IRRS follow-up mission to France - October 2017

50 Suggestion 25: A specific workshop was organized by ASN in December 2016 on the issue of the practical implementation of the ALARA principle, involving stakeholders and ASN inspectors. The experience from BNIs was presented and the opportunity and feasibility to extend this approach, particularly to interventional radiology, were discussed. The need for specific guidance in interventional radiology was underlined, but the reinforcement of the regulatory framework was also suggested. ASN gathered information and considered the need for providing guidance on a graded approach of the implementation of the optimization principle. In 2017, ASN requested to its advisory Committee for Medical Exposure (GPMED) to prepare recommendations on this topic and the issue of guidance will be discussed in 2018 in consultation with the Ministry of Labour. On 14 March 2017, ASN produced a resolution concerning the permanent training of professionals on radiation protection of people exposed to ionizing radiations for medical purposes. The objective n°4 in art.4 of this resolution deals with the training of radiologists in optimization. Similar objectives are also presented for other medical areas. This resolution will allow for the further development of training guides by the scientific societies. These guides will have to be approved by ASN. Recommendation15: The decree in preparation modifying the Labour Code, for the transposition of the European directive 2013/59/EURATOM “BSS”, specifies that radiation protection inspectors are authorized to enforce the requirements expressed within the Labour Code concerning the radiation protection of workers (new article L.1333-30 of the Public Health Code). Therefore, ASN radiation protection inspectors will have access to the necessaryelements and data to perform this control, which includes access to workers’ effective doses and external doses, included in the national dose register SISERI (Information System on Exposure to Ionizing Radiations). According to this decree, the Radiation Protection Advisor (RPA) (covering both Radiological Protection Expert (RPE) and Radiation Protection Officer (RPO) as expressed within the European directive) has direct access to the workers’ effective doses and external doses in the national dose register. Concerning internal doses, the Ordinance n° 2016-128 issued on 10 February 2016 allows the RPA to get any information relevant for occupational radiation protection and covered by medical confidentiality from the occupational physician: “Art. L. 4451-2. – By way of exception to article 226-13 of the Penal Code, the occupational physician can transmit to the person designated by the employer to advise said employer with regard to occupational radiation protection, all elements or information covered by professional secrecy on condition that their transmission is limited to those strictly necessary for the exercise of the person's duty.” "Art. L. 4451-3. – The person designated by the employer to advise said employer with regard to occupational radiation protection is bound by professional secrecy subject to the penalties and under the conditions provided for in articles 226-13 and 226-14 of the Penal Code, with respect to the data covered by the obligation of professional secrecy which were communicated to himby the occupational physician in application of article L. 4451-2.” Considering the constructive evolution since the first IRRS mission in 2006 and the second IRRS mission in 2014 and the changes which have to be made in the legal framework (new Article L. 1333-30 of the PHC), the team considers that, under the coordination of ASN and in close co- operation with IRSN, full compliance with these new legal requirements could be achieved in the coming months.