Le groupe de travail ACRP-CCSN renforce la culture de radioprotection du Canada

For some time now, The Canadian Radiation Protection Association (CRPA) has been meeting with the Canadian Nuclear Safety Commission (CNSC) to exchange information relevant to all stakeholders in the licensee community regarding challenges in our regulatory system.[1]

The primary goal of these biannual CRPA-CNSC exchanges is to promote a strong radiation protection culture among CNSC licensees across Canada. CRPA representatives relay your questions, comments, and suggestions and all topics are discussed, so please feel free to contact us with your concerns. This working group is a unique opportunity to make your voice heard.

The official minutes of the working group’s discussions are available in the member-only section of the CRPA website. CRPA members can log in to read the full minutes of the meeting held on May 29, 2025, and I am including a brief synopsis of the discussion below.

Consolidation of use types

CNSC provided an update on the consolidation of use type groups for nuclear medicine licences. The categories have now been consolidated into two new types—Diagnostic and Therapeutic and Diagnostic, Therapeutic, and Human Research—which were approved in March and became effective at the end of April 2025.

CNSC noted that the process is still being fine-tuned. Updated information, including new use types and payment formulas, is available on the CNSC website. The licence application guide (REGDOC-1.6.1) has not yet been revised to reflect these changes. CNSC will merge existing licence conditions but will not introduce new ones. For licensees holding multiple licences, the latest expiry date will be used on the new consolidated licence.

Compliance with Radiation Protection Program, Section 25, and instrumentation

CNSC provided a high-level update addressing ongoing performance issues among nuclear medicine licensees, as documented in annual regulatory oversight reports over the last several years. CNSC staff have been considering these issues in the context of compliance with Radiation Protection Program, section 25 (RP25).

CRPA members raised concerns regarding RP25, specifically that instrumentation calibration requirements appear to have shifted from 100% to 50%, which contradicts regulatory standards. CNSC committed to following up with radiation protection (RP) to clarify the rationale for this change.

Radiation safety officer time

Concerns about insufficient radiation safety officer (RSO) time persist across jurisdictions. CNSC reiterated that it does not prescribe or recommend specific time allocations, leaving such decisions to the applicant authority (AA). However, AAs often lack a full understanding of the operational demands of radiation safety programs.

RSOs are working to define expected time commitments based on specific tasks, though early feedback from senior management has been mixed. A national poll revealed significant inconsistency in how organizations assign dedicated RSO time.

Definition of servicing

The working group revisited the definition of “servicing” under the Nuclear Substances and Radiation Devices (NSRD) Regulations, which define it as maintenance beyond what is required for routine use.

Concerns were raised about third-party contractors performing servicing work without sufficient operational training. If a contractor requires device operation for servicing, they must undergo appropriate training and be added as authorized users under the servicing licence.

Meeting dates

The working group meets at least twice per year. Most recently, the group met on December 5, 2025, to discuss the following:

• licence consolidation,
• the role and operation of service licences,
• compliance with certain sections of the Nuclear Safety and Control Act, and
• expectations regarding the role of RSOs and commitments of the Applicant Authority.

At least one meeting each year is held at the same time as the CRPA annual conference.

Meeting minutes on the CRPA website

I hope this article has piqued your curiosity. If you are a CRPA member, you can find a more complete summary of the May 29 meeting in the members-only section of the CRPA website. This is also where all future minutes from CRPA–CNSC Working Group meetings will be shared. So, check back to find the minutes of the December 5 meeting.

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[1] The mission of the CRPA-CNSC Working Group is to provide a forum for communication and information sharing, involving stakeholders in the regulated community, with the aim of promoting a strong radiation safety culture in licensees across Canada. See the Terms of Reference for the working group.