with radiation protection rules, or operating incidents. Furthermore, it is often carried out on work sites under difficult conditions (working at night, or in places that are exposed to the elements, or in cramped spaces, etc.). On this account, it is an activity with serious radiation protection implications that figures among ASN’s inspection priorities. Industrial X-ray radiography Industrial X-ray radiography devices are very varied, ranging from fixed devices (integrated in a facility of very variable size) to mobile devices which can be used equally well in worksite conditions as in a facility. In application of the principle of optimisation, they must be used instead of gamma radiography devices when the Retrospective on the inspections relating to the protection of ionising radiation sources against malicious acts 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; the number of indicators has therefore evolved in line with the entry into effect of these various requirements. 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 RNAs in the medical sector do not possess, as they prefer to subcontract transport operations to their source suppliers. In the industrial sector it can happen that the vehicle is not available on the day of the inspection or that the transport operation has been subcontracted. • Out of all the inspection items, four concern questionnaires stemming from obligations figuring in the non-published appendices of the Order of 29 November 2019 amended. As this is sensitive information, it cannot be addressed in a publication. • The changes indicated in the medical sector must be taken with caution as the number of inspections dedicated to malicious acts is relatively small. • The figures compare the values for the years 2020 to 2023 with those recorded in 2024. The figures for 2019, considered old, are no longer taken into account. Some inspection items were nevertheless put in place after 2020, because they concern provisions which did not enter into application until 2021 or 2022. In such cases the findings for 2024 are compared with the average for the years 2021 to 2023 for indicators 3 and 4 and 2022 to 2023 for indicators 5 and 6. 1. Classification of radioactive sources or batches of sources In 2024, nearly 90% of the inspections performed in industrial facilities raised no comment on this point. This good result is very much the same as the findings over the previous four years, which witnessed a continuous improvement in conformity. The conformity of the medical facilities inspected in 2024 is identical to that of the industrial facilities. It is also identical to the result of the previous years. This is that indicator that obtains the highest score of conformity and the number of sites that have not yet classified their sources is therefore very small. The fact that some sites do not have a classification leads obligatorily to nonconformities because it is this classification that is the basis for the deployment of the technical provisions of the protection plan against malicious acts which is applicable since 1 July 2022. 2. Nominative authorisations These are delivered by the RNA 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 2024, half of the nominative authorisations issued raise no observations. This result is comparable with the values recorded in the previous four years. A similar level has been found in the medical sector, even though it would in principle seem more difficult to comply on this point given the large staff numbers concerned and the very nature of the facilities whose function is to receive the public. It also noteworthy that the number of critical situations (no authorization issued) has again been found in five facilities, all in the industrial sector. To conclude, the industrial sector must make further efforts to comply with this provision. 3. Policy of protection against malicious acts This indicator makes it possible to determine the senior management’s involvement in the change necessary for all the personnel to acquire a security culture, including in terms of cybersecurity, 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. More than two thirds of the sites in the industrial sector are found to be in compliance in this respect. This is a great improvement compared with the last three years. Only one facility in two in the medical sector was considered to comply correctly with this provision. A slight improvement is nevertheless noted. 4. Identification and control of sensitive information In 2024, slightly over half the industrial facilities had a procedure in this respect which was correctly applied and raised no comments. This is a slight improvement on the findings over the last three years. Nevertheless, in nearly one company in five inspected in 2024 this question is not addressed. The level of conformity in the medical sector is similar. This is an improvement compared with the previous four years and in particular with respect to the situation observed in 2023. 5. Principle of barriers This inspection item concerns the identification by the site RNA of the barriers to be protected. If this is not done, the RNA cannot make any effective reinforcements that might be necessary, which can result in additional delays and costs. Slightly over half the industrial sites inspected in 2024 are considered to have clearly identified “barriers”. This figure is very similar to what has been observed over the last two years. In the medical sector, however, this indicator is poor, with the barriers clearly identified in only about one situation in four in 2024. This result is distinctly poorer that in the previous two years and showing the greatest deterioration of all the tracked indicators. 6. 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 electronic equipment requires maintenance to prevent failures. It is therefore vital to establish a verification programme and comply with it. Such a programme existed in the industrial sector in 2024 but was implemented in just slightly over 40% of the inspected companies, a level which is about 10% higher than in 2022-2023. In slightly under a third of the companies inspected in 2024, however, there was no maintenance plan. One third of the medical sites inspected have a maintenance plan that is correctly implemented, a figure that is comparable with the preceding years. The inspections in 2024 nevertheless confirmed that in slightly less than half the sites this question was not addressed at all, exactly the same proportion as in the previous two years. 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”. This indicator (along with the previous one for the medical sector) is the one with the greatest room for improvement. 262 ASN Report on the state of nuclear safety and radiation protection in France in 2024 Sources of ionising radiation and their industrial, veterinary and research applications
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