Safety and Security: Sustainable Continuous Control of the
Use of Radioactive Sources
A Speech by
Ken Pereira, Executive Vice President, Operations Branch
Canadian Nuclear Safety Commission
To the
International Conference on the Safety and Security of
Radioactive Sources: Towards a Global System for the Continuous Control of
Sources throughout their Life Cycle
Bordeaux, France
June 29, 2005
There is now wide agreement that safe and secure use of radioactive sources
can only be assured by commitment to continuous control measures. In a sense,
the attendance at this international conference is a good indication of the
interest in this goal.
So, what is meant by continuous control? Continuous control implies the
implementation of regulatory oversight of radioactive sources at every stage of
their life cycles, i.e. from cradle to grave. This means that there must be
safety and security goals and measures in place to govern every stage from the
design of a source through to its final disposal at the end of its useful life.
An effective and comprehensive cradle to grave regime has to extend beyond
national borders. As we know, there is widespread use of sources and to support
this wide use there is considerable trade is radioactive sources and radiation
devices. Hence an effective cradle to grave regime must have participation by
the international community in assuring safe and secure use of radioactive
sources.
So what must we do to establish regimes for continuous control of the safety
and security of sources? Entities involved in all stages of the life cycle of
radioactive sources have roles and responsibilities for assurance of safety and
security. There has to be engagement by regulators, manufacturers, distributors,
users and transporters. A life cycle approach to radioactive source management
is a corner stone for successful and effective regulatory control over high-risk
radioactive sources. Each entity should play its role and discharge its
responsibilities with a commitment to assurance of safety and security in the
use of these substances.
Competent national authorities should establish and implement national
regulatory requirements in accordance with risks posed by the radioactive
sources that fall within their jurisdictions. Their regulatory systems should be
risk-informed in order to optimize resource allocation and enhance the
regulatory oversight of radioactive sources. Continuous regulatory oversight
introduces challenges that need to be addressed. A primary one is the challenge
of achieving effective international regulatory control without unduly
restricting the medical, industrial, academic or research benefits received from
the use of radioactive sources. Nuclear regulators have differing mandates when
it comes to regulating radioactive sources, and these differences should not be
ignored when addressing the issues of life-cycle control of sources. Clearly,
though there is a need for the regulatory bodies to have the mandate and power
to assert unencumbered regulatory control of activities with radioactive sources
within their jurisdictions. In Canada, the nuclear regulator, the Canadian
Nuclear Safety Commission, has, as part of its mandate, the requirement to
regulate the production, possession, use and transport of nuclear substances to
protect health, safety and security. It carries out these functions via a
comprehensive regulatory licensing regime. Licensees are required to conduct
their activities within their authorizations and with due diligence. The
regulatory oversight of the Canadian Nuclear Safety Commission includes a
program for assurance of compliance with regulatory requirements. The compliance
assurance program is supported by powers to take graduated enforcement action.
Further, inspectors are empowered to issue orders to require corrective action
to protect against perceived immediate risks to health, safety or security.
There are unique control and security challenges that need to be addressed in
each phase of the life-cycle of a radioactive source. The first phase is the
manufacture of the radioactive sources and the design of the devices in which
they are installed. The primary concerns involve the risk of theft of the
source, and the degree of dispersability of radioactive material if the sealed
source is breached. Regulatory initiatives should be undertaken to reduce the
production of easily dispersible radioactive material. Competent national
authorities and manufacturers should collaborate in investigating how devices
can be designed to make them less attractive for malicious use purposes.
Radioactive source production is centralized in a relatively few countries,
which then supply users throughout the world. Hence, it may be possible to
achieve relatively large improvements in protection against safety and security
risks, by focused efforts on the part of this small industry group.
The second phase of the life-cycle of a radioactive source commences when
distributors or manufacturers transfer or sell sources to users around the
world. The nuclear regulator should require that anyone wishing to use a
radioactive source be authorized to possess and use the source for a specific
application. It also must ensure that the person is qualified to carry out this
licensed activity and that the nuclear regulator, with the jurisdiction in the
location of use, has in place robust national regulations that govern the use of
radioactive sources and a comprehensive compliance program to verify that the
licensed activity is carried out in accordance with those national regulations.
Prior to authorizing the possession and use of a radioactive source, the nuclear
regulator must verify that the prospective user is a legitimate entity with
valid reasons for wanting to possess the source and that the prospective user
will make adequate provisions to guard against undue risks to health, safety and
security that may arise in the use of the source. During this stage, the
manufacturer or distributor has a responsibility to verify that radioactive
sources are only being transferred to holders of valid authorizations. In some
situations, the manufacturer or distributor will also install sources into
devices, and provide management oversight training regarding safety culture,
worker training and security measures and procedures. This training may take
into account the nature of the local environment but there should not be any
relaxation in adherence to fundamental principles that govern assurance of
protection against risks to health, safety and security.
In order to ensure continuous control and verify security during the transfer
and use of sources, regulators must ensure that adequate tracking is being
carried out for sources within their jurisdictions. This requires the
establishment of systematic data records and the generation and flow of key
information on the sources. Fundamental data for tracking purposes can be
obtained by requiring the manufacturers and distributors to:
- Manufacture sources with unique identifiers;
- Obtain authorization information for the possession and use;
- Provide transaction records to the regulatory body; and
- Maintain records of disposition of returned sources.
Nuclear regulators must establish national sealed source registries for
high-risk radioactive sources. The sealed source registry will provide the
nuclear regulator with a means to manage the risk posed by these radioactive
sources. The existence of such registries will facilitate the tracking of
high-risk sources as they are being transferred, used, imported or exported.
This will provide tangible assurance concerning accountability for safety and
security.
Periodic regulatory self-assessment must be carried out by the competent
national authority to ensure that existing regulatory programs are effective in
ensuring regulatory oversight of radioactive sources. When needed, the competent
authority should enhance its regulatory programs so as to exercise control that
is appropriate for the risk posed by the radioactive sources within national
boundaries. Control measures should be appropriate not only for changes in types
of sources in use but also to respond to emerging security threats, safety
concerns identified from operating experience, and changes in safety culture in
the regulated community.
Consideration should also be given to requirements for manufacturers or
suppliers to inform the regulator of unusual requests for the supply of
radioactive sources. Examples are requests for sources with increased activity
levels, requests for more sources than normal, and changes in the frequency of
orders. The international expectations dictate there must be a commitment to act
prudently to guard against potential security threats even in the face of
competing commercial interests.
These steps would improve the overall control over sources within national
boundaries. However, countries that manufacture and supply radioactive sources
are not able to obtain the same level of assurance concerning protection of
safety and security with respect to buyers in other countries. In most cases,
there is very little regulatory oversight in controlling the export of sources.
Currently, exporting countries are only able to carry out a limited verification
that buyers are authorized to possess the sources being sought. Clearly, the
verification of the legitimacy of end users, their possession of proper
authorizations, and that adequate provisions for the safety and security of
high-risk radioactive sources are in place, can only be carried out by national
regulatory bodies. This is where assurance can be obtained from commitments by
importing states to the principles incorporated in the IAEA Code of Conduct for
the Safety and Security of Radioactive Sources.
Acceptance of these principles for controlling the export of radioactive
sources, by providing political commitment to the IAEA Code of Conduct for the
Safety and Security of Radioactive Sources and its Export ∕ Import guidance will
ensure international harmonization for continuous regulatory control over
high-risk radioactive sources. The implementation of this guidance through
international agreements would enhance the overall control and security in both
the short and long term.
The final phase of the life-cycle of a radioactive source is its disposal or
recycling when it has reached the end of its useful life. The cost of properly
disposing of an unwanted source is a financial burden users would rather not
have. Manufacturers and exporting countries should be urged to facilitate the
return of unwanted sources to entities that can provide the necessary controls.
It will always be better to do so than to leave the sources in the possession of
individuals with no desire or resources to implement adequate control over them.
One issue that is an obstacle for manufacturers in readily accepting the return
of unwanted sources is the uncertainty of future disposal costs.
In summary, efforts to enhance the control over the safety and security of
radioactive sources cannot be carried out in isolation by the regulatory
authorities. Collaboration with manufacturers and suppliers of sources is needed
when developing and implementing an overall regulatory regime.
In addition bilateral, multilateral, and regional arrangements will also
enhance the control of the safety and security of radioactive sources. On the
North American continent, there has already been some collaboration between
Canada, Mexico, and the United States aimed at trilateral cooperation in
assuring the safety and security of radioactive sources used in the three
States. Member States are encouraged to initiate regional discussions for
successful implementation of the Code and its guidance on the import and export
of radioactive sources. They should capitalize on the experience of other Member
States who have mature regulatory systems.
The IAEA offers several guidance documents that will aid competent
authorities in facing regulatory challenges. Adoption of these principles will
enable international harmonization and promote international cooperation. The
IAEA has in place several regulatory enhancement programs. Member States are
encouraged to embark on these programs either to enhance their existing
regulatory programs or to establish new ones.
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