Inspection report: Australian Antarctic Division – Polar Medicine Unit (AAD-PMU) (R21/09765)

An inspection was conducted as part of ARPANSA’s planned inspection program. Due to the COVID-19 pandemic, the inspector did not enter the licence holder’s premises; instead, the inspection was conducted using documents, photographs, and records sent by the licence holder, and further clarification via phone or email where necessary.

The purpose of the inspection was 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 S0008.

The scope of the inspection included an assessment of AAD-PMU’s medical facilities at its Antarctic bases (Davis and Macquarie Island) and the equipment destined for the new ship RSV Nuyina against the Source Performance Objectives and Criteria. 

Background

The Australian Antarctic Division (AAD), as leader of Australia's Antarctic Program, plays an important role in advancing Australia's Antarctic interests and achieving the government's Antarctic goals. AAD-PMU is part of the Department of Agriculture, Water, and the Environment, authorised under section 33 of the Act to deal with controlled apparatus. The AAD Chief Medical Officer (CMO) is responsible for medical diagnostic radiation safety management given the specific clinical expertise and knowledge requirements.

The Australian Antarctic Division, based in Kingston Tasmania, manages and administers Australia’s interests in Antarctica and the Southern Ocean along with the sub-Antarctic territories of Heard Island and McDonald Island and their adjacent waters.  The AAD leads, coordinates, and delivers the Australian Antarctic Program which is focused on conducting world-class science of national importance and global significance.

AAD-PMU uses mobile or portable medical and dental X-ray equipment to provide health care at Casey, Davis and Mawson stations on Antarctica, the subantarctic station at Macquarie Island, and supply ships. The Antarctic stations and the ship are isolated from usual medical facilities due to Antarctica's remoteness.  Each station and ship therefore require on-site Antarctic medical practitioners (AMPs) who provide surgical, medical and dental care to expeditioners.  The AMPs are, in turn, supported by full-time medical practitioners located at the AAD-PMU's headquarters in Kingston, Tasmania.

Medical diagnostic and dental radiography are part of the services these AMPs provide. The medical and dental equipment are regularly rotated through stations and the ship and back to the headquarters at Kingston. Once the equipment arrives at Kingston, AAD-PMU sends it for testing and servicing by appropriately licensed personnel from the equipment supplier.

The main codes and standards applicable to these sources are:

• Radiation Protection Series C-5: Code for Radiation Protection in Medical Exposure (2019) (RPS C-5)
• Radiation Protection Series 10: Code of Practice and Safety Guide for Radiation Protection in Dentistry (2005) (RPS 10)
• Australian/New Zealand Standard, Safety in Laboratories Part 4: Ionising radiations (AS/NZS 2243.4:2018)

Observations

In general, the management of radiation safety at AAD-PMU in relation to controlled apparatus was found to be sound. In this instance the e-inspection was limited to the X-ray units at Davis and Macquarie Island stations and equipment to be sent to the new Australian icebreaker RSV Nuyina.

Performance reporting verification

The Chief Medical Officer (CMO) coordinates information for quarterly reports combining multiple sites in Antarctica, subantarctic Tasmania, Kingston and Southern Ocean Vessels. Once collected, this information is consolidated into a single final report to ARPANSA.  AAD quarterly reports have been submitted to ARPANSA in a timely manner in recent years and contain relevant information including details of compliance with the Act and Regulations. The CMO has medical oversight of diagnostic radiation safety. Section 63 and section 65 applications are also coordinated through the CMO as needed.

Configuration management

Of the controlled apparatus pictures provided for the e-inspection, all matched the internal designations assigned to those sources and listed in the source inventory workbook (SIW).

Training and education

All personnel using the X-ray equipment are required to undertake training related to the source they will be using before being permitted to perform medical or dental radiography.  This training includes general radiation induction, individual medical facility induction and specific use training, the extent of which depends on the proposed dealing for the given person. Training records are kept electronically. Certificate of attendance and completion of user training courses in 2020 for several individuals authorised to use the controlled apparatus were provided for the e-inspection.

Access to each medical facility is restricted to approved operators, patients and if required medical facility maintenance personnel.  Mobile diagnostic X-ray sources are clearly marked ‘AAD approved operators only’. A list of the approved operators was provided for the e-inspection.

Security

With the rotation of medical and dental X-ray units from the various stations and the ship being returned to AAD Kingston, they are stored in the AAD building beyond the public areas which is protected by an electronic access control system.  The existing security measures are therefore considered appropriate.

Radiation protection

AAD-PMU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use of radiation emitting apparatus at the various stations and ship.  This is supported by a comprehensive plans and arrangements, Radiation Management Plan (RMP) version 2, Medical Diagnostic X-ray Safety Management (SM) version 3 and Medical Diagnostic X-ray Radiation Protection (RP) version 4 to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. These documents were all recently (March 2021) reviewed by various AAD-PMU staff and approved by the CMO.

Photographic evidence was provided to show the X-ray room access doors at Davis and Macquarie Island stations are fitted with appropriate ionising radiation and warning signs restricting access to only approved staff. An example of a radiation warning label was provided by the CMO to be implemented in 2021/22 and displayed on all AAD-PMU diagnostic X-ray sources indicating that the item is a controlled apparatus registered with ARPANSA. Photographs were also provided of the PPE (lead aprons) used by the operators of the medical and dental X-ray units.

AAD-PMU provided documentary evidence that each X-ray unit was tested in accordance with Tasmanian requirements by a licensed tester upon rotation of the equipment back to Kingston. A recent excel spreadsheet was provided which shows routine maintenance tasks for the X-ray units using phantoms to take images which are then uploaded to Kingston PMU for review. The CMO provided documentation that the X-ray units are serviced by the manufacturer as required in the SM document.

The RMP requires that diagnostic examinations and doses are recorded and reviewed. The CMO has stated that the examinations and doses are recorded in a logbook with copies subsequently provided for the e-inspection. Externally qualified experts (medical and dental radiologists) are available to AAD-PMU for advice on optimisation, dosimetry and quality assurance of clinical X-ray results. The need for diagnostic procedures, both medical and dental, are assessed on-site and assistance sought from the CMO if necessary.  Lead aprons are provided to the patient for all dental procedures. 

Arrangements are in place for interpretation of the images by radiologists at the Royal Hobart Hospital or dentists at the Royal Dental Hospital (Melbourne). In addition, the doses are administered as per the Polar Medicine Radiographic Exposure Table. AAD-PMU also provided photographic evidence of each logbook showing details of the use of the equipment such as the diagnostic procedure carried out, QA checks, the date and the person carrying out the procedure.

Findings

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