|Licence holder||CSIRO National Collections & Marine Infrastructure (NCMI) as part of CSIRO Digital, National Facilities & Collections (DNFC); CSIRO Environment (Oceans & Atmosphere); and CSIRO Agriculture & Food|
|Location inspected||CSIRO Laboratories Battery Point Hobart Tas & Research Vessel (RV) Investigator|
|Licence numbers||S0216; S0019; S0021|
|Date of inspection||16 March 2023|
An 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 licences S0216; S0019; S0021.
The scope of the inspection included an assessment of performance against the Source Performance Objectives and Criteria (POC). The inspection consisted of a review of records, interviews, and physical inspection of sources.
CSIRO business unit licence holders are authorised under section 33 of the Act to deal with sealed radioactive sources; ionising and non-ionising controlled apparatus located in laboratories at Battery Point, Hobart and on board the research vessel RV Investigator. The RV Investigator is a Marine National Facility (MNF) configured to enable a wide range of atmospheric, biological, geoscience and oceanographic research.
The main codes and standards applicable to the licences 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)
- RHS 9 Code of practice for protection against ionizing radiation emitted from X-ray Analysis Equipment (1984)
- RPS C-5 Code for Radiation Protection in Medical Exposure (2019)
- Australian/New Zealand Standard: Safety in laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
- AS/NZS IEC 60825-1:2014 Australian/New Zealand Standard: Safety of laser products Part 1: Equipment classification and requirements
- AS/NZS IEC 60825-14:2022 Australian/New Zealand Standard: Safety of laser products Part 14: A user’s guide
In general, the management of safety and security of sources and controlled apparatus was found to be satisfactory. In some cases, however, there appeared to be room for improvement with respect to operating under a radiation management structure inconsistent with the Radiation Protection Plans (RPP) and managing publicly available information identifying the location of the containerised radiation laboratory (RADVAN) on the deck of the RV Investigator. The use of QR codes on each controlled apparatus to ensure the operator has immediate access to the current Safety Work Instruction (SWI) is considered good practice.
Accountabilities & Responsibilities
The RPPs for S0216; S0019; S0021 state under Chapter 2 ‘Effective Control’ that “…in order to meet specific regulatory requirements, effective radiation safety management requires a reporting structure that defines the responsibilities delegated from the Licence Holder (LH)”. Figure 1 in section 2.2 of the RPPs displays the CSIRO organisational structure and radiation safety structure overlay. CSIRO states this structure demonstrates how it achieves effective control when supported with clear lines of responsibility for delegated positions identified in Section 2.3 Accountability – roles and responsibilities.
All three RPPs make a distinction between the roles of a HSE Radiation Safety Support Officer (RSSO) and that of the HSE Chief Radiation Safety Officer (CRSO) in the CSIRO organisational and radiation safety structure diagram. However, CSIRO does not have a CRSO.
Both CRSO and RSSO roles are identified as critical in the development and success of CSIRO’s RSO network. However, the CRSO has additional higher responsibilities of mentoring and providing specialist support to CSIRO in radiation safety and nuclear security. The CRSO role is a strategic position representing CSIRO with key regulatory agencies including ARPANSA and has responsibility for providing assurance to CSIRO licence holders with respect to the state of compliance across the organisation.
There is repetition and overlap in the listed activities to be undertaken by the CRSO and RSSO in sections 2.3.2 and 2.3.3 respectively, nonetheless there are important differences in these roles. For example, the CRSO role is intended to drive the implementation of CSIRO’s HSE strategy and build strong proactive partnering relationships as it relates to radiation safety through leadership. In addition, the CRSO role is to develop understanding of the unique radiation safety needs of the organisation and its business units to enable the delivery of targeted initiatives and guidance.
CSIRO includes a statement in Section 2.3.2 that attempts to address the absence of a CRSO by granting an equivalent level of delegation and responsibilities to the RSSO. This statement is not mirrored in the RSSO description under 2.3.3 of the RPPs. The RSSO advised that his current personal job description nonetheless covers the leadership aspects of the CRSO role. However, the blending of two key radiation safely position descriptions does not reflect CSIRO’s own statement on the importance of clear lines of responsibility for delegated positions for effective radiation safety management as articulated under RPP Chapter 2 Effective Control. In addition, RPP Chapter 8 ‘Incidents and Emergency Management’ and Appendix B ‘Protocols for notification of ARPANSA incidents and non-compliances’ Process Maps B.1 and B.2 all highlight the important role of the CRSO in reporting incidents and providing assistance to the Business Unit Radiation Safety Officer (BU RSO) investigating radiation incidents (For example: S0216 RPP at p.53, 54, 64).
An area for improvement (AFI) for CSIRO is to reassess its practice of operating outside of its radiation safety management and incident response structure by failing to appoint a CRSO and to update the RPPs to reflect current practices for maintaining effective control during normal operations and dealing with source incidents. In undertaking the review of the radiation safety structure, CSIRO should consider human factors when merging the CRSO and RSSO roles to demonstrate this is a reasonably practicable step to prevent and minimise human errors and organisational failures.
Regulatory compliance & document control
A site audit of all accessible controlled sources and apparatus across the Battery Point laboratories and supporting infrastructure and on the RV Investigator was conducted to verify compliance with safety requirements in the relevant codes and standards for sources in the ARPANSA Licence Administration Database (LAD) as controlled under licences S0216, S0019, and S0021.
Site UV sources
UV sources located across the site are used in water sterilisation plant; laboratory biological safety cabinet sterilisation; or other laboratory equipment such as a spectrometer crosslinker. Some UV sources are exempt. CSIRO demonstrated sound judgment when assessing the safety requirements for retaining regulatory control on equipment containing UV sources. For example:
- Regulatory control over the UV source (LAD 754) on the water sterilization unit on the water cutting machine in the workshop is retained because it does not require tools to remove the globe. In addition, as the change of the globe is required only every ten years the new training system flags the need for periodic training to line management.
- A Biological Safety Cabinet with a UV source (LAD 1394) does not have a safety interlock.
A bank of UV sources in the Aquiculture Plant Shed located outside of the laboratories next to a car park were individually audited against the register of controlled sources in the ARPANSA licence and administration database to verify that there have been no unauthorised disposals; and to confirm the UV sources with LAD numbers (LAD No.s 3930; 6389, 6387, 6390) displayed compliant UV safety hazard warning signage.
NCMI S0216 RPP Section 4.2 Source Inventory states “CSIRO uses an electronic inventory database CSIRO Radiation Inventory Database (CRID) that contains all data equivalent to the ARPANSA Licence Administration Database”. Inspectors drew CSIRO’s attention to the absence of Laser Hazard Class and operating output parameter information for a Mini 24 Epilog laser Engraver (LAD 6328) in the ARPANSA LAD. CSIRO subsequently demonstrated that laser output parameter and wavelength information is captured in CSIRO’s internal database to inform the development of SWIs and hazard labelling requirements for operating equipment incorporating a laser. On 19/4/2023 CSIRO provided specific information from the CRID on the operating parameters of the 50W CO2 laser engraver indicating CSIRO deals with this engraver as a Class 4 laser product.
On 28/4/2023 CSIRO provided the manufacturer’s Laser System Manual which indicates the manufacturer consider this laser system to be Class 2 laser product, as defined in International Standard IEC 60825-1 because the embedded high-power CO2 laser is fully contained. The engraver also contains a visible Laser Diode Pointer which is potentially accessible to the operator; however, its beam path is located well within the cabinet and the manufacturer assesses under normal operation conditions no hazardous levels of radiation can escape.
AS/NZS IEC 60825.1:2014 defines a Class 2 laser product as ‘any laser product in the wavelength range from 400nm to 700nm [visible spectrum] which during operation does not permit human access to laser radiation in excess of the AEL [Accessible emission limit] of Class 2 for applicable wavelengths and emission durations.’ This definition includes the following safety caveat – ‘Note 2: As tests for the determination of the classification of the product are limited to tests during operation, it may be the case for embedded laser products that, depending on the product, radiation above the AEL of the class of the product can become accessible during maintenance or service when interlocks of access panels are overridden, or the product is opened or disassembled’.
The manufacturer identifies specific safety features incorporated into the design of this laser system to meet the requirements of International Standard IEC 60825-1 including:
- A safety enclosure (cabinet), which is fully encloses the engraving laser and its beam path.
- Dual redundant interlock systems that turn of the engraving laser when the window is opened.
- A visible emission when the laser Diode Pointer is operating (an LED indicator on the machine’s front panel).
CSIRO uses a qualified external service provider to conduct maintenance of this laser engraver; however currently maintains the Class 4 classification of this laser product in its database given the laser’s power output and the invisible nature of the CO2 laser which operates at a wavelength of 10.6 Microns.
CSIRO should include Laser Hazard Class and operating output parameter information in the S0216 SIW for inclusion in LAD.
Digital X-ray & Photography Room
The Fish Collection Facility, building 5 (ground floor), Digital X-ray & Photography Room for taxonomic assessments is identified in the S0216 RPP as a Designated Radiation Area (DRA) which requires authorised access only. The inspection confirmed appropriate radiation hazard signage on the entrance door.
The operating key for a fully enclosed X-ray unit (LAD 536) was appropriately secured. The X-ray unit displayed appropriate hazard signage and identification labelling. The revised (February 2023) CSIRO ‘Donesafe’ risk assessment (RIS) and SWI for this X-ray unit was reviewed and the safety interlock was tested and found to be operational. Surveys are conducted every quarter by the RSO using a specific X-ray meter.
RV Investigator Aerosol Laboratory on Level 1 (Forward)
An Aerosol Laboratory on Level 1 (Forward) on the RV Investigator contains a fully enclosed class 3B laser (LAD 6236) within a Cloud Condensation Nuclei Counter instrument displaying compliant labelling and laser hazard warning signage. In addition, an aerosol neutraliser containing an Am-241 source (LAD 5896) with compliant labelling and ionising radiation hazard warning signage was also present in this secure laboratory. However, CSIRO does not consider the Aerosol laboratory a DRA, as the main function of the area is to gather atmospheric data while at sea and as such CSIRO considers this area to be a general laboratory due to the mixed nature of the apparatus that do not use radiation.
Inspectors observed the presence of flammable liquid reagent glass bottles on the floor near the device containing the Am-241 source. It was observed that both bottles (one for drawing butanol and another acting as a waste reservoir) were seated in a tray secured to the floor to ensure stability during rough ocean conditions. The entry door to the aerosol laboratory displayed both a flammable liquid warning label and radiation hazard signage. The area is capable of being securely sealed and a dedicated ‘HVAC’ system is installed to expel smoke contaminated air from the room in the event of a fire. There is a sensor to detect an oxygen deficient atmosphere and an alarm to alert the ship’s bridge. The room was constructed of non-flammable material. It is assessed a fire could not be sustained in this environment or be of sufficient intensity to compromise the integrity of the encapsulated source. In addition, a Type A package with UN 2915 with appropriate radiation warning signage was observed for use in transferring the source from ship to shore storage. The radioactive source storage requirements comply with Section 5.1 of AS/AZS 2243.4:2018.
RV Investigator Hospital room Level 02
A Carestream Motion Medical X-Ray Unit is authorised under source licence S0216. The medical X-ray unit displayed compliant radiation hazard signage; however, an additional label indicated the unit is due for recertification testing by 31 March 2023 immediately prior to the vessel leaving port. Post inspection, CSIRO advised on 3/4/2023 a risk assessment (RIS35814) for the Carestream Motion Medical X-Ray Unit was conducted on 14/3/2023. A certificate of compliance issued by a service provider under the Radiation Safety Act (WA) certified the X-ray machine was compliant on 19 January 2023; however, this compliance date had not been updated on the machine. Inspectors advised CSIRO should maintain up-to-date compliance test information on labels affixed to medical X-ray equipment.
A lead-lined protective apron was sighted during the inspection as available PPE for use by the Medical X-Ray unit operator.
RV Investigator Level 7 (Crow’s Nest) - outside
A number of RF sources including two VSAT communications domes and a weather radar are installed on the outside of Level 7 Crow’s Nest on the RV Investigator. Section 44 of the ARPANS Regulations (2018) exempts dealings with controlled apparatus such as radar equipment used for detection and ranging; and radiofrequency equipment used for communications. Bird watchers may need to go outside when these RF generating units are in operation to take photographs. Inspectors noted that CSIRO has established painted safety zones and requires personal RF radiation monitors (‘RadMan 2LT’and ‘RadMan 2XT’ Monitors) be worn when outside. Authorisation must be obtained from the captain of the vessel before proceeding outside and the area is under 24/7 surveillance to enforce this requirement for authorised access to outside RF areas. A change in configuration of the RF generating equipment would trigger a risk review for the RF safety zones as part of CSIRO’s change management process. CSIRO advised it is working towards a single-entry protocol for level 7 when multiple source types are in use.
The doppler radar dome on the top of the ship also contains a tritium ionising radioactive source. Inspectors observed that appropriate radiation hazard signage warning of the presence of an ionising source was also affixed to the door providing access to the upper deck. In addition, two ionising sources containing tritium are securely stored at CSIRO’s Battery Point Laboratories in two 2911 transport accepted packages within a locked safe (with combination lock) for future use in the Doppler Weather Radar on the RV Investigator. Inspectors verified the stored tritium sources matched inactive inventory records in LAD. Inspectors informed CSIRO that another Commonwealth agency has commenced a program of replacing doppler weather radar components containing tritium with non-radioactive solid-state components. Inspectors encourage CSIRO to review the hierarchy of controls available to reduce or where practical to eliminate the use of ionising radioactive sources in onboard weather radar and in storage at the National Collections and Marine Infrastructure (NCMI) laboratory at Battery Point.
Safety policy & objectives
The Marine National Facility (MNF) Policy to Health and Safety for all personnel on board RV Investigator is available on the CSIRO website https://mnf.csiro.au/en/About/Policies/For-participants/Health-and-safety. Section 5.9 ‘Voyage participant’s equipment and supplies’ states only in general terms that “there are safety and regulatory requirements for all equipment and consumables brought on board the vessel, and how they are used and stored once on the vessel. Voyage participants are responsible for meeting these safety and regulatory requirements which will be identified during the voyage planning process.” Inspectors recommend CSIRO strengthen the radiation safety message in this policy by referring to CSIRO’s obligations under their source licences.
Principles of radiological protection
All three RPPs identify CSIRO’s requirement to consider the International Commission on Radiation Protection (ICRP) principles of radiological protection that apply to planned, emergency and existing exposure situations. In addition, inspectors note CSIRO adopts the Precautionary Principle for dealings involving all forms of both ionising and non-ionising radiation apparatus. For example: S0216 RPP at pages 30-31.
Radiation safety officer/Radiation safety committee
All three RPPs indicate the CRSO is the Chair of the Radiation Safety Committee (RSC); however, the role of the CRSO is vacant. The RSSO advised he chairs the RSC in addition to taking the minutes of the meeting. However, this does not reflect the organisational radiation safety structure under Effective Control.
Local rules & procedures
Inspectors noted that a physical copy of the Safe Work Instruction (SWI) is present next to controlled apparatus and a QR Code is affixed to each instrument to ensure an electronic copy of the SWI is also available to the operator. CSIRO’s innovative approach to ensuring radiation safety across this complex research environment in which three different business units deal with sources regulated under three separate source licences in the same building or laboratory includes the introduction of QR codes on each device.
This initiative ensures that the current SWI for each instrument is used by the operator as only the up-to-date version of the SWI can be accessed electronically. This also enables CSIRO to manage SWI for similar equipment across its various business units in a consistent risk-based manner to drive continuous improvement. In addition, QR codes are also on doors to laboratories allowing emergency responders to access documents in a laboratory to plan a response.
CSIRO Battery Point laboratories and wharf are situated close to the iconic Hobart tourist precinct. Controlled sources and apparatus are located in laboratories in multiple buildings situated along the foreshore of the Derwent River with swipe card access control and site surveillance.
At the time of the inspection the RV Investigator was in dock immediately adjacent to the CSIRO laboratory site. CSIRO controls access to the wharf from the landside using existing access-controlled buildings and gates requiring swipe card entry and additional oversight of staff servicing the RV Investigator. There are no security enhanced sources at this site and prudent site security measures are assessed as satisfactory.
Insider risks of unauthorised access to radioactive sources by contractors is managed by a well-defined procedure as evidenced by the CSIRO Contractor Engagement Checklist which requires a contractor undergo a security clearance if the nature of their work requires access to radioactive sources. In addition, CSIRO requires an assessment on the risk of foreign interference for all external research collaborations with overseas entities including other Australian agencies using a Research Engagement Sensitivities Tool (REST).
A range of sources and apparatus used for navigation and communication, weather and atmospheric assessments, and emergency medical response to an accident are permanently situated on or within the vessel. However, a containerised radiation laboratory (RADVAN) secured to the deck of the ship during a voyage is only in active use when at sea and the empty container remains in storage at all other times.
CSIRO has developed a guide on the activity limitations of radioisotopes that can be brought on board the vessel and a protocol requires sign off by the RSO including experiments proposed by overseas researchers even in circumstances where sources and instruments have been risk assessed and determined to be exempt from regulation.
The RV Investigator Marine National Facility’s (MNF) Policy on voyager usage of RV Investigator’s Information and Communications Technology (ICT) Network resources is publicly available on the CSIRO website https://mnf.csiro.au/en/About/Policies/For-participants . This policy aims to preserve the integrity and security of the ship’s ICT network and its critical data. The ICT consists of the ship’s network infrastructure including access points, security systems, communication systems, servers, information storage, and computers and other connected devices. Onboard users are required to use IT systems and services in accordance with CSIRO Cyber Security Principles and the CSIRO Responsible use of ICT and Internet Services.
Exploitable on-line information
CSIRO also provides publicly available information on the movement of the vessel. For example: Near Real-Time Underway Data is routinely sent from the ship to an onshore CSIRO public site (https://www.marine.csiro.au/data/underway/. However, inspectors note CSIRO provides information on the RV Investigator that could reveal the likely location of ionising radioactive sources in the Radiation Laboratory (RADVAN) on the ship. Consequently, the RADVAN may be at additional risk from unauthorised access by external adversaries (including protesters) compared to other radioactive sources located elsewhere within the vessel or those sources at the Hobart laboratories. For example:
Hazard signage information (the radiation trefoil in conjunction with the additional explanatory information under red information tab) in the virtual tour of the RV Investigator on the CSIRO website readily identifies the radioactive nature of the container contents; and the accompanying vessel layout identifying the RADVAN’s exposed position on the deck relative to other recognisable vessel infrastructure as illustrated in the location marker on the ship deck plan. See Figure 1 and Figure 2.
CSIRO should review the information on the CSIRO website identifying the likely location of the Radiation Laboratory.
S0216 RPP Chapter 8 advise CSIRO has emergency management plan and procedures relevant to potential incidents at the NCMI site to deal with a radiation emergency and CSIRO NCMI conducts emergency training. RPP section 8.5.1 indicates emergency equipment is readily available to safely bring a radiation incident under control. The Site RSO is responsible for ensuring that an emergency kit is kept in each laboratory and the PPE contents checked annually. S0216 RPP Section 8.3 addresses ARPANSA’s requirements in regard to a notifiable incident.
Protection of the environment
Protection of wildlife and the environment
S0216 RPP Section 4.15 ‘Protection of Wildlife’ indicates risk assessments consider the potential impact to habitat and wider ecosystems which may include an assessment of dose or exposure to wildlife and the environment.
S0216 RPP Section 4.14 ‘Environmental Monitoring’ requires a voyage risk assessment be conducted to identify potential risks to the environment. CSIRO procedures mitigate the potential radiation risk to the environment by requiring any waste generated by experiments undertaken at sea to be bagged and stored until the completion of a voyage. All items used in the RADVAN are monitored for contamination prior to being removed. Low level radioactive waste generated in the RADVAN remains the property of the voyage participant and the external organisation is responsible for its disposal. NCMI S0216 RPP at section 5.1 states that NCMI does not generate any radioactive waste at its Hobart site.
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:
- Review the practice of operating outside of the radiation safety management and incident response structure in the Radiation Protection Plans (RPP) and update the RPPs to reflect current practices for maintaining effective control during normal operations and dealing with source incidents. The review should demonstrate that the radiation safety management structure is reasonably practicable to prevent and minimise human errors and organisational failures. [All 3 licences]
- Review the information on the CSIRO website identifying the likely location of the radiation laboratory on the vessel. [S0216]
- Include laser hazard class and output parameters in the Source Inventory Workbook. [All 3 licences]
- Review alternative non-radioactive electronic components to replace radioactive sources in doppler weather radar. [S0216]
The inspection revealed the following good practice:
The use of QR codes on each controlled apparatus provides assurance that the current Safety Work Instruction is available to the operator regardless of the laboratory location or business unit responsible for the safe operation of a similar source.
It is expected that improvement actions will be taken in a timely manner.
 S0021 at p.11; S0019 at p.18; and S0216 at p.10.
 Note: This information request is part of a wider initiative to ensure all Commonwealth Licence holders provide more information on all output parameters relevant to the likely exposure conditions as per ARPANS Regulations (2018) Section 47(2)(a) table item 4 dealings with a controlled apparatus that produces non-ionising radiation including (c).