Regulatory Guide - Radiation Incident Site Preservation (ARPANSA-GDE-1764)

Regulatory expectations for preserving the site following a radiation incident

1. Introduction

Legislative Framework

The objective of the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act) is to protect the health and safety of people, and to protect the environment, from the harmful effects of radiation.

The Act and the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations) do not specify the requirements to preserve a site following an incident. However section 58 of the Regulations (Preventing, controlling and minimising accidents) and in particular section 60 (Managing Safety) require the licence holder to take all reasonably practicable steps to manage the safety of the facility or source; this includes the steps taken following a radiation incident (see ARPANSA Regulatory Guide: Plans and Arrangements for Managing Safety for further details and the ARPANSA Emergency Exposure Guide, RPSG3).

Further, under the Commonwealth Work Health and Safety Act 2011, Comcare must be notified of all notifiable incidents and the site must be preserved for investigation. Please refer to Comcare’s requirements.

2. Objective

The objective of this guide is to provide general information for licence holders, on-site and off-site first responders, local authorities and others who may have a role in the preservation of a site, including those providing assistance in the event of a radiation incident.

3. Scope

This guide provides high-level information regarding a radiation safety and/or security incident associated with a controlled facility, radiation source or site. It provides expectations for incident management to ensure safe, secure, effective and efficient operations where radiation exposure or contamination is known or suspected to be present.

This guide relates to site preservation only and does not attempt to inform on recovery or response procedures. These would be developed at the local level and be unique to the licence holder’s conduct or dealings.

4. Background

A radiation incident, as a result of work involving ionising radiation apparatus or radioactive material, may be defined as an unexpected deviation from normal conditions leading to an actual, or potential, unintended radiation exposure or contamination of persons or the environment (Section 7 Radiation Incidents AS/NZS 2243.4:2018 Safety in Laboratories – Ionizing Radiations).

ARPANSA’s National Directory for Radiation Protection defines a radiation incident as: any unintended or ill-advised event when using ionising radiation apparatus, specified types of non-ionising radiation apparatus or radioactive substances, which results in, or has the potential to result in, an exposure to radiation to any person or the environment, outside the range of that normally expected for a particular practice, including events resulting from operator error, equipment failure, or the failure of management systems that warranted investigation.

It is essential to ensure that all actions at the site of a radiation incident are carried out in a way that maintains the integrity of the site and that all relevant locally developed procedures are applied through effective radiological emergency (incident) management. While not covered in this document, as a reference point for development of response procedures, please see Section 7.2 Response Procedures of AS/NZS 2243.4:2018 Safety in Laboratories – Ionizing Radiations.

Management of the radiation incident includes the process of ensuring the orderly, accurate and effective collection and preservation of information so that it can be used for post incident investigation and site clean-up (see ARPANSA Regulatory Guide: Plans and Arrangements).

5. Preserving incident sites

While preservation of the incident site is of great importance, it is paramount that the safety of those involved with the incident is first priority and that any actions do not result in any undue risk to operators or persons present. As such, personnel safety, including decontamination activities, must be the first priority of those persons affected.

The person with management or control of a workplace at which a radiation incident has occurred must ensure as far as is reasonably practicable that the site where the incident occurred is not disturbed until the Radiation Safety Officer (or equivalent) or on-site response arrives and provides further instruction. When it is concluded that a radiation incident has occurred the following actions should be taken:

1. Establish perimeter control procedures in parallel with other immediate actions
2. Initiate pre-planned and coordinated actions
3. Report the radiation incident to the relevant competent authority

The primary goals of an incident investigation are to determine the cause of an incident, and/or to determine factors that contributed to the impact of the incident or the management of the incident (site reconstruction). This is done by identifying, collecting and analysing all relevant physical information and documenting the conditions at the incident site in a timely manner.

Special attention should be paid to the importance of securing the site/facility to prevent any destruction or cross-contamination of the physical information as well as for protection of responding personnel and other individuals.  In addition, the site of the radiation incident should be managed in a way that takes into account the possible presence of multiple hazards.

Site Preservation Prerequisites

The following key prerequisites will ensure appropriate site preservation following a radiation incident:

1. Front line supervisors must be fully aware of the importance of site preservation and the role the supervisor can play
2. Quick decision-making on the level of investigation to be carried out and sending appropriate staff (this may include the Regulator) to the facility/site early to capture vital data and information

Licence holders should ensure that:

• Persons are appropriately trained and competent in the procedures for dealing with foreseeable radiation incidents
• Suitable personal protective equipment, radiation survey instrumentation and an emergency kit are available and maintained
• The name and contact details of the person to contact in an emergency, and an alternate, are displayed at appropriate locations
• Incidents are reported in accordance with locally developed incident management procedures
• Adequate communications, including notifications to relevant personnel regarding the incident occur in a timely manner
• Radiation incidents are investigated, recorded, and reported to ARPANSA as required by the Regulations as soon as practicable

Site Preservation Activities

Essential activities to consider when developing a radiation incident management plan or for input into existing plans and arrangement documents (see ARPANSA Regulatory Guide: Plans and Arrangements) are:

• Contact relevant response personnel (or the RSO) so they arrive at the facility as soon as possible after the incident (ideally before physical evidence is disturbed)
• Do not pre-judge the situation
• Do not move or remove anything until evidence is recorded and measurements are taken; ask if anyone has moved or removed anything
• Take necessary photographs with corresponding information/notes
• Take videos as necessary
• Take measurements
• Identify staff (or contractors) who may have information that needs to be captured early; carry out preliminary interviews
• Note the working conditions (including lighting and weather conditions) 
• Note the housekeeping
• Record the chronological course of events, if possible
• Record what tools, instrumentation and equipment were used at the incident site
• Do a formal risk assessment as necessary

6. Conclusion

It is important that site preservation is well understood and actions to be taken if an incident occurs are clear. The following questions should be considered when developing a radiation incident management plan or for input into existing plans and arrangement documents (see ARPANSA Regulatory Guide: Plans and Arrangements):

1. Who is responsible and/or accountable for preservation of a radiation incident site?
2. Does your current training and awareness program provide the appropriate level of theoretical and practical sessions for a radiation incident?
3. Does your incident procedure or guideline outline what to do to preserve the site of an incident?

References

1. Australian & New Zealand Standard AS/NZS 2243.4: 2018 Safety in Laboratories – Ionizing Radiations
2. Long, Ian Simplicity in Safety Investigations, A Practitioner’s Guide to Applying Safety Science, Routledge, Great Britain, 2017 (pp 18–20 The Investigation Process - Scene Preservation)