|Licence holder||Australian National University (ANU)|
|Location inspected||College of Engineering, Computing and Cybernetics (CECC) (previously CECS) and John Curtin School of Medical Research (JCSMR)|
|Date of inspection||27-28 April 2023|
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 the ANU Acton premises within CECC and JCSMR against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.
ANU is a research-intensive university located in Acton, Australian Capital Territory (ACT), and specialises in a range of activities that require the use of radioactive materials and ionising and non-ionising radiation apparatus. The ANU source licence covers several schools at the Acton campus and one at Mt Stromlo, ACT, many of which use controlled apparatus and controlled materials as part of their research and teaching roles. ANU is licensed under Section 33 of the Act to deal with controlled material and controlled apparatus for research purposes in its various schools.
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 11 Code of Practice for the Security of Radioactive Sources (2019)
- RPS C-2 Code for the Safety Transport of Radioactive Material (2019)
- RPS C-6 Code for Disposal of Radioactive Waste by the User (2018)
- Australian Standard Safety in Laboratories – Ionizing Radiations (2018) (AS 2243.4-2018)
- Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS12)
- Australian/New Zealand Standard Safety in Laboratories – Non-ionizing radiations - Electromagnetic, sound and ultrasound (2004) (AS/NZS 2243.5:2004)
- Australian/New Zealand Standard Safety of laser products Part 1: Equipment classification (AS/NZS IEC 60825-1:2014)
- Australian/New Zealand Standard Safety of laser products Part 14: A user’s guide (AS/NZS IEC 60825-14:2011)
In general, the management of radiation safety at both CECC and JCSMR in relation to controlled material and controlled apparatus was found to be sound. In some cases, however, there appeared to be room for improvement as follows:
- Records of training in each of the schools, while comprehensive for the particular school, did not translate to the ANU central record system.
- Reminders of refresher training for relevant staff were sent out manually thus requiring human intervention of the relevant school WHS Manager.
- Several differently rated types of laser protective eyewear were available in one of the laser laboratories (CECC) but these were all located in one unlabelled storage container.
- A warning label at the entry to a JCSMR X-ray laboratory was generic and warned staff of types of apparatus that were neither located nor stored in that laboratory. Further, the X-ray warning item on that sign used the non-ionising radiation symbol.
- The panels on two lasers were not interlocked in accordance with the requirements of the laser standard.
ANU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources throughout all schools at the university. This is supported by a comprehensive Radiation Management Plan (RMP) to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. It should be noted that a comprehensive review of the ANU RMP was conducted during the December 2022 inspection and this inspection therefore concentrated on the ‘local’ RMPs of both CECC and JCSMR.
ANU has a Radiation Safety Advisory Group (RSAG) that meets quarterly and comprises representation from all schools including CECC and JCSMR. CECC and JCSMR have local work health and safety (WHS) committees that include radiation safety issues as a standard agenda item. These local committees also meet quarterly and report radiation matters to RSAG as appropriate.
Statutory & regulatory compliance
Both the CECC and JCSMR RMPs have been drafted to ensure compliance with the Act, the Regulations and the conditions of licence S0027.
Processes relating to the purchase and in-house manufacturing of sources across ANU are aimed at reducing the likelihood of the procurement of unauthorised sources.
Radiation safety matters for both CECC and JCSMR are reported according to their local WHS plans. The reporting line provides for communication to the relevant Heads of Departments, WHS committee meetings and the ANU’s RSAG. Example agendas and minutes of WHS meetings were sighted during the inspection for both schools.
ANU requires risk assessments and safe operating procedures in all laboratories where radiation is used, including CECC and JCSMR. An example of these requirements covering the processes for developing risk assessments, and the review and approvals required for all projects involving controlled materials or apparatus was viewed during the inspection.
The RMPs of both schools require annual WHS inspections that incorporate a component on radiation safety. Sample reports, which can contain corrective actions where relevant, were viewed during the inspection.
Neither school had had a radiation related incident since their last ARPANSA inspections. Should such an incident occur though, it would be reported through the internal incident reporting system and identified as a radiation related incident. Once flagged as a radiation related incident, the ANU WHS office would ARPANSA-TMP-1943 v1.0 S0027 R23/03550 3 of 5 investigate it and the results of the investigation, including any actions taken to mitigate the problem, would be reported to ARPANSA in accordance with the regulatory requirements.
Controlled apparatus and material were found to have appropriate radiation warning signs. However, the entry door of one X-ray room in JCSMR had a generic warning sign identifying equipment that was neither used nor stored in that particular room. Further, the symbol used to represent the X-ray apparatus was the non-ionising radiation symbol and not the standard ionising radiation trefoil. It should be noted that second of the two side-by-side entry doors did have a clearly visible ‘Caution X-ray Radiation’ sign bearing the standard trefoil. The generic sign should however only show relevant warning labels for the room and the symbols used need to be consistent with the equipment type.
Training & education
All personnel using controlled apparatus or controlled material at ANU are required to undertake training related to the particular type of source they will use. This training includes:
- Tier 1: general induction
- Tier 2: school induction
- Tier 3: individual laboratory induction and specific use training, the extent of which depends on the proposed dealing for the given individual.
Access to laboratory areas is restricted to those personnel who have undergone appropriate induction training or are otherwise closely escorted by appropriately trained staff.
Training records are kept in physical form and electronically. The ARPANSA inspector verified these records for several individuals authorised to use the controlled apparatus and controlled materials in both CECC and JCSMR as having completed the training.
The training records of relevant staff in each of the schools was found to be comprehensive within the given school however, the records in the ANU central record system were not as comprehensive. For example, completion of Tier 3 induction in a particular school would only be recorded in the central system if the trainee uploaded those records. This would then ‘overwrite’ any previous Tier 3 induction that the individual had completed in another school.
Reminders of refresher training for relevant staff had to be sent out manually by the school WHS manager. While this notification commenced 6 months before the due date as alerted by a colour change in a spreadsheet for the relevant individual, human intervention of the relevant school WHS manager was required to complete this process.
ANU’s overall training record keeping system was under review with a view to rectifying these potential issues.
Exposure meters are calibrated annually, and contamination monitors are calibrated every 5 years in accordance with current regulatory requirements. Calibration certificates for the survey meters were sighted during the inspection.
Personal protective equipment
Appropriate laser protective eyewear is available to staff and students however, in one laser laboratory, several different pairs of laser goggles were stored in a single acrylic container at the entry door with no indication of their intended use other than the rating on the glasses themselves. Ideally, each different type of laser goggle should be stored in a separate, well labelled container to avoid as far as possible incorrectly choosing the wrong type.
Further, one pair of goggles appeared to have melt on the field of vision and others had some pitting in the protective glass.
Two lasers in CECC had protective panels but these were not interlocked as required by the laser standard.
Monitoring of the individuals
Personal radiation monitors are used for work with ionising radiation, and personal exposure records are kept in the central record system. 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.
Some short-lived, low-level radioactive waste is generated in JCSMR. This waste is placed in a locked and labelled store until such time as it can be disposed of as normal trash under a licence from the ACT Health Department.
The store has been constructed to minimise the likelihood of flooding impacting on the radioactive materials. All storage is in large, well-labelled drums and JCSMR maintains a radioactive source inventory for the store.
Dose rates outside the store did not exceed the background radiation level and the store was considered to meet the requirements of AS2243.4:2018.
Access to all CECC and JCSMR buildings is protected by an electronic access control system only available to those who had completed the appropriate training. The aggregation of all sources under both CECC and JCSMR control do not invoke enhanced security requirements and the existing security measures were 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. Any alarm on campus provides an email and text to the Radiation Safety Officer (RSO) and other radiation site RSOs.
The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions. The inspection revealed the following areas for improvement:
- A mismatch of training records between individual schools and the main human resources training record system.
- Human intervention was required to alert relevant staff of the need for refresher training.
- Personal protective equipment, namely laser goggles, was not easily identifiable.
- Room entry warning labels did not accurately reflect the apparatus within the room.
- Panels on some laser devices were not interlocked.
It is expected that improvement actions will be taken in a timely manner