3 Roles and responsibilities in regulating the transport of radioactive substances 3.1 Regulation of nuclear safety and radiation protection In France, ASN has been responsible for regulating the nuclear safety and the radiation protection of transports of radioactive substances for civil uses since 1997, while the Defence Nuclear Safety Authority (ASND) fulfils this role for transports relating to national defence. Within its field of competence, ASN is responsible, in terms of safety and radiation protection, for the regulation and oversight of all steps in the life of a package: design, manufacture, maintenance, shipment, actual carriage, receipt and so on. 3.2 Protection against malicious acts The prevention of malicious acts consists in preventing sabotage, losses, disappearance, theft and misappropriation of n uclear materials (as defined in Article R*. 1411-11-19 of the Defence Code) that could be used to manufacture weapons. The Defence and Security High Official (HFDS), under the Minister responsible for energy, represents the Regulatory Authority responsible for preventing malicious acts targeting nuclear materials. In the field of transport security, the IRSN Transport Operations Section (EOT) is responsible for managing and processing applications for approval of nuclear material shipments, for supervising these shipments and for notifying the authorities of any alerts concerning them. This security mission is defined by the Order of 28 February 2023 relative to the security of transport of nuclear materials, implementing Articles R. 1333-4 and R. 1333-17 to R. 1333-19 of the Defence Code. Thus, prior to any transport operation, the Defence Code obliges the carriers to obtain a transport authorisation. The EOT reviews the corresponding application files. This review consists in checking the conformity of the intended provisions with the requirements defined by the Defence Code and the above-mentioned Order of 28 August 2023. ASN has initiated the process to update its resolution 2015-DC-0503 of 12 March 2015 relative to the notification system for companies transporting radioactive substances on French territory. This update aims to introduce an authorisation system for the transport of the most radioactive sources, in the light of their security implications. The interface between the provisions taken from the new regulations on the protection of ionising radiation sources and batches of category A, B, C and D radioactive sources against malicious acts (Order of 29 November 2019, amended) and the transport regulations will be dealt with. 3.3 Regulation of the transport of dangerous goods Regulation of the transport of dangerous goods is the responsibility of the Dangerous Materials Transport Commission (MTMD) of the Ministry responsible for the environment. This structure is tasked with measures relative to the safe transport of dangerous goods other than class 7 (radioactive) by road, rail and inland waterways. It has a consultative body (standing sub-committee in charge of dangerous goods transport, within the CSPRT that is consulted for its opinion on any draft regulations relative to the transport of dangerous goods by rail, road or inland waterway. Inspections are carried out by land transport inspectors attached to the Regional Directorates for the Environment, Planning and Housing. For the regulation of dangerous goods to be as consistent as possible, ASN collaborates regularly with the administrations concerned. The breakdown of the various inspection duties is summarized in Table 3. TABLE 3 Administrations responsible for regulating the mode of transport and the packages(*) Mode of transport Regulation of mode of transport Package regulation By sea Directorate General for Infrastructures, Transports and the Sea (DGITM) at the Ministry for the Environment. In particular, the DGITM is responsible for regulating compliance with the prescriptions applicable to ships and contained in the International Code for the Safe Carriage of irradiated nuclear fuel, plutonium and high-level radioactive wastes on board ships (“Irradiated Nuclear Fuel” Code). The DGITM has competence for regulation of dangerous goods packages in general and is in close collaboration with ASN for radioactive substances packages. By road, rail and inland waterways General Directorate for Energy and Climate (DGEC) of the Ministry for the Environment. The General Directorate for the Prevention of Risks (DGPR) is responsible for regulation of packages of dangerous goods in general and, in close collaboration with ASN, of packages of radioactive substances. By air General Directorate for Civil Aviation (DGAC) at the Ministry for the Environment. The DGAC has competence for regulation of dangerous goods packages in general and is in close collaboration with ASN for radioactive substances packages. * In 2025, ASNR takes over the roles and ASN and IRSN regarding transport. 286 ASN Report on the state of nuclear safety and radiation protection in France in 2024 Transport of radioactive substances
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