Thank you to the Canadian Nuclear Safety Commission for the opportunity to present in front of you today. My name is Tanya Neretljak, current President of the Canadian Radiation Protection Association, and with me is Ali Shoushtarian, Director of Internal Affairs. Ali and I are Registered Radiation Safety Professionals with the CRPA. We would like to begin with a brief introduction of the association. 1
The Canadian Radiation Protection Association (CRPA) is a not ‐ for ‐ profit professional organization that supports the development and implementation of radiation safety programs in Canada. Our mission is to ensure the safe use of radiation by providing scientific knowledge, education, expertise and policy guidance for radiation protection. We do this by promoting educational opportunities in those disciplines that support the science and practice of radiation protection, assisting in the development of professional standards in the discipline of radiation protection, and supporting the activities of other national and international radiation protection relevant societies, associations, and organizations. CRPA is an associate society of IRPA and our members sit on committees and task forces under the auspices of IRPA, the ICRP and others. 2
In connection with today’s report, our members represent licensees covered in all four sectors of the annual report: • Hospitals or medical • Universities or academic and research facilities • Commercial, and • Industry Many of our members are directly responsible for the day to day operations and management of radiation safety programs. 3
The Graph shows the demographic of CRPA representations across Canada. The red bars represent the Canadian population distribution and the blue bars represent the percent distribution of CRPA Membership. As you can see the province of Ontario is where most of CRPA members are located. 4
The pie graph shows the CRPA membership by sector. 40% of our members come from Universities and Hospital sector. And 10% of CPRA members comes from Regulatory sector. 5
This table shows our CRPA members cover a variety of license type such as consolidated, fixed and portable gauges, servicing and diagnostic and therapeutic nuclear medicine to name a few. 6
Registered members of the CRPA are individuals who hold the CRPA(R) designation. The CRPA (R) designation is the highest level of competency recognized by the CRPA at the Canadian level. The attainment of the designation is determined by: academic achievement, experience in the radiation field and successful completion of an exam based on identified core competencies. These competencies reflect many of the Safety and Control Areas used to measure the safety performance of licensees and ensure comprehensive regulatory oversight. The purpose of the designation is to ensure the public, an employer or a regulator, that an individual with the CRPA (R) credential has the qualifications and the knowledge and ability to perform duties as a competent professional in radiation safety. 7
Comment 1 ‐ Unlike past reports, the compliance ratings results do not outline the Type II Inspection grading system results licensees are commonly familiar with and do not infer an overall compliance grade. The SCA data for Operating Performance, Radiation Protection and Security does not quantify the meaning of “ satisfactory regulatory compliance ” or “ regulatory compliance ”. Under section 4.1, it is not clear whether an average compliance rating of 88.4% is indicative of inspections which yielded no non ‐ compliances found, 1 non ‐ compliance found, 2 non ‐ compliances, or if it measures zero recommendations, 1 recommendation, 2 recommendations, etc. Under section 4.2.4, the report indicates for the security SCA, “ overall, all sectors showed satisfactory ratings”. Inspection ratings ranged from 94% to 97.6% in this SCA. This rating information is confusing and it is difficult to understand whether 88.4% is indicative of compliance inspections which yielded perfect inspections with zero non ‐ compliances, when an inspection rating of 94% or greater in one of the SCA’s is only satisfactory. 8
The CRPA recommends that the CNSC define the meanings of “satisfactory regulatory compliance” “regulatory compliance” “in compliance” for the comprehension of the reviewer. To note: after following the CNSC staff presentation, it is evident that the regulatory oversight presentation has better represented the findings of the inspection results in comparison to the draft report released in August and some of these confusing rating results have been addressed. 9
Comment 2 ‐ Many members of the CRPA who represent licensees and perform the day to day operational/executive functions of the radiation safety program have previously indicated challenges ensuring compliance in other safety control areas, in particular: human performance management waste management packaging and transport, and general management system which includes senior management oversight 10
We recommend that the CNSC include a brief summary or appendix on the findings of the other Safety Control Areas for inspections conducted in 2014 for the benefit of licensees reviewing industry specific trends in their areas of concern. 11
Comment 3 ‐ In section 4.2.4, the report indicated that “ CNSC staff verified licensee compliance against requirements described in REGDOC ‐ 2.12.3, Security of Nuclear Substances: Sealed Sources” . This section highlighted very good compliance ratings but did not offer any insight into challenges faced by licensees to meet compliance. 12
For the benefit of licensees currently developing programs to comply with the requirements that come into effect in 2018… we recommend that the CNSC include a brief summary of any challenges faced by the inspected licensees to meet the requirements by the implemented deadline. 13
Comment 4 ‐ In section 4.2.6, it is indicated that 141 out of 147 reported events were ranked as INES Level 0. Often, events which fall under the INES Level 0 and have no safety significance may be overlooked by licensees. Events without immediate safety significance can lead to poor practices and if not captured proactively, can eventually result in an event with a safety significance. Comparable events or practices at like institutions/organizations may be regularly occurring without being reported. 14
For transparency and the benefit of licensees, the CNSC should consider compiling a summary of INES Level 0 reported events for better operational experience sharing among licensee for the purpose of improving safety performance. 15
Comment 5 ‐ Licensees have been closely following the issuances of orders as well as administrative monetary penalties (AMP) since their implementation in 2013. Section 4.2.5 outlines the escalated compliance enforcement action in 19 instances. Licensees question the relevance of administrative monetary penalties issued in some circumstances and the lack thereof in others. For example, In the event of Cliffs Quebec Iron Mining Limited, which led to 10 workers being exposed above the regulatory limits for workers, an order was issued following the event. No AMP was issued. This event was ranked as an INES Level 2. In the event of Sunnybrook Health Sciences Centre and Sunnybrook Research Institute, an order was issued following the reported event of lost sources, and despite the corrective measures taken by the licensee, an AMP was issue subsequently. This event was not ranked in the report, but comparable lost source events were ranked at Level 1 or 0. Other lost source events did not result in AMPs including a Level 1 ranked event at the CNSC Laboratory. More recently, an AMP was issued to an Ontario university for an illegal transfer of a source within a scintillation counter. Despite voluntary and immediate reporting, assistance to the CNSC and corrective measures, an AMP was administered after determining factors assessed the penalty at a score of ‐ 2. The incident had no safety significance or actual or potential risk to the public or environment. This type of action by the CNSC in issuing AMPs can make licensees skeptical in offering information to the regulator. 16
For the benefit of licensees, the CNSC needs to be transparent or show consistencies in their methodology for issuing AMPs. Regulatory compliance is now overshadowed by regulatory compliance tools which are more damaging to a licensee than beneficial to the radiation protection community. 17
Commendation 1 for licensees ‐ In the executive summary, it was reported that “ More than 99.9% of the 60,407 workers received doses below their applicable regulatory dose limits ”. We would like to commend the radiation protection community for their diligence and efforts afforded to ascertain doses to workers and ensure that doses are maintained ALARA. 18
Commendation 1 for the regulator in relation to the last point ‐ We would like to commend CNSC staff for making it a priority in their enforcement efforts that radiation protection programs are implemented to ensure that radiation doses to workers are well below regulatory limits and kept ALARA. 19
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