∙the radiation protection of people external to the veterinary facilities who may participate in the diagnostic procedures; ∙the formalisation and traceability of the documents proving due compliance with the regulatory requirements relating to radiation protection. There are also some (rare) cases of veterinary facilities in which the radiation protection organisation is highly unsatisfactory. These shortcomings can lead ASN to take more stringent or even enforcement measures, if a “soft” approach has no effect. Over the last few years ASN has also observed large-scale recourse to Radiation Protection Organisations (RPOs) external to the veterinary facilities to fulfil the function of Radiation Protection Expert (RPE) in these facilities. Such outsourcing is possible, but must not reduce the sense of responsibility of the veterinary surgeons, who retain prime responsibility for appropriate radiation protection in their facilities. The strong nationwide commitment of the profession to harmonising practices, raising awareness, training student veterinary surgeons and drafting “framework documents” and guides is considered very positive by ASN, which has regular interchanges with the profession’s national bodies (more particularly the veterinary radiation protection commission). These interchanges enable ASN to take the particularities of the veterinary environment into account when defining its policy. For example, in 2024 they led ASN to introduce an administrative simplification for non-salaried veterinary surgeons (private practice associate, locum or consultant veterinary surgeon) who use the diagnostic devices provided by a veterinary facility. This simplification, which takes into account low radiation exposure risks, is therefore not applicable to activities that are subject to the licensing system and present substantial risks. 1.3.3 The other uses of electrical devices emitting ionising radiation This category covers all the electrical devices emitting ionising radiation other than those mentioned above and which are not concerned by the licensing, registration or notification exemption criteria set out in Article R. 1333-106 of the Public Health Code. This category includes, for example, devices generating ionising radiation but not used for this property, namely ion implanters, electron-beam welding equipment, klystrons, certain lasers, certain electrical devices such as high- voltage fuse tests. Lastly, some applications use particle accelerators (see point 3.3.1). 2 The legislative and regulatory framework for industrial, research and veterinary activities 2.1 The authorities regulating the sources of ionising radiation ASN is the Authority that grants the licenses, issues the registration decisions and receives the notifications, depending on the regulatory regime applicable to the nuclear activity concerned. However, to simplify administrative procedures for licensees already licensed under another system, the Public Health Code makes specific provisions. This concerns more specifically: ∙The radioactive sources held, manufactured and/or used in installations licensed under the Mining Code (Article L. 162-1) or, for unsealed radioactive sources, those held, manufactured and/or used in Installations Classified for Protection of the Environment (ICPEs) which come under Articles L. 511-1 to L. 517-2 of the Environment Code, and have a licensing system. The Prefect is responsible for including, in the licenses he delivers, radiation protection requirements for the nuclear activities carried out on the site. ∙The installations and activities relating to national defence, for which Defence Nuclear Safety Authority (ASND) is responsible for regulating the radiation protection aspects. ∙The installations authorised under the BNI legal system. ASN regulates the radioactive sources and electrical devices emitting ionising radiation necessary for the operation of these installations under this system. Holding and using other sources within the bounds of the BNI remain subject to licensing pursuant to Article R. 1333-118 of the Public Health Code. These provisions do not exempt the licensee from complying with the requirements of the Public Health Code, and in particular those relative to source acquisition and transfer; they do not apply to the distribution, importing and exporting of radioactive sources, which remain subject to ASN licensing under the Public Health Code. Only the facilities possessing unsealed radioactive substances in quantities exceeding 1 tonne (t) or managing radio- active waste in quantities exceeding 10 cubic metres (m3) for either of the activities are subject to the system governing ICPEs (excluding the medical sector and particle accelerators). Any sealed radioactive sources also possessed or used by these establishments are regulated by ASN under the Public Health Code. GRAPH 4 Use of electrical devices generating ionising radiation for veterinary activities 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000 5,500 6,000 2024 2023 2022 2021 2020 15 122 219 335 Number of veterinary authorisations Number of veterinary notifications Number of veterinary registrations 254 ASN Report on the state of nuclear safety and radiation protection in France in 2024 Sources of ionising radiation and their industrial, veterinary and research applications
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