Inspection report: Australian Federal Police, VIC, 3 December 2020

This inspection was conducted as part of ARPANSA’s baseline 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 S0056.

The scope of the inspection included an assessment of the AFP’s performance at the Melbourne CBD and Melbourne airport sites against the Source Performance Objectives and Criteria (POCs). The inspection consisted of a review of records, interviews, and physical inspection of the sources.

Background

The AFP is authorised under section 33 of the Act to deal with controlled apparatus. This inspection covered the industrial x-ray equipment and lasers that the AFP uses for examination of potential explosive devices and other forensic purposes. The handheld backscatter X-ray sources were not on-site during the time of this inspection.

The main codes and standards applicable to this apparatus are those that appear in section 59 of the Regulations and:

• RPS C-4 Code of Radiation Protection Requirements for Industrial Radiography (2018)
• Australian/New Zealand Standard Safety of laser products Part 1: Equipment classification (AS/NZS IEC 60825-1:2014)
• Australian/New Zealand Standard Safety of laser products Part 14: A user’s guide (AS/NZS IEC 60825-14:2011)

Observations

In general, the management and operation of the controlled apparatus at both sites was found to be satisfactory.

However, there were some areas for improvement identified during this inspection including inconsistencies with review of the plans and arrangements, outdated standards being referred to in standard operating procedures, personal monitoring results not being provided to staff in accordance with internal requirements, frequency of servicing of X-ay equipment and related record keeping, and confusing terminology in standard operating procedures relating to personal monitoring badges. These will be discussed in more detail in the relevant sections below.

Configuration management

The AFP operates at several physical sites across the country. Both the Melbourne CBD and airport sites deal with industrial x-ray devices used by the AFP’s Bomb Response Group. The CBD site also deals with a baggage inspection unit and lasers. The baggage inspection unit has not been used for several years but was due to be recommissioned in the short term with relevant training of users scheduled within two weeks of this inspection.

Most controlled apparatus observed during both site inspections were listed in the AFP’s source inventory workbook (SIW) although one recently acquired industrial x-ray device at the CBD site was to be placed on the SIW at the next quarterly report cycle. Further, one of the lasers listed at the CBD site had recently been transferred to Brisbane and the SIW would also be updated accordingly and reported in the next quarterly report.

Performance reporting verification

The AFP has adopted formal processes, procedures and reporting structures for managing radiation safety. AFP’s reporting obligations are conducted in accordance with their licence requirements in a timely manner.

The AFP manages all dealings with their controlled apparatus through its Work Health & Safety (WH&S) framework. A Radiation Safety Officer (RSO) is employed to coordinate these dealings centrally including the management of the AFP’s plans and arrangements. Local WH&S representatives report through to the RSO and assist the local business units and unit commanders with specific arrangements to achieve a uniform approach in their dealings with the controlled apparatus.

Training

Each AFP staff member who is required to use controlled apparatus undergoes internal AFP radiation awareness training and training specific to the apparatus used. Training records for staff are recorded in the AFP’s ‘iAspire’ learning management system and the inspection team sighted these during the September 2020 inspection.

Inspection Testing and Maintenance

The AFP’s P&As require that all portable industrial X-ray units and baggage inspection X-ray units are serviced every two years and that records of this servicing are appropriately retained. At the time of inspection, AFP staff were unable to locate the service records for this type of equipment representing an area for improvement.

Security

Access to both sites was restricted to relevant personnel and commensurate with the operational aspects of the AFP. During the inspection, it was observed at both sites that all deployable controlled apparatus were securely stored or secured within appropriately access controlled locations.

Radiation protection

AFP has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use of controlled apparatus across the country. This is supported by their P&As to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions. Several practice specific sets of standard operating procedures and work instructions have also been developed and maintained to support these P&As. Some minor discrepancies were identified in these documents that if appropriately addressed would improve clarity of the documentation. These discrepancies include:

• Information on the cover of the P&As such as ‘date modified’ and ‘date last reviewed’ was not consistent.
• The date of the next review was given as 28 September 2020 although this had not taken place. It was noted however, that the most recent review of the document (28 September 2018) was within the 3-year period prescribed in section 61 of the Regulations.
• Some references to outdated and superseded standards and codes.

The AFP holds a centralised dose register for all personnel and locations as identified during the inspection of September 2020. Workers were not routinely advised of their personal dose monitoring results as outlined in section 5.3 of the P&As unless the dose exceeded their stated reference level.

Signage issues was identified during the September 2020 inspection and is being addressed on an organisation wide basis.

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:

1. Lack of consistency of review information in the P&As
2. Workers are not being routinely advised of their doses unless the dose is considered abnormal
3. Portable industrial X-ray equipment and baggage inspection X-ray equipment is not being serviced in accordance with internal requirements
4. Unclear or confusing information in the standard operating procedures for personal monitoring devices

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