THE INDUSTRIAL, VETERINARY AND RESEARCH SECTOR The licensees of the industrial, veterinary and research sector are characterised by their diversity: they are numerous and carry out their activities in structures of widely varying size and status; they also use ionising radiation sources for a wide variety of applications. With regard to radiation protection, ASN’s assessment of these licensees is to a large extent comparable to that of previous years. Among the nuclear activities in the industrial sector, industrial radiography and more particularly gamma radiography are priority sectors for ASN oversight owing to their radiation protection implications. ASN observes that the vast majority of companies maintained the necessary degree of rigorousness to meet the regulatory obligations concerning the organisation of radiation protection, training and dosimetric monitoring of the workers, the use of operators holding the required Certificate of proficiency in handling industrial radiology devices (CAMARI) and maintaining gamma radiography devices. However, significant efforts are still required on the part of many companies to correctly define the programme of verifications required by the Labour Code, implement it, correct any nonconformities found on this occasion and ensure the traceability of the corrections made. If the risk of incidents and the doses received by the workers are on the whole well managed by the licensees when this activity is performed in a bunker in accordance with the applicable regulations, ASN is still concerned by the observed shortcomings in the signalling of the operations area during on-site work, even if a slight improvement in relation to 2022 is observed. ASN underlines that the lack of preparation and cooperation ahead of the work, between the ordering customers and the radiography contractors, is frequently one of the causes of these nonconformities. Progress is in particular needed regarding the content of the prevention plans, and familiarity with and implementation of the provisions contained in them. More generally, ASN considers that the ordering parties should, whenever possible, give priority to industrial radiography services in bunkers and not on the worksite. In the other priority sectors for ASN oversight in the industrial sector (industrial irradiators, particle accelerators including cyclotrons, suppliers of radioactive sources and devices containing them) the state of radiation protection is considered to be on the whole satisfactory. With regard to suppliers, ASN considers that advance preparations for the expiry of the sources administrative recovery period (which by default is ten years), information for the purchasers regarding future source recovery procedures, and the checks prior to delivery of a source to a customer, are areas in which practices progressed by comparison with 2022, but still need to improve further. As for the distributors of accelerators or X-ray emitting devices, the monitoring tools that they put into place to identify the devices distributed and who acquired them often need to be reinforced, to avoid compromising any recall or OEF processes. The actions carried out by the licensees in recent years are continuing to improve radiation protection within the research laboratories. This is to a large extent based on the involvement of the RPAs and depends on the resources placed at their disposal. It should be recalled that the radiation protection issues in many research laboratories tend to be small or are decreasing owing to the use of techniques other than those using ionising radiation. The conditions for the storage and elimination of waste and effluent remain the primary difficulties encountered by the research units or universities, including with regard to the performance and traceability of checks prior to elimination, the recovery of “legacy” unused sealed radioactive sources or the regular elimination of stored radioactive waste. On these latter points, the lack of forward planning for the funding needed to manage “legacy” sources or waste and their prior characterisation if necessary, is often observed. Finally, the facilities are also still experiencing difficulties in taking on board and correctly implementing checks on equipment, workplaces and instrumentation, as a result of changes to the Labour Code and Public Health Code in 2018, in particular in the case of joint research units. With regard to the veterinary uses of ionising radiation, ASN can see the results of the efforts made by veterinary bodies over the past few years to comply with the regulations, notably in conventional radiology activities on pets. For practices concerning large animals such as horses, or performed outside veterinary facilities, ASN considers that the implementation of radiological zoning and the radiation protection of people from outside the veterinary facility who take part in the radiographic procedure, are points requiring particular attention. With regard to the protection of sources of radiation against malicious acts, more particularly when high-level radioactive sources or batches of equivalent sources are used, the inspections conducted by ASN show that the licensees are gradually implementing the measures needed to comply with the requirements set out in the Order of 29 November 2019. Thus, on the basis of the inspections performed in 2023: ∙ source categorisation, an essential step in identifying the applicable requirements and implementing an approach proportionate to the risks, was carried out by the vast majority of facilities; ∙ in half of the industrial facilities and one third of the medical facilities, ASN has no comments regarding the source protection policy, supported by the facility’s general management and promoting the concrete measures to be taken; ∙ if all the facilities inspected have taken steps to protect the sources, about one third of them had not formally identified the physical barriers guaranteeing this protection, or demonstrated that they offered adequate intrusion resistance; ∙ in half of the cases, no preventive maintenance programme is defined for the equipment designed to detect intrusions; ∙ the issue of nominative permits for access to sources has barely progressed by comparison with 2022 and still needs to be implemented in nearly half the facilities; ∙ half of the facilities do not take steps to identify and protect sensitive information concerning source security. ASN therefore considers that considerable progress is still needed. In 2024, ASN will continue its actions to raise licensee awareness on these subjects. 28 ASN Report on the state of nuclear safety and radiation protection in France in 2023 ASN assessments
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