Finnish views on the proposals

1
Finnish views on the proposals

• Ritva Havukainen
• Radiation and Nuclear Safety Authority (STUK)
• www.stuk.fi
• Second EUTERP Platform Workshop
• Definitions, Qualifications and Requirements for
  Radiation Protection Experts,
• Radiation Protection Officers and Radiation
  Workers
• Vilnius, Lithuania
• 23-25 April 2008

2
Content of presentation

• Finnish comments on
• proposed EU BSS definitions, competences, roles
  and duties of RPEs and RPOs recognition of RPE
• Requirements for competences, education and RP
  training of RWs in Finland
• Challenges when implementing new proposals in
  Finland

3
Proposed EU BSS Definitions Radiation
Protection Expert (RPE) and Radiation Protection
Officer (RPO)

• RPE
• Persons having the knowledge, training and
  experience needed to give radiation protection
  advice in order to ensure effective protection of
  individuals, whose capacity to act as a radiation
  protection expert is recognised by the competent
  authorities.
• RPO
• An individual technically competent in radiation
  protection matters relevant for a given type of
  practice who is designated by the registrant or
  licensee to oversee the application of the
  requirements of the Standards, whose capacity to
  act as a radiation protection officer is
  recognised by the competent authorities.
• FIN OK

4
Proposed EU guidanceCompetence of an RPE

• An RPE will have
• an education to Bachelor degree level in RP or a
  closely related physical or biological science,
  or an equivalent qualification or level of
  experience and
• acquired competence in RP, by virtue of a
  combination of special studies, training and
  practical experience.
• FIN
• An RPE should possess education and training
  relevant to the practice
• In the most demanding practices (e.g. nuclear
  energy, medical use of radiation, use of
  accelerators and isotope production)
• higher academic degree level (at least MSc) in RP
  or in a closely related physical science.
• In other practices education could be on
  Bachelors degree level

5
Proposed EU guidanceCompetence of an RPE

• The RPE must have the ability to
• anticipate and recognise the interactions of
  radiation with matter and to understand the
  effects of radiation on people, animals and the
  environment
• carry out a risk assessment identify and assess
  risks of actual and potential exposure to
  ionizing radiation, including the calculation of
  potential exposure
• interpret regulatory requirements and provide
  practical situations for compliance
• identify and propose appropriate control
  procedures to restrict radiation exposure, in
  accordance with the principles of optimisation
• interpret and apply radiation protection data
  (e.g. radionuclide decay and emission data,
  source outputs, dose histories, workplace
  monitoring results, manufacturers data,
  shielding data).
• In addition to scientific and technical
  competence, it is very important that the RPE has
  the ability to communicate effectively with a
  wide range of persons and has a good
  understanding of the social and environmental
  considerations associated with different
  radiation practices.
• FIN OK

6
Proposed EU guidanceCompetence of an RPO

• The RPO is
• generally designated from among those persons
  that work in the practice
• in a suitable management position to oversee the
  radiation work
• must have received sufficient training and
  experience to be able to fulfil the required
  functions for the given type of practice
• FIN
• It is important that an RPO is familiar with the
  practice he/she is overseeing, and his/her
  working place is the same as the radiation using
  place.
• If an RPO is not in a management position, then
  special authorization is needed

7
Proposed EU guidanceRole of an RPE

• Provide comprehensive, professional advice to
  users of radiation on a wide range of RP matters,
  including the protection measures needed to
  restrict exposure.
• Thorough understanding of the relevant national
  legislation.
• An RPE may be an employee of the employer, their
  advice should be independent from production and
  operational management
• Alternatively, an RPE may be an external
  consultant who is contractually appointed to
  provide advice to an employer.
• There is no requirement for the RPE to be present
  or available at all time
• The RPE would not necessarily be involved in the
  routine radiation protection arrangements e.g.
  supervision, radiation monitoring.
• FIN
• In a small country it could be difficult to
  arrange an RPE independent from production or
  operational management

8
Proposed EU guidanceDuties of an RPE

• The primary duty is to provide the employer with
  professional advice to users of radiation on a
  wide range of radiation protection matters. This
  will include advice on
• plans for new installations and the acceptance
  into service of new or modified sources of
  ionising radiation in relation to any engineering
  controls, design features, safety features and
  warning devices provided to restrict exposure to
  ionising radiation
• the classification of controlled and supervised
  areas
• the classification of workers
• the content of area and personal monitoring
  programmes
• the appropriate radiation monitoring
  instrumentation to be used
• the appropriate methods of personal dosimetry
• the adequacy of current arrangements to restrict
  exposure
• radioactive waste disposal requirements.
• FIN Perhaps risk assessments could be added
  onto the list

9
Proposed EU guidanceDuties of an RPE

• The RPE may also be asked to provide other RP
  services in association with the advice provided.
  These may include
• drafting the radiation protection policy of the
  registrant or licensee, and the programme to
  restrict exposure
• interpreting RP information e.g. manufacturers
  data, the output from monitoring programmes, and
  provide recommendations to the employer on
  actions to take
• providing a report to the Board of Directors,
  covering the RP arrangements and standards
  achieved.
• FIN OK

10
Proposed EU guidanceDuties of an RPO

• The primary function to oversee the application
  of the relevant legislative requirements and
  ensure that the work is carried out safely
• The specific duties will depend on the nature of
  the practice, but may include the following
• ensuring that work with radiation is carried out
  in accordance with the requirements of any
  specified procedures or local rules overseeing
  the programme of workplace monitoring
• maintaining adequate records of radioactive
  sources held by the practice
• carrying out periodic assessments of the
  condition of the relevant safety and warning
  systems
• overseeing the personal monitoring programme
• overseeing the health surveillance programme
• liaison with the radiation protection expert
• give new employees an introduction in local rules
  and procedures
• give advice and comments on work plans
• authorise work plans
• provide reports to the local management.
• FINOK

11
Proposed requirementsRecognition of RPEs

• Qualification
• Minimum educational level and training
• Work Experience
• Ability to give advice
• Required Competences
• Legislation, hazard and risk assessment,
  optimization, monitoring area and personal
  dosimetry, classification of areas and workers,
  protection of the public
• FIN
• Required qualifications, competences and RP
  training could be defined for various practices
  (medical, industrial, nuclear power etc.)
• Required competences should be defined by the
  Regulatory Authority.

12
Proposed requirements Renewal of recognition
and mutual recognition of RPEs

• Renewal
• 5 year validity for recognition of RPEs
• Mutual recognition
• language skills and knowledge of national
  legislation
• FIN
• Renewal of recognition of RPEs after 5 years
  validity is challenging
• RPE-passbook?
• work experience, RP training, knowledge of
  national legislation, language skills
• Recognitions of RSOs in Finland at present
• Approved training organization
• Acceptance for 5 years period for arranging RSO
  training and examinations (Guide ST 1.8)
• Certificate - competent to serve as an RSO
• Licensees are responsible for continuous RP
  training of RSOs
• verified in inspections by STUK (max. 5 y
  interval)

13
Competences, training and education of RWs in
Finland

• Medical use of radiation
• Competences for various worker groups
• a physician issuing referrals to a procedure
  involving exposure to radiation
• a physician responsible for a procedure
• professional performing a procedure
• MPEs
• Decree no. 423/2000 of the Ministry of Social
  Affairs and Health http//www.stuk.fi/saannosto/20
  000423e.html
• Content and minimum extent of RP training
• for different worker groups (physicians, nurses,
  physicists, etc.)
• based on the publication Radiation Protection
  116 European Commission, 2001
• ST Guide 1.7 issued by STUK
• http//www.stuk.fi/saannosto/ST1-7e.html
• Other practices
• Content and minimum extent of RP training
• ST Guide 1.8 issued by STUK
• http//www.stuk.fi/saannosto/ST1-8e.html

14
MPEs in Finland

• With the exception of medical physicists, no
  special training for RPEs is currently available
  in Finland
• If nominated an RPE, Regulatory Authority
  verifies the expertise taking account of the type
  of the use of radiation
• Implementation of new proposals means changes
  into legislation
• Under Finnish radiation legislation
• An MPE must be appointed for radiation therapy
  and nuclear medicine
• Medical physics expertise must also be applied in
  X-ray diagnostics and interventional procedures
• An MPE must possess a licentiate or doctoral
  degree and practical training
• An MPE could also perform the duties of an RPE
• No need to appoint one person as an RPE and
  another as an MPE for the same practice.

15
Implementation of new EU proposals

• Use of radiation in medicine
• The medical physicists currently serving as RSOs
  are sufficiently competent to be appointed as
  RPEs
• Many radiologists are currently serving as RSOs
• Extensive RP training they all have been
  required to pass the RSO examination.
• All physicians currently serving as RSOs could
  serve as RPOs
• Radiographers could serve as RPOs in less
  demanding practice (e.g. health care centres) in
  future
• no management position, special authorization is
  needed
• Use of radiation in industry
• In the most demanding practices the roles of an
  RPE and RPO should be separated
• In less demanding practices the duties of RPOs
  and an RPEs could be combined
• Requirements for the RPO/RPE should be adjusted
  for the level of risks in the practice.