Inspection report: Australian Federal Police, ACT, 9-10 September 2020

An inspection was conducted as part of ARPANSA’s baseline inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act), the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations), and conditions of source licence S0056. 

The scope of the inspection included an assessment of the AFP’s performance at the Belconnen and Majura sites against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of the sources. 

Background

The AFP is authorised under section 33 of the Act to deal with controlled apparatus. This inspection covered the industrial x-ray equipment, handheld backscatter x-ray imagery sources, x-ray diffraction (XRD) and x-ray fluorescence (XRF) analytical devices that the AFP uses for examination of potential explosive devices and other forensic purposes.  

The main codes and standards applicable to this apparatus are those that appear in section 59 of the Regulations and: 

• RPS-C1: Radiation protection in Planned Exposure Situations (2016)
• RHS-9: Code of Practice for the Protection against Ionising Radiation Emitted from X-ray Analysis Equipment (1984)
• AS/NZS 2243.4 Safety in laboratories Part 4: Ionizing radiations (2018)
• RPS-C4 Code of Radiation Protection Requirements for Industrial Radiography

Observations

In general, the management and operation of the controlled apparatus at both sites was found to be satisfactory. It was identified during the site inspections that there is an area for improvement with respect to signage used for examination, site control and laboratories. Suitable control of the apparatus keys at Belconnen and for portable x-ray at Majura also required attention. The AFP’s risk assessments as they pertain to their plans and arrangements could also be improved and integrated into their quality management system. Rectification of these issues will strengthen the AFP’s plans and arrangements and physical safety practices. 

Configuration management

The AFP operates under Source Licence S0056 and has a number of physical sites and controlled apparatus dealings across the country.  

The Belconnen site houses a number of industrial x-ray devices used by the AFP’s Bomb Response Group (BRG). The inspection of the Majura site focussed on controlled apparatus utilised by the AFP’s forensic services business unit including XRF, XRD and handheld backscatter apparatus housed within Chemical Criminalistics and the Imagery and Geomatics laboratories. 

Of the controlled apparatus observed during both site inspections, all were listed in the AFP’s source inventory workbook. 

Performance reporting verification

The AFP has adopted formal processes, procedures and reporting structures for managing radiation safety. AFP’s reporting obligations are conducted in accordance with their licence requirements in a timely manner.  

The AFP manages all dealings with their controlled apparatus through its Work Health & Safety (WH&S) framework. A Radiation Safety Officer (RSO) is employed to coordinate these dealings centrally including the management of the AFP’s plans and arrangements. Local WH&S representatives report through to the RSO and assist the local business units and unit commanders with specific arrangements to achieve a uniform approach in their dealings with the controlled apparatus.

Documented risk assessments were sighted by the inspection team, however, some aspects of the centralised risk assessment required updating. 

Training

Each AFP staff member who is required to use controlled apparatus undergoes internal AFP radiation awareness training and training specific to the apparatus used. Training material was viewed by the inspectors at both sites and is in accordance with manufacturer requirements. Training records for staff at each site are recorded in the AFP’s ‘I Aspire’ Learning Management System and these were sighted by the inspection team. Refresher training is provided every 2 years and ongoing apparatus specific training provided at the local level pertinent to the risks and hazards faced. WH&S representatives at both sites have also undertaken the ANSTO RSO course. This provides a level of radiation safety assurance and support for the primary RSO (currently Sydney based).  

Inspection Testing and Maintenance 

The AFP’s National Guideline on Safe Working with Radiation requires that all licensed portable and fixed controlled apparatus are maintained and calibrated in accordance with manufacturer’s requirements. Calibration and maintenance records for the controlled apparatus at both Belconnen and Majura sites were provided during the inspection and found to be satisfactory.  

Security

Access to both sites, storage areas and laboratories was appropriate and commensurate with the operational aspects of the AFP. During the inspection, it was observed at both sites that whilst all deployable controlled apparatus were securely stored or secured within appropriately access controlled laboratories, X-ray generator keys were found either in the units (Belconnen), or in close proximity to the units (Majura – 4 draw filing cabinet on general floor area). It was also observed that the operating key was left in the Terra XRD unit housed within the Chemical Criminalistics laboratory in a laboratory with signage insufficient for an area where controlled radiation apparatus is used.

Radiation protection and signage

The AFP holds a centralised dose register for all personnel and locations. Trend analysis and review of doses is undertaken by AFP-WHS with any anomaly actioned as required.  

Signage issues were observed with some differences noted between sites in particular with the deployable roles within the AFP. Radiation warning signs/barrier tape was insufficient for the deployable operations of the BRG. The deployable kits used by the Imagery and Geomatics team was appropriate and stored within the apparatus. 

It was noted during the inspection that radiation hazard warnings were insufficient or missing on some door/barrier areas within the Chemistry Criminalistics Laboratories.  

Findings

The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions.

The inspection revealed the following areas for improvement:

• Risk Assessments to be completed and integrated into AFP Quality Management System
• Keys to be removed from controlled apparatus and securely stored
• Appropriate signage to be displayed in the chemical criminalistics laboratory
• Ensure uniformity of signage and barrier tape across the organisation for AFP deployable portable x-ray systems

It is expected that improvement actions will be taken in a timely manner.