Inspection report: Note Printing Australia (S0033), Craigieburn VIC, INS-01012

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 Note Printing Australia’s (NPA’s) Craigieburn premises against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of sources. 

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 Note Printing Australia’s (NPA’s) Craigieburn premises against the Source Performance Objectives and Criteria (SPOC). The inspection consisted of a review of records, interviews, and physical inspection of sources. 

Background

NPA is authorised under section 33 of the Act to deal with various controlled apparatus. At the time of the inspection this consisted of non-ionizing apparatus and one fully enclosed X-ray analysis unit.

The main codes and standards applicable to this licence are:

• RPS C-1 Code for Radiation Protection in Planned Exposure Situations (Rev 1) (2020)
• Radiation Health Series 9: Code of practice for protection against ionizing radiation emitted from X‑ray Analysis Equipment (1984)
• 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)
• Radiation Protection Series 12: Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006)
• 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 was found to be satisfactory. There appeared, however, to be areas where there was room for improvement as follows:

• Codes and standards that are a condition of licence were either missing (RPS C-1 Rev 1, AS 2243.5:2024, AS/NZS IEC 62471:2011) or outdated (AS/NZS IEC 60825.14:2022) in the radiation management plan (RMP)
• Principles of radiological protection were not mentioned throughout the RMP. 
• No formal committee was established to discuss radiation safety issues. 
• No safety glasses were present in the Security Inks area for the UV source (NI-40) 
• External laser safety training was not being conducted as indicated in the RMP. 

In addition, it was observed that the UV warning sign in the RMP was incorrect and needs to be corrected. However, the warning signs at all UV apparatus were correct.

Effective control

Accountabilities & Responsibilities

The CEO of NPA is the licence nominee and accepts responsibility for NPA radiation safety policy and practices. The responsibility for compliance with the radiation policy and practices is delegated to the NPA RSO. The RSO maintains the RMP document, and all department managers and workers involved with the operation of radiation sources are required to act in accordance with this document.

Statutory & regulatory compliance

The RMP was written to ensure compliance with the Act, the Regulations, and the licence conditions of S0033. Although the RMP was reviewed within the 3 yearly intervals, some codes and standards that are a condition of licence were either missing (RPS C-1 Rev 1, AS 2243.5:2024, AS/NZS IEC 62471:2011) or outdated (AS/NZS IEC 60825.14:2022). The RSO will correct this during the next review of the document.

Process implementation

Throughout the inspection, we found that the policies and procedures in the RMP were successfully implemented with two exceptions. The first was external laser safety training requirements which is discussed further in the report under the training and education sub header. The second was the UV warning sign, which was inconsistent between the RMP and the UV sources on site. The UV sources on site had the correct colour combination (black on a yellow background) in accordance with AS2243.5:2024 while the RMP version was incorrect (black on a white background). The RSO will also correct this discrepancy during the next review of the document. An example of the correct UV warning symbol can be found in Appendix C of AS 2243.5.

Documentation & document control

The RMP, risk assessments and standard operating procedures (SOPs) were all reviewed within the required time frames and up to date hard copies were viewed throughout the inspection. Up to date NPA Teams Posters were also seen across the site which contained the details of the NPA RSO, WHS manager, etc.

Safety management

Risk assessment 

Any new radiation source acquired by NPA has a risk assessment conducted for its usage. A SOP is also written, and appropriate training conducted. If there is a change to how the equipment is used that could impact on the level of risk, Department Managers are responsible for ensuring that risk assessment and procedures are reviewed. If there are no changes, risk assessments are conducted every 3 years to ensure appropriate controls are in place. Several risk assessments were sighted on the inspection, and all were reviewed within the 3-year frequency band.

Monitoring & measurement

The fully enclosed X-ray analysis unit is owned by a Commonwealth contractor. Commonwealth contractors and NPA staff use the X-ray unit. The required radiation monitoring is carried out by the Commonwealth contractor, and results of the monitoring were sighted during the inspection. 

Training & education

Workers receive general laser/UV/X-ray awareness training as part of their induction at NPA to ensure that they are aware of the hazards. Users of radiation sources are required to have further training to ensure they are able to safely follow the applicable SOPs. Department managers are responsible for ensuring this training is completed and this was viewed throughout the inspection. However, the RMP indicated that users of controlled laser sources, maintainers, department managers and RSO's would receive external laser safety training. There was no documentation to support the completion of external laser safety training and NPA agreed that for most staff this had not been conducted. This is considered to be an area for improvement (AFI) and NPA will review their training requirements accordingly.

Radiation protection

Principles of radiological protection

The principles of radiological protection were not mentioned in the RMP which is a requirement of RPS C-1 (see s3.1.2 and s3.1.12-14). It was acknowledged that this was likely due to RPS C-1 not being included in the RMP. The NPA will amend the RMP to include the principles of radiological protection.  

Radiation safety committee

There was no formal radiation safety committee established to discuss radiation safety issues. Due to the relatively low number of sources present and low risk associated with these sources, it was suggested that forming a radiation safety committee may be an inefficient use of resources, and it would be more effective to formally incorporate a radiation safety component into the WHS committee meetings. 

Local rules & procedures

The SIW was found to be accurate and up to date at the time of inspection indicating local rules, procedures and reporting requirements had been followed. 

Personal protective equipment

The required PPE was sighted in most locations; however, the Security Inks section did not have safety glasses available for the UV curer. This was identified as an AFI. 

Ultimate disposal or transfer

Management of ultimate disposal or transfer

The RMP outlines the process for the transfer or disposal of a source. Since the last inspection of NPA, conducted in 2014, several controlled apparatus have been transferred or disposed of in a manner approved by ARPANSA. 

Emergency plans

The emergency management processes are outlined in the RMP – RBA Emergency Procedures – Craigieburn Site 1. Any incidents or accidents involving controlled apparatus are reported to the Department Manager who then notifies the RSO and HSE Manager. The guidelines for reporting of notifiable events to ARPANSA were referenced in the emergency plans.

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 compliance outcomes:

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