As for the distributors of accelerators or X-ray emitting devices, the monitoring tools that they put into place to identify the devices distributed and who acquired them often need to be reinforced, to avoid compromising any recall or OEF processes. The actions carried out by the licensees in recent years are continuing to improve radiation protection within the research laboratories, even if these efforts appear to be flagging somewhat. Correctly taking account of radiation protection is to a large extent based on the involvement of the radiation protection advisers and depends on the resources placed at their disposal. It should be recalled that the radiation protection issues in many research laboratories tend to be minor or are decreasing owing to the use of techniques other than those using ionising radiation. The conditions for the storage and elimination of waste and effluent remain the primary difficulties encountered by the research units or universities, including with regard to the performance and traceability of checks prior to elimination, the recovery of “legacy” unused sealed radioactive sources or the regular elimination of stored radioactive waste. On these latter points, the lack of forward planning for the funding needed to manage “legacy” sources or waste and their prior characterisation if necessary, is often observed. In 2024, two significant events – both correctly managed – recalled that vigilance is required during maintenance of particle accelerators or in the event of any changes to their conditions of use. Finally, the facilities are also still experiencing difficulties in taking on board and correctly implementing checks on equipment, workplaces and instrumentation, as a result of changes to the Labour Code and Public Health Code in 2018, in particular in the case of joint research units. With regard to the veterinary uses of ionising radiation, ASN can see the results of the efforts made by veterinary bodies over the past few years to comply with the regulations, notably in conventional radiology activities on pets. For practices concerning large animals such as horses, or performed outside veterinary facilities, ASN considers that the implementation of radiological zoning and the radiation protection of persons from outside the veterinary facility who take part in the radio- graphic procedure, are points requiring particular attention. There are however rare cases of veterinary structures with a highly unsatisfactory radiation protection organisation, which, if explanatory measures are not sufficient, may lead ASN to take more rigorous steps, or even enforcement measures. In addition, the growing outsourcing of the RPE-O function, with large-scale use of RPOs from outside the facilities, must not lead to veterinarians abdicating their prime responsibility for the level of radiation protection in their facilities. THE PROTECTION OF RADIATION SOURCES AGAINST MALICIOUS ACTS The inspections conducted by ASN show that the licensees are gradually implementing the measures needed to comply with the requirements set out in the Order of 29 November 2019, more particularly when high-level radioactive sources or batches of equivalent sources are used. Thus, on the basis of the inspections conducted in 2024: ∙Source categorisation, an essential step in identifying the applicable requirements and implementing an approach proportionate to the risks, was carried out for the vast majority of facilities. ∙The source protection policy, supported by the facility’s general management and promoting the concrete measures to be taken, leads to no comments on the part of ASN in two-thirds of the industrial facilities and half the medical facilities, which constitutes progress by comparison with previous years. ∙Even if all the facilities inspected have taken steps to protect the sources, a little over half of them had not formally identified the physical barriers guaranteeing this protection, or demonstrated that they offered adequate intrusion resistance. On the other hand, only 20% of the medical facilities had carried out this analysis, which is a deterioration by comparison with the results of the inspections carried out in 2023. ∙In one third of the industrial facilities and half the medical facilities, no preventive maintenance programme is defined for the equipment designed to detect intrusions. In addition, when there is a programme, it is only correctly implemented in less than half the facilities. ∙The issue of nominative permits for access to sources has barely progressed and still needs to be implemented in nearly half the facilities. ∙Half of the industrial facilities do not take steps to identify and protect sensitive information concerning source security. This finding is less severe for medical facilities, because only one third of them are in this situation, which is a clear improvement on 2023. Compliance with the requirements set for source protection against malicious acts usually implies modifications to the facilities and organisational and human changes, which may prove costly given the resources available to the facility. In the gamma radiography sector for example, ASN finds that the requirements for the protection of sources against malicious acts sometimes led the licensee to close certain facilities or branches to avoid having to upgrade them, with the result being increased operational constraints, notably longer transport times to the sites where the non-destructive inspections are to be conducted. ASN asks the gamma radiography contractors to take greater account of this question in their responses to invitations to tender and in the preparation of their work. It also recalls that it is the responsibility of the ordering parties to ensure correct performance conditions for the inspections they order. Overall, whether in the industrial or medical sector, ASN considers that considerable progress is still needed. In 2025, ASNR will continue its actions to raise licensee awareness on these subjects. ASN Assessments 30 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
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