2016–17 Annual Report - Part 3: Report on performance

Introductory statement

I, as the accountable authority of the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), present the 2016–17 Annual Performance Statement of ARPANSA, as required under paragraph 39(1)(a) of the Public Governance, Performance and Accountability Act 2013 (PGPA Act). In my opinion, this annual performance statement is based on properly maintained records, accurately reflect the performance of the entity, and comply with subsection 39(2) of the PGPA Act.

Carl-Magnus Larsson
Accountable Authority
21 August 2017

Purpose - to protect the Australian people and the environment from the harmful effects of radiation

Program – Radiation protection and nuclear safety
Program objectives
Program activities intended to benefit the Australian community and the environment will be delivered under the following strategic objectives

1. Protect the public, workers and the environment from radiation exposure.

2. Promote radiological and nuclear safety and security, and emergency preparedness.

3. Promote the effective use of ionising radiation in medicine.

4. Ensure the effective and proportionate regulation and enforcement activities.

Enabling capabilities
Delivery against these strategic objectives is supported by whole of entity enabling capabilities

People Governance Infrastructure Technology Stakeholder engagement

Overarching analysis of performance against ARPANSA’s purpose

ARPANSA’s Corporate Plan 2016–2020 provides the underlying framework for this annual performance statement. The corporate plan brings together the measures and projects that support the achievement of our purpose and strategic objectives as well as enhancing our supporting capabilities.

Over the course of the reporting period, ARPANSA achieved or partially achieved all 23 targets. We made many steps forward to contribute to delivering enhanced radiation protection and nuclear safety outcomes to the Australian community and environment. Highlights include:

  • eight organisations are now submitting worker exposure records to the Australian National Radiation Dose Register
  • emergency preparedness and response plans have been tested through participation in a 36 hour international exercise coordinated by the International Atomic Energy Agency
  • over 1500 diagnostic reference level surveys have been completed to promote patient protection through an optimised range of radiation exposures for specific medical imaging protocols
  • more efficient and transparent regulation of Commonwealth licence holders under the Regulator Performance Framework.

We have made this progress despite some challenges along the way:

  • the continued focus on efficiency dividends and average staffing level ceiling impacts on the agency’s ability to discharge our responsibilities
  • the enterprise bargaining has been prolonged and resulted in the agreement being voted down mid-way through the reporting period and a return to the negotiations
  • our stakeholder engagement in relation to the proposed establishment of a National Radiation Waste Management Facility is unfunded but is at the very core of our purpose and program objectives
  • the Shared and Common Services Program presents challenges for planning of technology investment to avoid duplication with the provider’s service offering.

A summary of performance against the measures and projects outlined in the ARPANSA Corporate Plan 2016–20 and the analysis of this performance is provided against each strategic objective and supporting capability in the following sections.

Objective 1 - Protecting the public, workers and the environment from radiation exposure

No. Measure Target Source Annual Result
1.1 Develop high quality advice for the Australian Government and other stakeholders on radiation protection issues Relevant, evidence‑based advice developed and provided in a timely manner PBS (portfolio budget statement) 2016–17, page 245
ARPANSA Corporate Plan 2016–20, page 11
Achieved
1.2 Monitor radiation doses to occupationally exposed workers including uranium mining workers Annual reporting of trend in radiation does received by workers determined from quantitative dose measurement provides evidence of optimisation of radiation protection PBS 2016–17, page 245
ARPANSA Corporate Plan 2016–20, page 11
Achieved
1.3 Number of organisations submitting worker exposure records to the Australian National Radiation Dose Register Eight PBS 2016–17, page 245
ARPANSA Corporate Plan 2016–20, page 11
Achieved

Analysis of performance against purpose and program objective

In 2016–17 ARPANSA continued to provide advice, specialised resources, and services to support protection of the public, workers and the environment from the harmful effects of ionising and non-ionising radiation. 
ARPANSA achieved this by:

  • increasing the number of organisations submitting worker exposer records to the Australian National Radiation Dose Register (ANRDR) from six organisations to eight, with dose records for over 38 000 workers now held
  • publishing ANRDR in Review, the annual report of the ANRDR (September 2016)
  • publishing the Wi-Fi in Schools Study (January 2017)
  • responding to 455 ‘Talk to a Scientist’ program phone call enquires during the program hours, and 441 emails within five working days
  • reviewing and maintaining 104 frequently asked questions and 36 fact sheets on the ARPANSA website
  • transitioning our Personal Radiation Monitoring Service from the reliable but slow thermoluminescent dosimetry technology to the state‑of‑the‑art beryllium oxide Optically Stimulated Luminescence technology (July 2016). In the first year of operation over 171 000 client dosimeters were issued, and 16 800 dose reports were produced
  • compiling the final report of the evaluation of the solar ultraviolet radiation (UVR) prevention SunSmart application for mobile devices. This  improves the public’s ability to make informed decisions about reducing risk of skin cancer and other diseases related to solar UVR exposure
  • modernising the UVR network infrastructure and developing new UVR index graphs published on the updated ARPANSA website. This has enabled expansion of the UVR network and establishment of short-term pop-up monitors during special events in the future
  • supporting the World Health Organization (WHO) to publish the advice Artificial‑tanning devices: public health invention to manage sunbeds. The guide reflects Australia’s position to ban sunbeds for commercial use as best practice. ARPANSA is a WHO Collaborative Centre in Radiation Protection
  • testing, assessing and assigning an ultraviolet protection factor (UPF) rating to 2100 samples of sun protective clothing, hats, sunglasses and other sun protective materials 
  • issuing over three million UPF swing tags2 for sun protective products. 
     

Objective 2 - Promoting radiological and nuclear safety and security, and emergency preparedness

No. Measure Target Source Annual Result
2.1 ARPANSA is prepared for a radiological or nuclear incident or emergency Emergency preparedness and response systems for field, network and laboratory measurements, and information management and decision support systems are available, calibrated, tested and aligned with national planning PBS 2016–17, page 245
ARPANSA Corporate Plan 2016–20, page 13
Achieved

Analysis of performance against purpose and program objective

ARPANSA’s commitment to test the adequacy of our emergency preparedness arrangements and capability by participating in exercises both internally and with other agencies has remained strong during the 2016–17 reporting period. Our commitment was demonstrated (and our capabilities tested) through participation in a 36 hour IAEA Convention Exercise, known as ConvEx-3. This was the first full-scale exercise of this type for ARPANSA. 

Eighty countries, ten international organisations and five Australian federal government agencies and partners participated in the exercise that tested:

  • full activation of ARPANSA’s Incident Management Plan
  • our modelling and communications capabilities
  • interactions with IAEA, WHO and the Australian Government
  • interactions between our WHO Radiation Emergency Medical Preparedness and Assistance Network (REMPAN) collaborating centre partners
  • sample testing and coordination between laboratories in the Australasian Radioanalytical Laboratory Network (ARLN).

ARPANSA also participated in smaller exercises throughout the reporting period. Various opportunities for improvement, to enhance our preparedness for a radiological or nuclear incident or emergency, were identified during these exercises. The agency aims to ensure these lessons are captured and improvements are incorporated into existing emergency plans.

Other ARPANSA activities that promoted radiological and nuclear safety and security, and emergency preparedness included:

  • upgrading the Australian Radiation Incident Register (ARIR) and collaborating with state and territory regulators to ensure that incidents are captured and learnings shared across Australia. In the 2016 calendar year, 378 incidents were reported3
  • facilitating the final training course for the National Radiation Security Advisor Accreditation Scheme, providing state and territory regulators with a pool of nationally trained security assessors in order to implement ARPANSA’s Radiation Protection Series 11 – Code of Practice for the Security of Radioactive Sources (2007), in a nationally consistent manner
  • operating seven particulate radionuclide monitoring stations and two noble gas monitoring stations that form part of the Comprehensive Nuclear-Test-Ban Treaty Organization International Monitoring System with > 95 per cent data availability
  • integrating safety and security plans and arrangements into the regulatory compliance and enforcement regime to form an integral part of the inspection program
  • maintaining 24/7 point of contact for stakeholders with > 95 per cent availability
  • providing input into national emergency preparedness and response arrangements
  • promoting the ARLN resulting in increased collaboration and methodological harmonisation
  • overseeing the import and export of radioactive materials across our borders through the assessment and issuing of permits and providing advice to stakeholders
  • meeting performance targets in five proficiency testing programs, designed to assess our performance in conducting radio-analytical test methods against other laboratories that participate worldwide in the same programs.

Objective 3 - Promoting the effective use of ionising radiation in medicine

No. Measure Target Source Annual Result
3.1 Number of Diagnostic Reference Level Surveys per annual survey period > 1000 PBS 2016–17, page 246
ARPANSA Corporate Plan 2016–20, page 15

Achieved

1550

3.2 Percentage of Australian Radiotherapy Providers participating in the national dosimetric auditing program provided by the Australian Clinical Dosimetry Service > 80% PBS 2016–17, page 246
ARPANSA Corporate Plan 2016–20, page 15

Achieved

> 90%

3.3 Percentage of Australian Radiotherapy Providers covered by ARPANSA dose calibration services > 70% PBS 2016–17, page 246
ARPANSA Corporate Plan 2016–20, page 15

Achieved

73%

Analysis of performance against purpose and program objective

In 2016–17, ARPANSA promoted the safe and effective use of ionising radiation in medicine through three major programs summarised below, and through interaction and engagement with the medical profession.

Diagnostic reference level (DRL) surveys:

  • DRL surveys demonstrate to clinics how they compare to equivalent clinics across Australia; if they use more radiation than the majority of clinics, they will feel compelled to optimise their procedures to achieve improved patient protection.
  • The engagement from the profession with these surveys exceeded the target by 50 per cent.
  • A nuclear medicine DRL program was released in consultation with key professional and clinical stakeholders.
  • Engagement with university medical departments is creating more opportunities to educate the Australian medical community about radiation risks and measurement techniques.
  • The medical community recognises the positive patient safety benefit of engaging with the DRL program and reducing patient dose.

Australian Clinical Dosimetry Service (ACDS):

  • At 2016 year-end, over 90 per cent of Australian radiotherapy providers were participating in the national dosimetric auditing program provided by the ACDS.
  • Following the transition to a user-pays funding model for the ACDS, more than 50 per cent of clinics across Australia have signed service level agreements and another 20 per cent are in the final negotiations.
  • ACDS audits resulted in 22 recommendations to Australian clinics leading to changes in equipment and clinical practices.
  • Coverage of clinics by ACDS is pivotal to promote the effective use of ionising radiation in medicine and ensuring the safety of all patients undergoing radiotherapy for cancer treatment.

Radiotherapy calibrations:

  • Seventy three percent of Australian radiotherapy providers are covered by ARPANSA dose calibration services.
  • ARPANSA maintains the Australian primary standards for ionising radiation, including absorbed dose for radiotherapy, and disseminates the standards to clinical practices.
  • Dissemination is achieved through ARPANSA’s calibration service, which ensures that the equipment used by hospitals to adjust the output of their own therapy equipment is accurate.
  • National demand and participation in ARPANSA’s calibration services has exceeded the target during the reporting period. The target is based on international recommendations.
  • The participation rate demonstrates the national regard for the service, recognising its fundamental contribution to high quality and safe patient treatment.

In addition to providing these services, APRANSA has:

  • facilitated an annual Practical Reference Dosimetry Course for external beam radiotherapy for the past three years
  • become the recognised national authority on small field dosimetry; this is a key area of expertise with an increasing clinical implementation.

Objective 4 - Ensuring effective and proportionate regulation and enforcement activities

No. Measure Target Source Annual Result
4.1 Percentage of licence applications assessed within the time agreed with licence holder >90% PBS 2016–17, page 246
ARPANSA Corporate Plan 
2016–20
, page 17 -
Regulator Performance Framework (RPF) KPI 1

partially achieved, criterion changed or removed

79% 
A number of factors that affect this indicator are outside the agency’s control. The measure was removed from the 2017–18 PBS and 2017–2021 Corporate Plan. The measure was retained in the 2017–18 RPF with a revised target of 75%.

4.2 Number of improvements to the regulatory framework implemented by ARPANSA, identified through self‑assessment or external reviews such as the Integrated Regulatory Review Service conducted by the IAEA Three or more PBS 2016–17, page 246
ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 6

Achieved

Three

4.3

Percentage of inspections conducted in accordance with established inspection schedule >90% PBS 2016–17, page 246
ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 1

partially achieved, criterion changed or removed

86%
The agency’s performance fell just short of the target because some inspections were not carried out due to factors outside of ARPANSA’s control; 92% of the inspections were conducted to schedule when such factors were taken into account. To accommodate for similar occurrences in the future, the target has been adjusted to 85% in the PBS, Corporate Plan and RPF from 2017–2018 and onwards.

4.4 Percentage of stakeholder inspection feedback in which the positive outweighs the negative >90% ARPANSA Corporate Plan 
2016–20
, page 17 - 
RPF KPI 2

partially achieved, criterion changed or removed

88%
Feedback received from the post‑inspection survey was overall positive and performance fell just short of the target. This measure has been amended in the 2017–18 RPF to include a score that can be trended over time and that captures a broader range of feedback methods.

4.5 Number of information sharing meetings with facility licence holders >20 ARPANSA Corporate Plan 
2016–20
, page 17 - 
RPF KPI 2

Achieved

32

4.6 Ratio of performance deficiencies to non-compliances during the inspections > 25:1 ARPANSA Corporate Plan 
2016–20,
page 17 -
RPF KPI 3

partially achieved, criterion changed or removed

16:1
This measure has been replaced in the 
2017–18 RPF with one that more accurately reflects a graded and proportionate regulatory approach. The current indicator is strongly affected by only a few non‑compliances. The quarterly ratio varied from 12:1 to 43:1 over the reporting period.

4.7 Ratio of site visits (monitoring) to inspections at licensed facilities > 4:1 ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 3

partially achieved, criterion changed or removed

3:1
This measure has been replaced in the
2017–18 RPF with one that more accurately reflects a graded and proportionate regulatory approach.

4.8 Percentage of inspections of licence holders with a medium to high-risk ranking > 70% ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 4

partially achieved, criterion changed or removed

56%
The intent of this measure was met as 76% of time spent on direct regulatory activities targeted medium and high risk licences. This measure was replaced in the 2017–18 RPF with one that measures the proportion of effort applied to areas of greatest risk.

4.9 Percentage of time that actions are initiated within three months of the issuance of a performance deficiency > 50% ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 4

Achieved

59%

4.10 Percentage of regulatory personnel time that is devoted to regulatory activities > 40% ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 5

partially achieved, criterion changed or removed

27%
This measure was replaced in the 2016–17 RPF as it only reflects direct regulatory work against specific licences carried out by staff in ARPANSA’s Regulatory Services Branch. It does not include important indirect activities, which contribute to safety among licence holders and will reduce the need for direct interventions in the longer term.

4.11 Percentage of instances in which licence holders are consulted on the development of guides, codes and standards > 90% ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 5

Achieved

100%

4.12 Percentage of facility inspections in which expertise external to ARPANSA was utilised > 30% ARPANSA Corporate Plan 
2016–20
, page 17 -
RPF KPI 6

partially achieved, criterion changed or removed

20%
External expertise can be used to supplement and enhance ARPANSA’s depth of knowledge and experience. This was not deemed necessary for many of the inspections conducted in 2016–17. This measure has been replaced in the 2017–18 RPF with a measure that reflects how well the agency contributes to the continuous improvement of regulatory frameworks.

Analysis of performance against purpose and program objective

We base all the measures and targets reported on above on the RPF, a Commonwealth-wide initiative that helps regulators report objectively on their efforts to administer regulation fairly, effectively and efficiently. As such, it also helps regulators to identify opportunities for improvement and to better target regulatory resources for greater impact. RPF performance indicators cover issues like communication, risk-based and proportionate approaches, transparency, reducing regulatory burden, and continuous improvement.

ARPANSA first obtained ministerial approval and implemented our RPF measures and targets for 2015–16, and subsequently each year performs a self-assessment against the targets. This year ARPANSA met, exceeded or made significant progress toward achieving the targets.

The first RPF self-assessment recommended a review of the RPF measures. We undertook this review in February 2017 and a revised set of measures were subsequently approved by the Minister to take effect from 1 July 2017. This is the last time ARPANSA reports against several of the targets listed above. The revised measures and targets enable ARPANSA to better assess our overall regulatory delivery and impact, and will support our program of continuous improvement. 

In addition to routine activities, ARPANSA has undertaken a number of projects and activities that will further improve our performance, including:

  • publication of the Code for Radiation Protection in Planned Exposure Situations (RPS C-1) and its promotion at events such as the Licence Holder Forum held in Canberra in June 2017
  • publication of the National Directory for Radiation Protection to include Amendment 7 (June 2017)
  • undertaking a cost recovery project to ensure that financial burden on licence holders is proportionate to the cost of regulation and that regulatory services are streamlined, efficient and effective, in accordance with the Australian Government Charging Framework
  • providing advice on regulatory requirements to the Department of Industry, Innovation and Science (DIIS) in relation to DIIS’ plans to establish a National Radioactive Waste Management Facility (NRWMF), including advice on waste management criteria, and other elements important to the safety case
  • publication of two documents outlining the regulatory approach to waste storage and disposal facilities in May 2017; Information for stakeholders and a Regulatory Guide: Applying for a licence for a radioactive waste storage or disposal facility
  • communicating with stakeholders in South Australia to inform them about ARPANSA’s role and assessment criteria in the licensing of a NRWMF, should plans to establish the facility be pursued
  • international engagement to take stock of and enhance the development of international risk assessments and standards, and to promote collaboration with regional partners. In 2016–17 this has included:
    • hosting delegations from Mongolia and Singapore
    • working with the safety standards committees of the IAEA on transport, waste and radiation safety, and on emergency preparedness and response; as well as the Commission on Safety Standards
    • activities related to the Convention on Nuclear Safety, the Joint Convention and the Code of Conduct on the Safety of Research Reactors
    • Integrated Regulatory Review Service missions to the Czech Republic and Estonia
    • participation in the International Commissions on Radiological Protection and Non-Ionizing Radiation Protection; and in activities of the World Health Organization and United Nations Scientific Committee on the Effects of Atomic Radiation
  • actively engaging in reviewing and continuously improving our regulatory processes. This includes embarking on a project to bring the inspection processes into line with ISO/IEC 17020
  • commencing self-assessment for the IAEA Integrated Regulatory Review Service mission to Australia in 2018, this mission will cover all Australian jurisdictions and ARPANSA has been providing assistance to state and territory radiation regulators.

Objective 5 - Capability

No. Measure Description and Estimated Completion Source Annual Result
5.1 Workforce Planning Strategy Develop a workforce planning strategy that includes recruitment, succession planning, performance feedback, leadership development, and training requirements. This ensures our workforce has the capability to meet future challenges of our operating environment.
June 2017
ARPANSA Corporate Plan 2016–20, page 20

Achieved

5.2 Project Management Framework Deliver an enhanced project management framework that will contribute to a more effective and efficient allocation of resources through improved governance and management of agency projects.
June 2017
ARPANSA Corporate Plan 2016–20, page 20

Achieved

5.3 Digital Strategy In response to key digital and social trends, create a digital strategy to harness opportunities, build business capability and transition information management and technology to support the agency’s vision.
May 2017
ARPANSA Corporate Plan 2016–20, page 20

Achieved

5.4 Stakeholder Engagement Framework This project represents ARPANSA’s ongoing commitment to work effectively with our stakeholders, learn from experiences and continue to improve performance. We will base the framework on the International Association of Public Participation (IAP2) spectrum and will seek to position stakeholder engagement as a priority across the agency and facilitate effective collaboration and knowledge sharing.
March 2017
ARPANSA Corporate Plan 2016–20, page 20 Achieved

Analysis of performance against purpose and program objective

The role of our supporting capabilities is to create a dynamic environment that enables and encourages excellence in services, research, advice, regulation and the utilisation of knowledge. Our enabling services work across the agency with all branches and offices to develop our people, governance, infrastructure and technology to ensure our systems and processes provide the appropriate capability to support achievement of our strategic objectives.

In 2016–17, ARPANSA undertook a significant review of its strategic planning framework, which included the development of two new strategic objectives to reflect the important work of our supporting capabilities:

  • strengthen engagement with community and government
  • enhance organisational innovation, capability and resilience.

These objectives have been included in our Corporate Plan for 2017–2021. We will measure and report on the performance of our supporting capabilities alongside our other four strategic objectives.
ARPANSA’s supporting capability assisted in the achievement of the strategic objectives through the following activities:

  • development of the ARPANSA Workforce Plan that comprises clear strategies across:
    • succession planning
    • attraction and recruitment
    • learning
    • performance and reward
    • diversity and inclusion
    • health and wellbeing.

This Workforce Plan sets out how ARPANSA can best place our capability to deliver against the agency strategic objectives. We will launch the plan in August 2017.

  • In June 2017 a new project management framework was delivered which aims to achieve a more effective allocation of resources through improved governance and management of agency projects. We established a Project Management Advisory Group to lead the implementation of the project management framework in 2017–18. The group will provide a centralised coordination and support function to agency projects.
  • In February 2017 the Digital Strategy was delivered which aims to shape and support digital initiatives, guide investment decisions and drive business transformation. We established a Digital Steering Committee to lead the execution of the Digital Strategy.
  • ARPANSA continues to progress work on a formal stakeholder engagement framework. The last financial year has seen considerable efforts to ensure that ARPANSA clearly defines the public participation goal for our stakeholder engagement activities, particularly with respect to major licensing decisions and consultation activities for the proposed National Radioactive Waste Management Facility. In 2016–17, ARPANSA underwent a limited assurance review of our current stakeholder engagement and communications processes to assess efficiency and effectiveness. The findings of this review will inform the development of a formal framework for future stakeholder engagement activities.


2. Swing tags with UPF ratings of 15, 20, 25, 30, 35, 40, 45, 50 and 50+ are issued by ARPANSA for use on garments or sunglasses tested in our laboratories.

3. The ARIR collates and analyses information from Commonwealth, state and territory radiation regulators each calendar year. Internal reporting requirements and processes vary between jurisdictions and consequently there is often a considerable delay between the incident data and the date it is reported to ARPANSA. ARPANSA requests submission of reports no later than six months from the date of occurrence wherever possible.