|Licence holder||Australian National University (ANU)|
|Location inspected||Research School of Physics|
|Date of inspection||1 and 2 December 2022|
This inspection was conducted as part of ARPANSA’s baseline inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act), the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations), and conditions of source licence S0027.
The scope of the inspection included an assessment of performance at RSPhys against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of sources.
The ANU is a research-intensive university located in Acton, ACT and specialises in a range of activities that require the use of radioactive materials and ionising and non-ionising radiation apparatus. The ANU holds a source licence under S33 of the Act which authorises the ANU RSPhys to deal with lasers, industrial radiography X-ray units, ultraviolet light sources and sealed and unsealed radioactive sources.
The main codes and standards applicable to this licence are:
- RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
- RPS C-2 Code for the Safety Transport of Radioactive Material (2019)
- RPS C-4 Code of Radiation Protection Requirements for Industrial Radiography (2018)
- RPS 11 Code of Practice for the Security of Radioactive Sources (2019)
- AS/NZS 2243.4 Safety in laboratories Part 4: Ionizing radiations (2018)
- RHS 9 Code of practice for protection against ionizing radiation emitted from X‑ray analysis equipment (1984)
- AS/NZS 2243.5 Safety in laboratories Part 5: Non-ionizing radiations-Electromagnetic, sound and ultrasound (2004)
- AS/NZS IEC 60825-1 Safety of laser products Part 1: Equipment classification (2014)
- AS/NZS IEC 60825-14 Safety of laser products Part 14: A user’s guide (2022)
In general, the management of radiation safety at RSPhys in relation to controlled material and controlled apparatus was found to be sound. However, in some cases there appeared to be room for improvement as follows:
- The Radiation Management Plan (RMP) for RSPhys did not identify user training specific to the type of apparatus and materials being used
- There is no evidence that radiation users are informed annually of their radiation dose
- The terms risk and hazard in the Procedure – Radiation Document did not reflect the terminology used in AS/NZS 2243.4
- Enclosed lasers where the covers can be removed did not have wording on the enclosure stating that “laser personal protective eyewear must be worn when laser enclosure cover removed” or similar
- X-ray equipment from which lasers have been removed still had the laser warning label affixed.
ANU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use of radiation and the safe storage of radioactive sources throughout all schools at the university. This is supported by a comprehensive RMP to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions.
In line with the ANU radiation safety policy, RSPhys has work health and safety (WHS) committees for all colleges, schools and field work that is carried out. The RMP is reviewed and updated annually and is approved by the Director of RSPhys.
Statutory and regulatory compliance
The RSPhys RMP states it has been designed to ensure compliance with the ARPANS Act 1998, the 2018 Regulations as well as the conditions of licence S0027.
Processes relating to the purchase and in-house manufacturing of sources are aimed at reducing the likelihood of the procurement of unauthorised sources.
Radiation safety matters are reported according to the local WHS plan. The reporting line provides for communication to RSPhys Heads of Departments, WHS committee meetings and the University’s radiation safety advisory group. During the inspection example agendas and minutes of WHS meetings were sighted.
Safety policy and objectives
The RSPhys RMP covers the fundamentals of radiation protection through to specific requirements for conducting risk assessments, developing safe working processes, as well as emergency response and incident management, reporting and safety learnings.
The ANU has a policy governing the safe and effective use of radiation within the University (ANUP_001232). The policy is implemented through radiation management plans, risk assessments, staff and student training, and safe operating procedures. These are to as the RSPhys ‘safety management systems’
Risk assessment and mitigation
The ANU requires risk assessments and safe operating procedures in all laboratories where radiation is used. Risk assessments are also used to identify source transport needs and how they will be conducted to meet the requirements of RPS C-2.
A detailed example of these requirements was examined during the inspection as they apply to ‘New Work Proposals’ (section 17.2 of the RMP). It covers the processes for developing risk assessments, and the review and approvals required for all projects involving controlled materials or apparatus.
Monitoring and measurement
The operation of the RSPhys safety management system is monitored through proactive inspections by the Radiation Safety Officer (RSO) or Laser Safety Officer (LSO) and knowledge obtained from the analysis and investigation of incidents. The ANU RSO presented some examples of inspections made using the iAuditor tool and stored and managed in Figtree, the ANU workplace safety incident and hazard reporting tool.
An example of an incident and the knowledge obtained from the investigation was discussed.
On 6/12/2021 a laser incident occurred whereby a worker received an exposure to their eye. This incident was investigated centrally by the ANU which reviewed the workers training, actions, the safe operating procedures, and the risk assessment for the experiment. The investigation showed that when the incident occurred the worker was not wearing any laser protective eyewear and it was said they had also been working long hours.
Controlled apparatus and material were found to have appropriate radiation warning signs however some legacy laser signs were apparent on X-ray equipment where the laser had been removed.
Training and education
The RSO and LSO receive training and refresher training. The WHS area arranges for local training for users and refresher training is scheduled at 5-year intervals. Evidence of hazard specific training for staff, students and ‘visitors’ was presented during the inspection. The RMP requires clarification in that hazard specific training is carried out for these persons and that ‘visitors’ relates to visiting scientists.
Training records are maintained in the ANU ‘Insight’ system. Currently the training records are being reviewed by the University for completeness as the training records are also used to determine whether staff, students and visiting scientists should have access to laboratories where controlled sources are used. There are three levels of training for staff, students and visiting scientists:
- WHS induction
- radiation training that is hazard specific (laser, X-ray or radioactive materials)
- laboratory and/or electrical training.
A copy of a safety induction register for the department of nuclear physics was provided at the inspection. The register covered the period 10/12/2019 to 29/10/2022.
Principles of radiological protection
The RMP covers the fundamentals of radiation protection namely justification, optimisation and limitation. Justification for the university was stated as being the benefits of research to society; optimisation and limitation were evident in the safety assessments, local working rules and the radiation monitoring of staff and students.
Radiation safety officer/radiation safety committee
The ANU has a radiation advisory group that includes representation from RSPhys. At the school level the roles and details for the RSO/LSO are specified in section 4 of the RMP. Training records were observed to be current with RSO and LSO refresher courses due in Feb 2024.
Local rules and procedures
Radioactive sources used in the nuclear physics department for the calibration of detectors for accelerator experiments are kept in a safe behind a locked cage within the accelerator facility. The safe is not locked however the cage is locked and access to the facility requires a swipe card.
The storage safe is checked every 6 months with dose rates recorded around the safe at specified locations. A copy of the ‘NP Radiation Store Monitoring Record’ was provided at the inspection indicating that checks were made at approximately 6-month intervals. The measured dose rates were a few microsieverts per hour.
Personal protective equipment
Appropriate laser protective eyewear is available to staff and students. Ionizing radiation survey meters are available within RSPhys. Exposure meters are calibrated annually, and contamination monitors are calibrated every 5 years. Calibration certificates for the survey meters were sighted during the inspection.
Monitoring of individuals
RSPhys uses personal radiation monitors for work with ionising radiation, and personal exposure records are kept in HISTORIAN. Staff and students can request to view their exposure records but are notified if exposures are above limits or different from the usual pattern of exposure for their work.
Packaging and containment of radioactive waste
The ANU engaged a radiation consultant to characterise and package the legacy radioactive sources held in the central store. As a result of this work the sources are packaged to meet the current storage requirements in AS/NZS 2243.4 and the Transport Code RPS C-2.
Limiting exposure to radioactive waste
Dose rates in the store and at external walls (measured outside of the store) were measured with an ANU calibrated radiation monitor and were found to be approximately 1.5-3.0 µSv/h. The store is in an area of low occupancy and not on a main pedestrian throughfare.
Storage of radioactive
The store has been constructed to minimise the likelihood of flooding impacting on the radioactive materials. All storage is on raised shelves and the store has a large stormwater drain centrally located. The waste store meets the storage requirements for radioactive materials in AS/NZS 2243.4.
Documentation of radioactive waste
ANU maintains a radioactive source inventory for the central store.
All buildings and laboratories use an electronic card access system. The WHS area manage this and can withdraw access if training or risk assessments for that area are not current. ANU security services check doors daily for correct operation.
Access to the central store requires 2 physical keys which are kept in separate locations. The store has a 24/7 monitored security system. The aggregation of all sources under RSPhys control do not invoke enhanced security requirements and the existing security measures are therefore considered appropriate.
The ANU has an overarching emergency plan and each school has their own plan based on the risks at that location.
ANU maintains an ongoing arrangement with ACT emergency services to ensure an awareness of the potential hazards on the site in the event of a radiation incident. ACT Fire have periodic tours of radiation sites on campus and the ACT Hazmat crews have visited the central radiation store.
Any alarm on campus provides an email and text to the RSO and other radiation site RSOs.
The licence holder was found to comply with the requirements of the Act, the Regulations, and licence conditions.
The inspection revealed the following areas for improvement:
- User training was not specific to the type of apparatus being used
- Radiation users were not informed of their dose on an annual basis
- The terms risk and hazard did not reflect the terminology used in the standard
- The laser warning signs on the X-ray equipment in the Applied Mathematics Department were not removed when lasers were no longer present within the cabinets
- Not all non-interlocked laser enclosures that permitted access to exposures above the MPE had a sign indicating laser protective eyewear must be worn when the cover is removed.
It is expected that improvement actions will be taken in a timely manner.