The methods of regulating the radiation protection stakeholders are presented in Table 1. They were updated with the June 2018 publication of the Decrees transposing European Directive 2013/59/Euratom of 5 December 2013 setting the Basic Standards for Health Protection against the dangers arising from exposure to ionising radiation. Regulating the application of labour law in the Nuclear Power Plants ASN carries out labour inspectorate duties in the 18 NPPs, the EPR reactor under construction at Flamanville and 11 other installations, most of which are reactors undergoing decommissioning. The regulation of safety, radiation protection and labour inspection very often covers common topics, such as worksite organisation or the conditions of use of outside contractors. The ASN labour inspectors have four essential duties: ∙ checking application of all aspects of labour legislation (health, occupational safety and working conditions, occupational accident inquiries, quality of employment, collective labour relations); ∙ advising and informing the employers, employees and personnel representatives about their rights, duties and labour legislation; ∙ informing the administration of changes in the working environment and any shortcomings in the legislation; ∙ facilitating conciliation between the parties. The ASN labour inspectors have the same powers and the same prerogatives as common law labour inspectors. They belong to the labour inspectorate system for which the central authority is the General Directorate for Labour. The duties of the labour inspectors are based on international standards (International Labour Organisation –ILO– Convention No. 81) and national regulations. ASN carries them out in liaison with the other Government departments concerned, mainly the departments of the Ministry responsible for labour. ASN has set up an organisation designed to deal with these issues. The action of the ASN labour inspectors (20 staff qualified as labour inspectors by ASN, representing 8.30 Full-Time Equivalent of which 2 are for the labour inspectorate mission) has been reinforced in the field since 2009, particularly during reactor outages, with inspection visits, advisory roles at the meetings of the Committee for Health, Safety and Working Conditions (CHSCT) and the Inter-company Committees on Safety and Working Conditions (CIESCT), as well as regular discussions with the social partners. 2.2 Internal checks performed by the licensees 2.2.1 Internal oversight of the licensees of Basic Nuclear Installations In 2017, ASN issued a resolution (2017-DC-0616 of 30 November 2017) which specifies the criteria for distinguishing the noteworthy modifications requiring ASN authorisation from those simply requiring notification. It also defines the requirements applicable to the management of noteworthy modifications, more particularly the internal check procedures to be implemented by the licensees. ASN checks correct application of the provisions stipulated by this resolution. 2.2.2 Internal monitoring of radiation protection by the users of ionising radiation sources The provisions of Articles R. 4451-40 to R. 4451-51 of the Labour Code reorganised the procedures for the performance of technical monitoring, now referred to as “verifications”. They harmonise the relevant requirements with those applicable to other risks, notably the electrical risk (Article R. 4226-14), or more generally for work equipment (Article R. 4323-22), making the measures to be taken proportionate to the nature and scale of the risk. During the lifetime of the work equipment or the facilities, these verifications take the form of initial verifications (by an accredited organisation), which may be repeated, and periodic verifications (by the Radiation Protection Advisor –RPA). The Order of 23 October 2020, set out in Article R. 4451-51, notably determines the work equipment or work equipment categories and the type of radioactive sources for which the employer is required to conduct an initial verification and, as applicable, to repeat it, and the procedures and conditions for the performance of these verifications. 2.3 Approval of organisations and laboratories ASN can draw on the results of inspections performed by the independent organisations and laboratories that it approves and whose actions it monitors. Article L.592-21 of the Environment Code states that ASN issues the required approvals to the organisations participating in the verifications and monitoring concerning nuclear safety or radiation protection. The list of approved organisations and laboratories is available on asn.fr. TABLE Methods of ASN regulation of the various radiation protection players EXAMINATION/AUTHORISATION INSPECTION COOPERATION Users of ionising radiation sources • Examination of the dossiers required by the Public Health Code (Articles R. 1333-1 et seq.) • Pre-commissioning inspection, mainly in themedical field • Receipt of notification, registration or issue of authorisation (Article R. 1333 ‑8) • Radiation protection inspection (Article L. 1333 ‑29 of the Public Health Code) • Jointly with the professional organisations, drafting of guides of good practices for users of ionising radiation Organisations approved for radiation protection checks • Examination of approval application f iles for performance of inspections required by Article R. 1333 ‑172 of the Public Health Code • Organisation audit • Delivery of approval • Second level inspection: ‒ in-depth inspections at head off ice and in the branches of the organisations ‒ unannounced supervision inspections in the f ield • Jointly with the professional organisations, drafting of rules of good practices for performance of radiation protection checks 1 146 ASN Report on the state of nuclear safety and radiation protection in France in 2021 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION
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