Regulatory Guide - Licence Merger Process (ARPANSA-GDE-1742)

1. Introduction 

This guide is provided to assist licence holders who wish to merge two or more licences as a result of an organisational change.

A licence merger will usually require an amendment of an existing licence by the CEO of ARPANSA under section 36 of the Australian Radiation Protection and Nuclear Safety Act 1998. 

Where the merger involves certain changes defined in section 63 of the Regulations, a request for approval by the CEO is required.

2. Process

1. The licence holder should write to the CEO, informing the CEO of the intended merger. The letter should indicate which licences will merge and provide the name in which the new licence should be issued. The letter should also indicate the timelines of the merger and request approval to surrender the superseded licence(s) when the new licence is issued. 
2. If the licence holder wishes to retain a previous licence number, this should be indicated but is not guaranteed. In some cases, it may be more efficient and less confusing to issue a new licence rather than merge existing licences. ARPANSA will make this decision in consultation with the licence holder. 
3. The licence holder should provide information about any movement of staff, laboratories, or controlled material and apparatus as a result of the merger. The licence holder should provide a new organisational chart indicating clear lines of responsibility for radiation protection and nuclear safety.
4. If, as a result of the merger, different people are undertaking dealings with radiation sources, the licence holder must ensure the new users have appropriate qualifications and training and provide evidence of this to ARPANSA. 
5. The licence holder should send a new source inventory workbook (SIW) containing details of all sources from the merging licences. 
   NOTE: It is critical that all ARPANSA source numbers are retained.  
6. Revised and updated plans and arrangements and/or safe operating procedures should be submitted to ARPANSA, reflecting any changes resulting from the merger.
7. When ARPANSA is satisfied that the merger has been undertaken safely and any risks arising from the merger have been addressed, the CEO (or delegate) will consent to the surrender of the old licence(s) and issue a licence in the new organisational name.