had been examined between 2019 and 2022. The percentage of situations without any authorisation observed in 2023 is marginal (about 5%). The situation can nevertheless be further improved in a third of the cases for 2023. The situation in the medical sector in 2023 is comparable with that of the preceding year, with one case out of two found compliant. In medical facilities however, far more people can have access to radioactive sources than on industrial sites, and the increase in compliant situations observed last year compared with the preceding years is continuing. Policy of protection against malicious acts This indicator (and the following one) was not put in place until 2021 since a general statement of management’s commitment regarding protection against malicious acts and its distribution was not required by the regulations until 1 January 2021. This provision contributes to establishing a corporate security culture, including in terms of cyber security, which is a long process by nature. Such a statement signed by senior management is not enough in itself, but it must allow the initiation of an acculturation process that makes all the personnel aware of the question of malicious acts. The industrial sector has such a policy, and prompted no observations in half the cases in 2023; the absence of a policy was noted in just 15% of the situations. There is a slight increase in the number of facilities that raised no comments compared with the two preceding years. In the medical sector, about a quarter of the sites inspected in 2023 have a statement from management that raised no observations, a figure that is considered all the poorer given that nearly half the sites did not have a general policy to present. This was already the finding last year. It could partly explain the fact that the majority of the other indicators are poorer in the medical sector than in the industrial sector. Identification and control of sensitive information In 2023, 40% of the industrial facilities inspected had a procedure on this theme that was correctly applied. This figure is lower than it was last year and stable if compared with the aggregated findings over the preceding years (2021 and 2022). In a third of the situations in 2023 there was no documented procedure. In the medical sector, 50% of the facilities had no document addressing this question. This percentage is identical to those of the preceding years. Principle of barriers This inspection item concerns the provisions with regard to break‑in resistance, which is now based on precise criteria. This indicator and the following one, whose obligations came into force in 2022, can therefore only be compared with the latter. Two thirds of the industrial sites inspected are considered to have “clearly identified “barriers”. This is a great improvement on last year, where this indicator showed about 40% of compliant situations. This percentage is improving in the medical sector, rising from 50% of the inspected facilities in 2022 to more than 70% in 2023. Therefore, although there is still room for improvement, it is to be noted that none of the sites inspected in 2023 had taken no protection measures. Maintenance of technical protection systems The systems adopted to protect against malicious acts necessitate the installation of detectors forming part of a chain of components allowing surveillance of the site. This equipment requires maintenance to prevent failures. It is therefore vital to have a verifications programme. Such a programme exists in the industrial sector but is only implemented in a third of the inspected companies, exactly the same level as in 2022. In half the situations, the subject is not addressed at all. The remaining cases correspond to situations where a programme exists but is poorly applied or is inappropriate. The situation in the medical sector is better. Slightly over half the inspected sites have a maintenance plan, but in 25% of the cases the question has not been addressed at all. The remaining 20% or so of the facilities inspected in 2023 have a plan that is inappropriate or poorly applied. While maintenance is an everyday function in industry and for the devices used in brachytherapy, these low levels indicate that the protection devices are monitored less rigorously than the “work tool”. RETROSPECTIVE ON THE INSPECTIONS RELATING TO THE PROTECTION OF IONISING RADIATION SOURCES AGAINST MALICIOUS ACTS ASN Report on the state of nuclear safety and radiation protection in France in 2023 259 • 08 • Sources of ionising radiation and their industrial, veterinary and research applications 08 05 15 11 04 14 06 07 13 AP 03 10 02 09 12 01
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