Inspection report: Australian Federal Police, S0056, 10 December 2024

This is the record of an inspection conducted as part of ARPANSA’s source 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 performance at the AFP’s Majura Forensic Services Group’s Forensic Chemical Analytics Laboratory (FCAL) and the Forensic Search and Imagery Section (FSAIS) against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of sources.

Background

The AFP is authorised under section 33 of the Act to deal with controlled apparatus. This inspection focussed on the AFP’s Forensic analytical laboratory and Technical Investigations sections’ holdings including X-ray diffraction (XRD), handheld backscatter X-ray and a number of controlled analytical devices incorporating Class 4 lasers. The main codes and standards applicable to this licence are: 

• RPS C-1 (Rev. 1) Code for Radiation Protection in Planned Exposure Situations (2020) 
• RHS 9 Code of practice for protection against ionizing radiation emitted from X-ray Analysis Equipment (1984)
• Australian/New Zealand Standard: Safety in laboratories Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
• RPS 11 Code of Practice for the Security of Radioactive Sources (2019)

Observations

In general, the management and operation of the controlled apparatus within the FCAL and FSAIS areas
were found to be satisfactory. Several (4) areas for improvement (AFIs) were identified during the 
inspection: centralising procurement procedures of controlled apparatus (TruNarc); updating work 
instructions for the Raman and First Defender handheld spectrometers within the FCAL; updating
references to codes and standards within FCAL standard operating procedures (SOPs); and using 
personal dosimetry devices in the FCAL laboratory or disposing of the currently unused XRD device
therein.

Rectification of these issues will strengthen AFP’s plans and arrangements and physical safety practices
(which are still under development).

Effective control

Accountabilities and responsibilities

The AFP operates under Source Licence S0056 and has several business units dealing with a number of controlled apparatus within the Majura site. The AFP’s organisational and radiation safety structure resides under the SHIELD, Injury Prevention section of the AFP’s People and Culture Command. The licence nominee is an un-sworn officer at the APS level equivalent of an AFP Superintendent and is based in Canberra. The Radiation Safety Officer (RSO) is an un-sworn staff member of the AFP whose primary role is National Safety Advisor – Strategy. This inspection focussed on the use of controlled apparatus in the Forensic Chemical Analytics Laboratory (FCAL) and the Forensic Search and Imagery Section (FSAIS). Of the controlled apparatus observed during both site inspections, all were listed in the AFP’s source inventory workbook and business unit specialists were on site for the inspection.

Management commitment

A recent inspection of a different business unit found the AFP in breach of s61(1) of the Regulations. Following this breach, and an AFI for the AFP to conduct a review of their radiation management structure, steps had been taken to strengthen this area. An additional RSO to support the primary staff member was recruited. Local business unit specialists who operate and are responsible for the controlled apparatus were also on site during the inspection. Both the new deputy RSO and the business unit specialist staff members have completed or planned to undertake (respectively) the ANSTO RSO training. Senior management of the Forensic Services site were also in attendance for the entry meeting.

Statutory and regulatory compliance

The last inspection at the Majura forensics department site was undertaken on 10 September 2020. Several AFIs were identified and were addressed at the time. Site management were engaged in the inspection, and AFP quarterly reports have been submitted in a timely manner.

Safety management

Managing change

The AFP RSO raised during the entry and exit meetings that acquisition of TruNarc Handheld Narcotics Analysers (which incorporate a Class 3B Laser), by AFP members across multiple sites and commands, had been occurring. Due to the cost of these devices, uncontrolled purchase has been occurring as the units are below the minimum purchasing limit ($10K) before CAPEX expenditure and procurement rules within AFP are mandated. Whilst the AFP is licensed for these devices, the ability to control the ad hoc purchasing of these units and maintaining an accurate Source Inventory Workbook (SIW) appears to be impacted. Inspectors reminded AFP WHS Team staff of the SIW requirements and licence conditions, and raised the potential for AFP to address this issue through procurement requirements and/or through the AFP’s WHS systems and procedures. This is considered to be an area for improvement.

Training and education

Each AFP staff member who is required to use controlled apparatus undergoes internal AFP radiation awareness training, and training specific to the apparatus used which 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 is provided at the local level pertinent to the risks and hazards faced. WH&S representatives at the Majura site and from the AFP Shield team have undertaken or are in the process of attending the ANSTO RSO course.

Radiation protection

Principles of radiological protection

Controlled apparatus within the FCAL and the FSAIS were found to be in good working order, with interlocks in place and securely stored. Both the FCAL and the FSAIS storage area/workshop had the required warning signage on or adjacent to entry doors. Manufacturer manuals held for the Raman and First Defender mobile laser spectrometers within the FCAL were reviewed. These manuals did not highlight safe work instructions/operation. These manuals require updating and need to address safe operation of the controlled apparatus and reporting requirements. This is considered to be an area for improvement. Some laboratory SOPs in the FCAL did not reference current codes and standards. This is considered to be an area for improvement.

Inspection testing and maintenance

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

Monitoring of individuals

During the inspection of the FCAL an older XRD apparatus was identified in a secure room within the lab. It was noted the device had not been used for a considerable period (potentially over 20 years). Use of this type of controlled apparatus requires operators to use dosimetry badges, however no dosimetry badges (OSLs, etc.) were assigned to trained operators of this apparatus and/or in situ within the lab. The escorting lab staff member confirmed to the inspection team that the XRD is not being utilised, and nor has the lab been issued with OSLs or other type of dosimetry device, and the apparatus remains a legacy item. Inspectors advised the AFP RSO and escorting lab specialist that due consideration should be given to disposing of the apparatus due to nil use, or that if the AFP wishes to keep this controlled apparatus they must obtain dosimetry badges. This is considered to be an area for improvement.

Security

Security procedures

Access is controlled at the Majura site through the main site entrance and visitor escort processes. Storage areas and laboratory security procedures were appropriate and commensurate with the operational aspects of the AFP. During the inspection, it was observed at both internal areas within the forensics sites that all deployable controlled apparatus were securely stored or secured within access-controlled storage and controlled areas within the laboratory.

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: 

• Centralise procurement procedures regarding acquisitions of TruNarc Handheld Narcotics Analysers and maintain accurate inventory
• Address/update safe work instructions and reporting requirements for the Raman and First Defender handheld spectrometers within the FCAL
• Update codes and standards referenced within FCAL SOPs
• Review the need for the unused XRD within the FCAL and either dispose of the source or address the need for dosimetry for staff within the FCAL. 

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