|Licence holder||CSIRO Health and Biosecurity|
|Location inspected||Black Mountain site, Acton, ACT|
|Date of inspection||20 - 21 June 2023|
This is the record of an inspection conducted as part of ARPANSA’s source 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 S0023.
The scope of the inspection included an assessment of performance at Black Mountain against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of CHB sources at the site.
CHB deals with controlled material and controlled apparatus at its sites across Australia to facilitate its role and intent of making a positive and transformational impact to Australia through innovation in the food, health and bioproducts industries. To perform this function, CHB uses a range of sealed and unsealed radioactive sources, x-ray analysis equipment, optical sources and lasers. They also have sealed and unsealed radioactive sources in storage at the CSIRO Black Mountain site awaiting ultimate disposal.
CHB is authorised under section 33 of the Act to deal with controlled apparatus and controlled material.
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 (Rev. 1) Code for the Safe Transport of Radioactive Material (2019)
- RPS C-6 Code for Disposal of Radioactive Waste by the User (2018)
- Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS12)
- Australian/New Zealand Standard Safety in Laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
- Australian/New Zealand Standard Safety in Laboratories Part 5: Non-ionizing radiations –Electromagnetic, sound and ultrasound (AS/NZS 2243.5:2004)
In general, the management of radiation safety at the CHB Black Mountain site in relation to controlled material and controlled apparatus was found to be sound.
CSIRO has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources across all of its Business Units (BUs). This is supported by a comprehensive radiation protection plan (RPP) from which each BU extracts the relevant information for the controlled apparatus and controlled material dealings for that the given BU. These RPPs are in turn, supported by subordinate location or work specific documents, safe work instructions. Access to this information is available to all relevant staff via QR codes attached or immediately adjacent to the particular source.
Statutory and regulatory compliance
The overall RPP, CSIRO’s Plans and Arrangements, are written to ensure compliance with the Act, the Regulations and the conditions of the licences for each BU, including S0023.
The CHB Radiation Safety Officer (RSO (or BURSO)) coordinates information for quarterly reports combining that from each CHB site. Once collected, this information is consolidated into a single final report to ARPANSA. CHB quarterly reports have been submitted to ARPANSA in a timely manner in recent years, and contain relevant information, including details of compliance with the Act and Regulations.
Although the inventory of controlled sources for CHB at the Black Mountain site covers sealed and unsealed radioactive sources, along with UV apparatus, all controlled material is in storage awaiting ultimate disposal. While this store is under overall oversight of the CSIRO Chief RSO, the RSO of each BU, including CHB, has a duty of care for the safe storage of the sources within that store as a result of maintaining their own sources on their inventories.
CHB uses some ultraviolet radiation apparatus at the Black Mountain site. Of those seen during the inspection, all matched the internal designations assigned to those sources and listed in the source inventory workbook (SIW). It was noted however that the model designation of these apparatus did not appear in the SIW although the information in the CSIRO database did include the model designation. This lack of complete data in the SIW is considered an area for improvement.
Training and education
All CHB personnel using the controlled apparatus at the Black Mountain site are required to undertake relevant training. Training records are kept electronically and ARPANSA inspectors observed these records for several individuals authorised to use the controlled apparatus at the Black Mountain site.
Access to laboratory areas is restricted to personnel who have undergone appropriate training.
Access to the radiation store is strictly limited to only personnel who have entry privileges under the authority of the CSIRO Chief RSO.
All CHB controlled apparatus in use at the Black Mountain site were considered to meet the relevant requirements of both RPS12 and AS/NZS 2243.5.
Radioactive waste including ultimate disposal or transfer
The radiation store contains many disused sealed and unsealed radioactive sources from six separate BUs, including CHB.
All storage is in large, well-labelled containers and the SIW of each relevant BU, including CHB, itemises all sealed and unsealed radioactive sources within the store. Dose rates outside the store did not exceed the requirements of AS/NZS 2243.4.
Access to all CSIRO buildings at the Black Mountain site beyond the public areas is protected by an electronic access control system. The aggregation of all sources under CSIRO control at the site, including those in the store, do not invoke enhanced security requirements. The existing security measures were therefore considered appropriate.
Event protection and emergency preparedness and response are handled under the broader CSIRO policy and work health and safety plans and were not assessed during the inspection.
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 area for improvement:
- The model designation of each controlled apparatus was not included in the SIW.
It is expected that improvement actions will be taken in a timely manner.