ASN and the DGT support the HERCA initiative to harmonise monitoring procedures for workers exposed to ionising radiation

ASN, the French Nuclear Safety Authority, and the DGT, France’s Directorate-General for Labour, support the HERCA initiative to promote implementation of an EC-wide system for monitoring exposure to ionising radiation given the context of the free movement of workers across Europe.

ASN and the DGT made some comments on implementing the system proposed under HERCA in France, mainly regarding the “hardcopy” format of the proposed radiological monitoring document (not suited to the need to constantly update information), the scope of application (it should be extended to all workers exposed to ionising radiation), its content, which should focus on operational monitoring, and the need to examine the compatibility of this document with national regulations regarding the confidentiality of certain individual dosimetric data.

 ASN and the DGT therefore propose two interrelated initiatives:

 - the first, at European level, consisting in encouraging HERCA to pursue discussions on the feasibility of using an electronic data exchange system to which the centralised systems of each Member State can be connected;

 - and the second, at national level, aimed at thinking about the changes in regulatory provisions governing dose monitoring procedures. To this end, a working group is being established, whose work will be defined in line with that of the COCT, the Working Conditions Committee. This work will be integrated in upcoming debates on transposing the future Euratom directive into national law.

 The position statement taken by ASN and the DGT can be seen as continuing the vast consultation process undertaken in France by ASN as part of the HERCA initiative.

 In the context of its studies relative to radiological protection for outside workers¹, HERCA has adopted a draft document on radiological monitoring (the “radiation passbook”) which will improve operational protection of workers exposed to a risk of ionising radiation when working in controlled areas. This document will satisfy the requirements of Directive 90/641 EURATOM.

On the basis of this draft document, the radiological protection competent authorities have decided to launch, at national level, a consultation of the stakeholders involved. In France, in addition to asking the IRSN for its technical opinion as the administrator of SISERI, the information system for monitoring exposure to ionising radiation, and coordination with the public administration (DGT), ASN has undertaken a consultation, since September 2010, with:

• ASN Advisory Committees for radiation protection (GPRAD opinion);
• labour/management partners that sit on the COCT, particularly the representatives of trade unions (COCT opinion).

Extract from Directive 90/641/EURATOM: outside worker: “means any worker of category A, (…), performing activities of any sort in a controlled area, whether employed temporarily or permanently by an outside undertaking, including trainees, apprentices and students within the meaning of Article 10 of that Directive, or whether he provides services as a self-employed worker”; outside undertaking: “means any natural or legal person, other than the operator, including members of his staff, performing an activity of any sort in a controlled area.”