Amendments to the CNSC Radiation Protection Regulations: Introduction

From: twitter.com/CNSC_CCSN/status/1192458160835092480

The amended Canadian Nuclear Safety Commission (CNSC) Radiation Protection Regulations were published in November of 2020. Following their publication, CNSC adopted a compliance promotion approach with licensees to allow them time to update their radiation safety programs. That period has ended and all licensees must now meet the new requirements.

The July 2022 issue of the Directorate of Nuclear Substance Regulation (DNSR) Digest highlighted some areas where CNSC inspectors continue to see non-compliance with the updated regulations. In particular, inspectors have noticed issues with

• extremity dosimetry, and
• provision of information to nuclear energy workers (NEWs).

We thought this would be a good time to remind our CRPA Bulletin readers of all of the changes to the Radiation Protection Regulations.

Compliance requirements with the amended Radiation Protection Regulations

The following summary was adapted from the information published in the July 2022 issue of the DNSR Digest.

Extremity Dosimetry

The requirements related to extremity dosimetry were previously addressed as licence conditions. The amended regulations have introduced a new requirement in paragraph 8(1)(b) that a licensed dosimetry service be used to measure and monitor doses to NEWs who have a reasonable probability of receiving an equivalent dose to the skin or the hands and feet that is greater than 50 mSv in a one-year dosimetry period. The onus is on the licensee to demonstrate that a licensed dosimetry provider isn’t needed because there is no reasonable probability of the dose to the extremities exceeding 50 mSv per year.

Section 8 of REGDOC-2.7.1, Radiation Protection, provides guidance for licensees on determining when licensed dosimetry may be required.

Provision of Information to Nuclear Energy Workers

Another area where non-compliance continues to be an issue is in the provision of information to NEWs. Section 7 of the regulation now states:

7 (1) Every licensee must inform each nuclear energy worker, in writing,

(a) of the fact that the worker is a nuclear energy worker;
(b) of the risks associated with radiation to which the worker may be exposed in the course of their work;
(c) of the applicable effective dose limits and equivalent dose limits prescribed by sections 13 to 15;
(d) of the worker’s radiation dose levels, received on an annual basis; and
(e) of the worker’s responsibilities during an emergency and the risks associated with radiation to which the worker may be exposed during the control of an emergency.

(2) Every licensee must inform each female nuclear energy worker, in writing,

(a) of the risks associated with the exposure of embryos and fetuses to radiation and the risks to breastfed infants from the intake of nuclear substances;
(b) of the importance of informing the licensee, as soon as feasible, in writing, that the female nuclear energy worker is pregnant or breastfeeding;
(c) of the rights of a pregnant nuclear energy worker and the rights of a breastfeeding nuclear energy worker under section 11; and
(d) of the applicable effective dose limits for pregnant nuclear energy workers prescribed by section 13.

(3) Every licensee must obtain from each nuclear energy worker who is informed of the matters referred to in paragraphs (1)(a) and (b) and subsection (2) a written acknowledgment that the worker has received the information.

Not all licensees are updating the information provided in writing to NEWs related to updated dose limits to the lens of the eye or updating the provisions for female NEWs. This updated information must be provided to existing NEWs by the licensee. The licensee must also be able to demonstrate that existing NEWs have received the information.

If you use a NEW acknowledgment form to demonstrate compliance with these regulatory requirements, ensure your form is up-to-date with all current information and that all NEWs (existing and new workers) have been provided with the updated information.

Section 7 of REGDOC-2.7.1, Radiation Protection, provides additional guidance for licensees on provision of information to NEWs.

As always, if you have any questions about meeting regulatory requirements, please contact your project officer, licensing specialist, or licensing project officer.

See related article

We also recommend that you read Amendments to the Radiation Protection Regulations: A CNSC perspective. It is an adaptation of the excellent summary written by Jessica Milligan-Taylor, a project officer in the CNSC Accelerators and Class II Facilities Division, which was originally published in the April 2021 issue of Canadian Organization of Medical Physicists (COMP) Interactions.