Inspection report: CSIRO, S0064, 4-5 February 2025

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 Clayton and Aspendale 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 Victoria at Clayton and Aspendale. 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 Safe 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: 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 both the Clayton and Aspendale sites. In some cases, however, there appeared to be room for improvement as follows:

• There was no radiation warning sign posted outside of room RF10 which contained a controlled UV apparatus.
• The hard copies of the Safe Work Instructions in several locations were found to be out of date versions. 
• The quarterly monitoring results documentation for a fully enclosed X-ray apparatus was incomplete. 
• Several quarters were missing monitoring results.

Effective control

Accountabilities and responsibilities

The Executive Director of CSIRO EER, under the delegation of the Chief Executive Officer, is the licence nominee. The Executive Director oversees all Research Units (RUs) within the sector, and delegates to the appropriate RU Director and RSO network to ensure effective control of radiation safety and implementation of the Radiation Protection Plan (RPP). RU Directors are responsible for radiation safety within their research 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 research units and manage regulatory requirements.

Statutory and regulatory compliance

The RPP is the main reference for the safe management of radiation sources and promotes compliance with the Act, the Regulations, and the licence conditions of S0064. The relevant codes and standards that are a condition of licence were referenced within the document or available via a link to the ARPANSA website.

Documentation and document control

Safe Work Instructions (SWIs) are required by the RPP to be reviewed every 2 years unless they are deemed a critical risk in which case they are reviewed annually at a minimum. Risk assessments are reviewed when there is change to the work detailed, while the RPP is to be reviewed annually. The RPP, risk assessments and SWIs sighted were all reviewed within the required timeframes. QR codes were attached nearby to controlled sources to provide a link to the relevant SWI. Printout versions of the SWIs were also available at some active controlled material or apparatus, however in several locations the hard copies were old versions. This was found to be an AFI as it was reasonably foreseeable that staff would access and use the out-of-date version of the SWI.

Safety management

Risk assessment and mitigation

All work with controlled radiation sources is required by the RPP to be covered by a risk assessment. Following a risk assessment, Safe Work Instructions (SWIs) are developed for the use of controlled material and controlled apparatus in consultation with the site RSO. SWIs are reviewed and signed off by either the RU RSO, CRSO or Sector RSO. Risk assessments and SWIs were sighted throughout the inspection.

Managing change

Staff consult with the RU RSO, Sector RSO and CRSO on any changes that may impact safety and compliance. Significant changes may require an updated risk assessment or SWI. Prior to the change occurring the RU RSO makes an assessment in consultation with the CRSO or Sector RSO to determine if the change requires the prior approval of ARPANSA.

Training and education

The RPP details the training requirements for RSOs and staff, as well as contractors and visitors. All occupationally exposed staff receive general training. Depending on what sources they use they also receive training on X-ray safety, dealing with sealed and unsealed sources, laser safety, UV safety and RF awareness. All training courses are approved by the RU RSO, in consultation with the CRSO. Training records are kept by the CSIRO, and during the inspection these training records were sighted.

Radiation protection

Radiation safety officer/radiation safety committee

RU 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. Furthermore, there is a site-based radiation safety committee at Clayton, however it has not met for approximately a year due to staff turnover.

Planning and design of the workplace

At the Aspendale site, sealed sources are kept in a designated locked storage cabinet when not in use in the field. This storage cabinet is located within a lab that contains Class 3 dangerous goods (Flammable Liquids). As the cabinet itself is the store and does not also contain the Class 3 material and provides sufficient controls to both classes of material, it does not breach the requirements of AS/NZS 2243.4. It would, however, be prudent for CSIRO EER to consult with the appropriate Work Safe regulator to ensure compliance with other regulatory requirements relating to colocation of Class 3 dangerous goods in the same laboratory as a storage cabinet for Class 7 (radioactive) dangerous goods. 

Local rules and procedures

Access to the radiation stores in Clayton was restricted to authorised personnel by swipe card access. In Aspendale, a key was required to access the radiation store. Radiation warning signs, along with the contact details of the responsible person, were displayed at the front of all radiation labs and work areas. However, there was no radiation warning sign posted outside of room RF10 which contained a controlled UV apparatus. This was deemed to be an AFI. 

Monitoring of the workplace

Radiation monitoring equipment was sighted during the inspection along with the calibration date for each device. Results of the annual external dose surveys of the two radiation stores in Clayton and one radiation store in Aspendale were sighted during the inspection. Furthermore, quarterly surveys for the fully enclosed X-ray systems in the XRF and XRD labs at Clayton were also sighted. However, the quarterly survey results for one fully enclosed X-ray system in room 1.18 were incomplete. Staff indicated that this was due to the apparatus being inactive for some time during maintenance, although this was not documented. As such, this was found to be an AFI. The NORM radioisotope laboratory in Clayton has not been in use for several years and therefore has not been monitored.

Monitoring of individuals

Personal monitoring was conducted at the Clayton site for work with X-ray apparatus, unsealed NORM or radioisotopes, sealed sources or radiation store work. The dose records were sighted during the inspection. Dose results from personal monitoring are reviewed by the RU RSO, and if an individual’s dose levels exceed the investigation level there is further investigation. There is no personal monitoring at the Aspendale site. 

Ultimate disposal or transfer

The RPP outlines the process for the transfer or disposal of a source. Since the last inspection of CSIRO EER Clayton and Aspendale sites, 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 card access to the radiation and radioisotope laboratories. Keys and swipe card access are issued under instruction from the RSO and laboratory custodian, where applicable. 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:

• There was no radiation warning sign posted outside of room RF10 which contained a controlled UV apparatus.
• The hard copies of the Safe Work Instructions in several locations were found to be out of date versions. 
• The quarterly monitoring results documentation for a fully enclosed X-ray apparatus was incomplete. 
• Several quarters were missing monitoring results.

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