Inspection report: Department of Home Affairs - Australian Border Force, Norfolk Island (R21/05730)

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 1999 (the Regulations), and conditions of the Source Licence S0092. 

The scope of the inspection included an assessment of Department of Home Affairs – Australian Border Force (DHA-ABF) performance with baggage X-ray and a class 3B laser substance identification device, used at the Australia Post mail unit site and the airport on Norfolk Island against the source Performance Objectives and Criteria. The inspection consisted of a review of records, interviews, and physical inspection of sources. 

Background

DHA-ABF is authorised under section 33 of the Act to deal with baggage inspection X-ray units and controlled laser apparatus. The X-ray equipment and laser device are owned by the Department of Home Affairs (DHA). The baggage X-ray units are used jointly by both the DHA-ABF and Department of Agriculture and Water Resources (DAWR) in support of mail and parcel screening at the Australia Post handling facility and the airport on Norfolk Island. A substance identification device incorporating a class 3B laser is also operated by DHA-ABF staff. 

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

• Radiation Health Series 21: Statement on cabinet X-ray equipment for examination of letters, packages, baggage, freight and other articles for security, quality control and other purposes (1987).
• Australian/New Zealand Standard: Safety of laser products: Equipment classification and products (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.  

DHA is required to fulfil its reporting commitments to ARPANSA by submission of a quarterly report, in the approved format and within 28 days of the end of the financial year with information about compliance for the previous quarter. The reports submitted by DHA for 2020-2021 contained information about compliance, submitted in a timely manner with no issues to report. DHA’s reports indicated that plans and arrangement had been reviewed in accordance with the regulatory requirements. 

Effective control

Accountabilities & Responsibilities 

DHA’s Canberra based Radiation Safety Officer (RSO) manages all reporting and training requirements for DHA staff and all relevant documentation was provided to ARPANSA for review before the inspection.  

Day to day management of the X-ray units on Norfolk Island is under primary control of the DHA-ABF with screening operations conducted jointly with the DAWR. One screening unit is used at the Norfolk Island Australia Post facility for all inbound air and sea freight and a second unit is used for border control operations at the Norfolk Island Airport.

The substance identification laser device is only operated by appropriately trained DHA-ABF staff. 

Documentation & document control

DHA’s plans and arrangements for managing safety were provided prior to the inspection and were considered satisfactory for Norfolk Island baggage X-ray operations. 

Serial numbers for both X-ray units corresponded with DHA’s source inventory workbook as did the serial number for the laser device. Baggage X-ray operating keys are held by the senior DHA-ABF officer with spare keys located in the DHA-ABF operations room at the airport. 

It was noted that there was no reference to the laser device in DHA’s Plans and Arrangements. The senior DHA-ABF officer did, however, produce an appropriate standard operating procedure for the laser device during the inspection. This document needs to be referred to in DHA’s plans and arrangements.

Safety management

Training & education

DHA requires that all staff who conduct X-ray screening or use the laser device have received appropriate training in radiation safety and the use/operation of both the X-ray units and the laser device. The training package information provided to ARPANSA before the inspection included manufacturer requirements and DHA specific procedures.

Training on systems and safety is delivered online and managed in-house by DHA. The senior DHA-ABF officer, a qualified Competency Assessment Training Officer under DHA-ABF’s operational structure, provides further local on-site equipment familiarisation training to all Norfolk Island based staff, including those from DAWR. 

Staff training records were seen during the inspection. 

Radiation protection

The control panel of each X-ray unit was key operated and a separate switch was fitted for the control of the X-ray beam. The keys are held by DHA-ABF staff with a spare key located at the airport office. 

Both X-ray units were found to be in a satisfactory condition. Warning lights and signs meeting the requirements of RHS21 were fitted to both X-ray units. Emergency stop buttons were fitted at both entry and exit ports and at the control panel. Leaded curtains were also fitted to the entry and exit ports to provide shielding.

Workplace procedures and instructions provided by the manufacturer of the X-ray units and DHA-ABF calibration testing procedures were kept in a folder held with DHA-ABF staff at the Australia Post facility and were seen during the inspection.  

The substance detection laser device is securely stored at the DHA-ABF office at Norfolk Island airport. Start-up logs were observed along with correct signage and safety eyewear. 

Findings

The licence holder was found to comply with the requirements of the Act, the Regulations, and licence conditions. 

The inspection revealed one area for improvement:

1. No reference to laser use within DHA’s Plans and Arrangements.