Inspection report: ANU Research School of Astronomy and Astrophysics (RSAA) and the Australian Phenomics Facility (APF), S0027

This inspection was conducted as part of ARPANSA’s source inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998, the Australian Radiation Protection and Nuclear Safety Regulations 2018, and conditions of source licence S0027. The scope of the inspection included an assessment of performance at the ANU Mt Stromlo and Acton premises of RSAA and APF, respectively, against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and a physical inspection of sources.

Background

ANU is a research-intensive university located in Acton, Australian Capital Territory (ACT), and specialises in a range of activities that require the use of radioactive materials and ionising and non-ionising radiation apparatus. The ANU source licence covers several schools at the Acton campus and one at Mt Stromlo, ACT, many of which use controlled apparatus and controlled materials as part of their research and teaching roles. ANU is licensed under Section 33 of the Act to deal with controlled material and controlled apparatus for research purposes in its various schools. The main codes and standards applicable to these schools under the ANU licence are: 

• Radiation Protection Series No. 12 Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006) (RPS 12) 
• Australian/New Zealand Standard Safety in Laboratories Part 5 – Non-ionizing radiations-Electromagnetic, sound and ultrasound (2024) (AS 2243.5:2024) 
• Australian/New Zealand Standard Safety of laser products Part 1: Equipment classification and requirements (AS/NZS IEC 60825-1:2014) 
• Australian/New Zealand Standard Safety of laser products Part 14: A user’s guide (AS/NZS IEC 60825-14:2022)

Observations

In general, the management of radiation safety at both RSAA and the APF in relation to controlled material and controlled apparatus was found to be sound. There appeared, however, to be areas where there was room for improvement as follows: 

• The local documentation for both schools contained no particular reference to the use of ultraviolet radiation (UVR) equipment despite the use of such controlled apparatus in both schools. It should be noted that ANU’s Radiation Management Plan (RMP), ANU’s overarching Plans and Arrangements, does contain such referencing. The importance of this is highlighted by the fact that researchers from institutions in jurisdictions that do not regulate the use of UVR could be unaware of their obligations unless they consult the ANU’s RMP. 
• Some equipment locations noted in RSAA’s source inventory workbook (SIW) did not match the actual laboratory location.

Warning signs in one of the laser laboratories at RSAA were an older style version in red and white, and therefore did not meet the requirements of the Australian Standard. However, the laboratory had not been used for laser work for many years. Should laser work be resumed in future, these warning signs would need to be replaced to meet the Australian Standard.

Effective control

Management commitment and statutory and regulatory compliance

ANU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of radiation sources throughout all schools at the university. This is supported by the RMP to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions for licence S0027. This current inspection concentrated on the ‘local’ RMPs of RSAA and APF. 

ANU has a Radiation Safety Advisory Group (RSAG) which meets quarterly and comprises representation from all schools including RSAA and APF. The ANU Work Health and Safety Consultant, as a member of RSAG, coordinates information for quarterly reports with input from each school, including RSAA and APF. Once collected, this information is consolidated into one final report to ARPANSA. ANU quarterly reports have been submitted to ARPANSA in a timely manner in recent years, and contained relevant information, including details of compliance with the Act and Regulations. 

A new project involving a high-power laser was planned for RSAA by the end of 2025. Although RSAA is licensed deal with lasers, the power of the proposed laser and the way it is expected to be used would necessitate a revised risk assessment and a sign-off by RSAG before commencement of the project. A Section 63 approval for the new work might also be required prior to commencement.

Communication

Radiation safety matters for both RSAA and APF are reported according to their local WHS plans. The reporting line provides for communication to the relevant Heads of Departments/Schools, WHS committee meetings and the ANU RSAG.

Safety management

RSAA has not performed any laser work for approximately 5 years or more. The lasers are stored in laboratories to which only persons who have the appropriate induction and training for the particular laboratory have access via the Cardax system. Further, the operating keys for all lasers at RSAA are kept with the laser safety officer (LSO). As such, no-one would be able to use any RSAA laser without the knowledge of the LSO. 

The local RMPs outline the training requirements, safe working procedures and accident/emergency response requirements relating to the use of radiation within the school.

Training and education

All personnel using controlled apparatus (or controlled material) at ANU are required to undertake training related to the type of source they will use. This training includes: 

1. Tier 1: general induction
2. Tier 2: school induction 
3. Tier 3: individual laboratory induction and specific use training, the extent of which depends on the proposed dealing for the given individual. 

In the case of APF, there is an additional induction for the floor of the building to which a person requires access. Access to laboratory areas at both schools is restricted to those personnel who have undergone appropriate induction training or are otherwise closely escorted by appropriately trained staff.

Radiation protection

The APF requires annual calibration of all fumehoods, including those used with the UVR sources, by external, third-party accreditors for its own quality control purposes. Records of these calibrations were seen during the inspection. During the inspection, two types of UVR fumehoods used at APF were identified which employed multiple point failure-protection of the UVR source and required special tools to obtain access to the cabinet. These types were therefore considered to be exempt dealings and can be removed from the APF SIW. Other than the instance of the out-of-date laser signage at RSAA outlined above, the warning signage at both schools was satisfactory. 

Personal protective equipment (PPE) 

Appropriate laser protective eyewear was available to RSAA staff and students at the entry doors to the laser laboratories. 

Monitoring of the individuals 

RSAA required retinal scanning of all staff requiring access to laser laboratories as a ‘baseline’ health record in the event of a laser strike during work at the school. Records of these retinal scans were kept on the relevant personal files

Radioactive Waste 

As only controlled apparatus was used at either school, no radioactive waste was produced. 

Security 

RSAA and APF buildings are protected by the Cardax system, and access is only available to those who have completed the appropriate training. 

Emergency plans 

The ANU has an overarching emergency plan and each school has its own plan based on the risks at that location.

Findings 

The licence holder was found to comply with the requirements of the Act, the Regulations, and licence conditions. The inspection revealed the following areas for improvement: 

• There was no particular reference to UVR use in the local plans and arrangements of either school, despite the use of such controlled apparatus in both schools. 
• Some laboratory locations listed in the RSAA SIW did not match the actual location of the given device. 

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