| Licence holder | Commonwealth Scientific and Industrial Research Organisation – Environment, Energy and Resources Sector |
| Locations inspected | Kensington WA 6151; Waterford WA 6152; Floreat WA 6014; and Crawley WA 6009. |
| Licence number | S0064 |
| Date/s of inspection | 18 June - 20 June 2024 |
| Report no | S0064 |
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.
The scope of the inspection included an assessment of performance at the Commonwealth Scientific and Industrial Research Organisation (CSIRO) Environment, Energy and Resources (EER) sites of Kensington, Waterford, Floreat and Crawley against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of sources.
Background
The CSIRO is Australia’s national science agency. The CSIRO EER has several sites around Australia, however, this inspection focused on the sites in WA at Kensington, Waterford, Floreat and Crawley. The Bentley and Watermans Bay sites were not included, as at the time of this inspection neither site had an active source. CSIRO EER is authorised under section 33 of the Act to deal with ionising and non-ionising controlled apparatus and controlled material.
The main codes and standards applicable to this licence are:
- RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
- RPS 11 Code of Practice for the Security of Radioactive Sources (2019)
- RPS C-2 Code for the Safety Transport of Radioactive Material (2019)
- RPS C-6 Code for Disposal of Radioactive Waste by the User (2018)
- 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)
- Australian Standard: Safety in laboratories, Part 5: Non-ionizing radiations - Electromagnetic, sound and ultrasound (AS 2243.5:2024)
- Australian/New Zealand Standard: Photobiological safety of lamps and lamp systems (AS/NZS IEC 62471:2011)
- Australian/New Zealand Standard: Safety in laboratories, Part 4: Ionizing radiations (AS/NZS 2243.4:2018)
Observations
In general, the management of safety and security was found to be satisfactory at the WA sites inspected. In some cases, however, there appeared to be room for improvement as follows:
- Contamination check equipment was available in the lab area but not in the exit area of the Waterford lab.
- X-ray monitoring was conducted at normal operating conditions but not at the maximum instrument settings, as stated in appendix D.4.3 of the Radiation Protection Plan (RPP).
- Not all controlled apparatus fit for use but not required at present were secured in a locked store/cupboard as stated in section 6.4 of the RPP.
In addition, it was observed that record keeping was not optimal as records on training, transport and other radiation matters were not kept on a single record management system and were instead spread over multiple systems. Further, there were some ambiguities and errors within the RPP which were mostly amended during the inspection. In particular, the dose constraint terminology was unclear and there was an incorrect standard referenced in 3.4.3 UV Eye Protection.
Effective control
Accountabilities & Responsibilities
Under the delegation of the Chief Executive, the Executive Director of CSIRO EER is the licence nominee and manages all Business Units (BUs) within the sector. The Executive Director delegates to the appropriate BU Director and RSO network to ensure implementation of the RPP and effective control of radiation safety. BU Directors are responsible for radiation safety within their business unit. The Health, Safety and Environment (HSE) Chief Radiation Safety Officer (CRSO) works with and supports the network of RSOs to understand the needs of the business units and manage regulatory requirements.
Statutory & regulatory compliance
The RPP is the main reference for the safe management of radiation sources and ensures compliance with the Act, the Regulations, and the licence conditions of S0064. This was the first version of the new RPP following the merger of licences S0009, S0019 and S0025 under S0064. The relevant codes and standards that are a condition of the licence were referenced within the document or available via a link to the ARPANSA website. However, there was an incorrect standard referenced in 3.4.3 UV Eye Protection (AS 1607.1) which will be amended when the RPP is next reviewed.
Documentation & document control
The RPP, risk assessments and Safe Work Instructions (SWI) sighted were all reviewed within the required timeframes. QR codes were attached nearby to provide a link to the relevant SWI. Printout versions of the SWIs were usually also available at active controlled material or apparatus. SWIs are reviewed every 2 years unless they are deemed a critical risk in which case they are reviewed every 6 months. Additionally, SWIs are reviewed when there is a change to the work detailed in the original document. On one occasion at the Crawley site an out-of-date SWI was sighted, however, the QR code attached to the equipment provided a link to the up-to-date SWI. Staff at the Crawley facility printed out a version of the updated SWI to replace the older version at the time.
Safety management
Risk assessment & mitigation
All work with controlled radiation sources must be covered by a risk assessment. Following the risk assessment, SWIs are developed by relevant staff in consultation with the site RSO/Contact for use of controlled material and controlled apparatus. SWIs are reviewed and signed off by either the BURSO, CRSO or Radiation Safety Support Officer. Risk assessments and SWIs were sighted throughout the inspection.
Managing change
Staff and affiliates consult with the BURSO and CRSO on any changes that may impact safety and compliance. Prior to the change occurring the BURSO assesses the change in consultation with the CRSO or Sector RSO to determine if the change requires the prior approval of ARPANSA. Change may require an updated risk assessment or SWI.
Training & education
Training is required for RSOs, staff using controlled apparatus and sources, contractors, and visitors. All staff who deal with controlled material or controlled apparatus undertake commensurate training in radiation safety, administration, equipment operation, security, and emergency arrangements. All training courses must be approved by the business unit RSO, in consultation with the CRSO. Records of training are recorded on the Learning Management System (LMS), however, not all training records are kept on the LMS as some are stored in other record keeping systems such as Content Manager. During the inspection, these training records were sighted.
Radiation protection
Principles of radiological protection
The principles of radiological protection were outlined in section 4 of the RPP, but there were some ambiguities. The dose limits for occupationally exposed female employees are stated in table 7 of section 4.3.1 Ionising radiation dose limit and in section 4.3.2 Dose Optimisation. This was discussed during the inspection and agreed that it was better to just be in section 4.3.1. Further, the dose constraint terminology was unclear with 250µSv per quarter being stated as an informal investigation limit as well as a constraint in section 4.5 of the RPP. This section requires some clarification.
Radiation safety officer/Radiation safety committee
BU RSOs and Sector RSOs are members of the CSIRO Radiation Safety Committee which meets quarterly to discuss radiation safety matters. The minutes of these meetings were sighted. Further, a site-based radiation safety committee at Waterford is established and meets as required to discuss the management of radiation safety.
Planning & design of the workplace
The exit area of the laboratory at the Waterford site did not contain contamination monitoring equipment. Contamination monitoring equipment was present but in the main area. This was identified as an area for improvement (AFI). Additionally, the RPP requires that all controlled apparatus fit for use but not required at present be secured in a locked store or cupboard (Section 6.4). This was found to be the case for smaller, portable apparatus although larger controlled apparatus were often stored in laboratories that were not locked, although they were tagged as not to be used. This was found to be an AFI as the RPP did not reflect what was occurring on sites.
Monitoring of the workplace
The BU RSO is responsible for managing the monitoring program. Quarterly surveys of routine area monitoring of enclosed X-ray systems occurred at the Kensington and Waterford sites. However, leakage X-ray monitoring was not conducted at the maximum instrument settings as specified in Appendix D.4.3 of the RPP. This was determined to be an AFI. Task-related area monitoring is also undertaken to identify any dose rate, air contamination or exposure levels for a specific activity or group of activities that are outside of the normal operation. Dose meters and contamination meters required for this were calibrated within the required timeframe and calibration certificates were sighted during the inspection.
Monitoring of individuals
Personal monitoring was conducted at the Kensington site (for X-ray Apparatus (XCT Scanner) Level 1 users, sealed sources, and NORM work) and Waterford site (for X-Ray Apparatus, NORM, or radioisotope work), and the records were sighted during the inspection. Dose results from personal monitoring are reviewed by BU RSO, and where an individual’s dose or area monitoring levels exceed or appear to exceed an ALARA investigation level, the dose or exposure levels are investigated by the BU RSO.
Ultimate disposal or transfer
The RPP outlines the process for the transfer or disposal of a source. Since the last inspection of CSIRO EER Kensington and Waterford sites conducted in 2018, several controlled materials or apparatus have been transferred or disposed of in a manner approved by ARPANSA.
Security
CSIRO EER has electronic security of buildings in addition to restricted swipe-pass access to the radiation and radioisotope laboratories. Keys and swipe pass access are issued under instruction from the RSO and laboratory custodian, where applicable, and require documented inductions. The inspection found the level of access control was satisfactory.
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:
| Compliance Outcome ID | Compliance Outcome | Subject | Description |
| CO-01008 | Area For Improvement | Contamination monitoring equipment | The exit area did not contain contamination monitoring equipment. |
| CO-01009 | Area For Improvement | Storage | Not all controlled apparatus fit for use but not required at present were secured in a locked store/cupboard as stated in section 6.4 of the Radiation Protection Plan |
| CO-01010 | Area For Improvement | X-ray monitoring | X-ray leakage monitoring was conducted at normal operating conditions but not at maximum instrument settings as stated in appendix D.4.3 of Radiation Protection Plan. |
It is expected that improvement actions will be taken in a timely manner.
