Amendments to the Radiation Protection Regulations: A CNSC Perspective

Amendments to the Radiation Protection Regulations were published in Canada Gazette, Part II, on November 25, 2020, and all of the new requirements were in effect as of January 1, 2021.

The amended regulations are accessible online in both official languages:

• English
• French

The objective of these amendments is to enhance radiation protection for workers, the public, and the environment based on international standards for radiation protection and Canadian Nuclear Safety Commission (CNSC) regulatory operational experience.

Changes of particular interest

While a complete list of the changes can be found below, the changes of particular interest include the following:

• Licensees are required to inform each nuclear energy worker (NEW) of their radiation dose levels. The amended regulations now require that NEWs be given this information at least once per year. Licensees must actively inform NEWs of their dose in writing; simply providing NEWs with access to the information but requiring them to retrieve it is not sufficient.
• Use of a licensed dosimetry service to measure and monitor the doses of radiation received by a NEW who has a reasonable probability of receiving an effective dose that is greater than 5 mSv in a one-year dosimetry period was already required. The amendments now also require that licensees use a licenced dosimetry service if there is a reasonable probability that a NEW may receive an equivalent dose to the skin or the hands and feet that is greater than 50 mSv in a one-year period.
• Previously, the regulations required NEWs to inform the licensee in writing immediately upon becoming aware of pregnancy and did not include any provisions regarding breastfeeding. Under the amended Regulations, NEWs are no longer required to declare their pregnancy status. However, licensees must inform NEWs of the risks associated with the exposure of embryos and fetuses to radiation, the risks to breastfed infants, and the importance of declaring pregnancy or breastfeeding status. The licensee must also make reasonable accommodations once either status has been declared.
• The requirement that a licensee provide patients receiving therapeutic treatments with nuclear substances information on methods for reducing exposure of others prior to the patient leaving the hospital has been removed in the amended regulations. This is to account for inpatient situations where the patient would not be leaving the hospital following the administration of the therapeutic dose.

The amended Radiation Protection Regulations are now in force. Licensees are expected to perform a gap analysis of their current management system in light of all new requirements and implement updates as required to align with the amended regulations. Updated management system documents that form part of the original licensing basis (and are referenced in the licence appendix) need to be submitted to CNSC with a request to amend the licence to reflect the changes.

Summary of changes

The following is an overview of the changes to the Radiation Protection Regulations.

Interpretation (definitions)

• The definitions of “working level” and “working level month” were deleted from the regulations, as they apply to mathematical formulas for calculating effective doses that have been removed from section 13 (Effective Dose Limits).
• The definition of “dosimetry service” has been clarified; it is a facility that is licensed by the commission to measure and monitor radiation doses.
• The definition of “caregiver” has been added to the regulations; a caregiver is a person who “willingly and voluntarily, and not as an occupation” helps in the support and comfort of a person who has received a nuclear substance for therapeutic purposes.

Dose received by caregivers

The amended regulations formalize an existing licensee exemption concerning doses received by non-occupational caregivers.

Administration of nuclear substances for medical purposes

When patients receive a nuclear substance for therapeutic purposes, the licensee is no longer required to inform them before they leave the place where they received the treatment of methods for reducing the exposure of others. Instead, this information can be provided in a manner that is convenient and specific to the situation.

Radiation Protection Program

The amendments remove the specific reference to radon progeny exposure because the mathematical formulas for calculating effective dose have been removed from section 13 (Effective Dose Limits).

Provision of information

Frequency of informing nuclear energy workers in writing of their radiation dose levels

The amended regulations increase the frequency with which licensees must inform (in writing) nuclear energy workers (NEWs) of their radiation dose levels. NEWs are to be informed of their radiation dose levels annually.

Requirement related to emergencies

The amended regulations require all licensees to inform NEWs (in writing) of their responsibilities during an emergency, as well as the radiation-related risks to which they may be exposed during the control of an emergency.

Requirements related to pregnancy and breastfeeding

The provision requiring female NEWs to disclose their pregnancy to the licensee has been removed from the regulations. The amended regulations require licensees to

• give female NEWs information about the risks to a breastfed infant posed by the mother’s intake of nuclear substances;
• inform all female NEWs in writing that it is important to notify the licensee, as soon as feasible and in writing, that they are breastfeeding, and inform them of the rights of breastfeeding NEWs; and
• make reasonable accommodations for female NEWs who have disclosed that they are breastfeeding.

Requirement to use a licensed dosimetry service: Equivalent dose to the skin or to the hands and feet

The amended regulations require licensees to use a licensed dosimetry service to measure and monitor radiation doses to NEWs who have a reasonable probability of receiving an equivalent dose to the skin or to the hands and feet that is greater than 50 mSv in a one-year dosimetry period. Licensees whose NEWs must be monitored by a licensed dosimetry service must provide the required information to the licensed dosimetry service for the purpose of reporting doses to Health Canada’s National Dose Registry.

Nuclear energy worker: Personal information for dose records

In the amended regulations, the term “sex” has been replaced with the term “gender” in the list of personal information that must be collected for the purpose of filing dose records in Health Canada’s National Dose Registry.

Formulas for calculating effective dose

The mathematical formulas for calculating effective doses have been removed from the regulations. The methods for calculating effective doses are now found in CNSC draft regulatory document REGDOC-2.7.2, Volume I, Ascertaining Occupational Dose.

Equivalent dose limits for the lens of an eye

The amended regulations reduce the equivalent dose limit for the lens of an eye for a NEW from 150 mSv to 50 mSv in a one-year dosimetry period.

When dose limit is exceeded

Under previous regulations, licensees were required to remove a person from work if that person may have or had exceeded any of the dose limits set out in sections 13 and 14. That requirement has been amended to only require the person to be removed from work if they exceed any dose limits for NEWs.

Application for licence to operate

The requirements regarding an application for a licence to operate a dosimetry service have been amended to

• replace the term “quality assurance program” with the term “management system,” which is consistent with the terminology used in the CNSC’s Regulatory Framework; and
• remove the requirement to specify the types of radiation and energy ranges that will be monitored, since this information is not applicable in all cases.

Labelling of containers and devices

The amended regulations exempt devices that contain radium luminous compounds from the labelling requirements if

• radium is the only nuclear substance in the device and
• the device is intact and has not been tampered with.

The amended regulations clarify that containers used to temporarily hold nuclear substances must be marked with the radiation warning symbol (trefoil) and the words “RAYONNEMENT – DANGER – RADIATION” to alert workers to the potential radiological hazards of the contents.

Posting of signs at boundaries and points of access

Under the amended regulations, licensees are exempt from the requirement to post signs at boundaries and points of access for vehicles containing consignments for transport.

Records to be kept by licensees

All licensees are now required to maintain dose records for 5 years from the day on which the information is collected.

Radiation detection and measurement instrumentation

Licensees must ensure radiation detection and measurement instrumentation is selected, tested, and calibrated for its intended use.

Organ or tissue weighting factors and radiation weighting factors

The weighting factors in the regulations have been amended so that they are consistent with International Commission on Radiological Protection (ICRP) 103.

 

(See related article – Amendments to the Radiation Protection Regulations: Introduction)