- 197 - by the temporary worker has no influence on the dose that he or she can still receive on the occasion of a new contract." In 2010, according to figures provided by EDF, the trades identified as being the most exposed to ionising radiation are the heat insulators (2.88 mSv/an), welders (1.68 mSv/year), technical checkers and inspectors (1.79 mSv/year), mechanics and boilermakers (1.61 mSv/year) and the nuclear logistics personnel (1.55 mSv/year). On average, the contractor staff received a dose of 1.67 mSv/year, as opposed to 0.52 mSv/year for the employees of the EDF nuclear power generation division. With regard to the occupational safety of the personnel of the contractor companies, EDF points out that most accidents recorded involved people falling over and injuries related to handling operations and were very rarely related to industrial risks (burns caused by steam, electrocution and so on.). EDF also details a programme of actions, including the creation on each NPP of a Joint Contractors Safety and Working Conditions Commission (CIESCT) and a occupational safety motivation programme for contractor staff, so far organised on 15 sites. EDF announces that it is taking long-term measures to improve the skills of the employees of the contractor companies, in particular to help them boost the professional levels of their management, improve recruitment and enhance staff loyalty. For example, EDF has set up a contractor management academy, has created a complete nuclear environment training curriculum in partnership with the Ministry of National Education and is promoting the nuclear professions and trades. Article R. 4451-117 of the Labour Code states that the "occupational physician participates in informing the workers about the potential health risks of exposure to ionising radiation as well as about the other risk factors liable to aggravate them". The EDF staff are monitored by the NPP occupational physician and the staff of the contractor companies by the occupational physician of these companies. ASN considers that the EDF staff and the employees of outside contractors may not receive the same level of information, in particular regarding the potential health risks of exposure to ionising radiation. ASN considers that, in accordance with the provisions of article L.4522-1 of the Labour code55, EDF must ensure that the outside contractors working on the site take the defined preventive measures, in particular that appropriate information about the risks of ionising radiation is indeed provided by the occupational physicians of the contractor companies. The conditions for intervention by contractors in a Radiological Emergency (SUR) are discussed in § 6 Severe accident management. To conclude, ASN considers, on the basis of the CSA reports, that the steps taken by EDF to ensure good working conditions for the contractor companies are on the whole satisfactory. However, the analysis made by the licensees of events involving contractors needs to be taken further, in particular looking more closely at the corresponding working conditions. ASN will be asking EDF for additional information to assist with the evaluations carried out at its request by IRSN and the GPR, on the subject of safety and radiation protection management during reactor outages and the oversight of subcontracting. 7.2.3 Monitoring of subcontracted activities The ASN specifications require a description of how subcontracted activities are monitored, in particular how the licensee continues to exercise its responsibility for nuclear safety and radiation protection. The order of 10th August 1984 states that the licensee shall monitor its contractors and check the correct working of the organisation adopted, to guarantee quality. In the CSA reports, EDF explains that the purpose of monitoring is to identify situations that are potentially prejudicial to quality, to reduce the probability of nonconformity and, as applicable, to restore conformity in the best quality and lead-time conditions. This monitoring, which involves spot checks, is covered by an organisation specific to each EDF nuclear site, using 55 Article L4522-1 of the Labour Code: "In the establishments mentioned in article L. 4521-1, when a worker or the head of an outside company or an independent worker is required to carry out work with potential particular risks owing to its nature or to the proximity of this facility, the head of the establishment of the user company and the head of the outside company jointly define the preventive measures as required by articles L. 4121-1 to L. 4121-4. The head of the establishment of the user company ensures that the outside company abides by the measures that it is the latter's responsibility to apply, in the light of the specific nature of the establishment, prior to performance of the work, during the course of the work and following its completion".
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