Occupational protection at nuclear power plants (NPPs)

Occupational radiation protection at NPPs is internationally governed by the ILO Convention 115 (ILO, 1960), by the BSS (IAEA, 1996a, 2011) and by specific guidance on occupational radiation protection (IAEA, 1999a) and on assessment of occupational exposure due to intakes of radionuclides (IAEA, 1999b) and to external sources (IAEA, 1999c). These are fully based on specific ICRP recommendations (ICRP, 1997b). A wide interna­tional consensus exists in this area (IAEA, 2003b) and its international regulation (Gonzalez, 2003b).

In short, the international accord establishes that all those persons engaged in work at NPPs are in principle considered occupational exposed workers, although the occupational protection standards apply in toto only to those performing work in controlled areas. Those organizations that employ them should be considered as employers. Both workers and employ­ers should be subjected to responsibilities established in the occupational radiation protection normative.

Employers shall be responsible for protecting the workers and complying with any relevant requirements of the occupational radiation protection standards, ensuring in particular that the occupational exposures be limited as specified in the relevant requirements and that occupational protection and safety be optimized in accordance with the relevant requirements.

Employers should also ensure that decisions regarding measures for occupational protection and safety be recorded and made available to the workers through their representatives where appropriate. They should establish policies, procedures and organizational arrangements for protec­tion and safety for implementing the relevant requirements, with priority given to measures for controlling occupational exposures.

Employers are also responsible for providing the following:

1. Suitable and adequate facilities, equipment and services for protection and safety, the nature and extent of which are commensurate with the expected magnitude and likelihood of the occupational exposure

2. Necessary health surveillance and health services, providing appropri­ate protective devices and monitoring equipment and arranging for its proper use

3. Suitable and adequate human resources and appropriate training in protection and safety, as well as periodic retraining and updating as required in order to ensure the necessary level of competence, keeping records of the training provided to individual workers

4. Adequate records of occupational exposure

5. Consultation and cooperation with workers with respect to protection and safety, concerning all measures necessary to achieve the effective implementation of requirements

6. Necessary conditions to promote a safety culture

7. In consultation with workers, writing rules and procedures as are nec­essary to ensure adequate levels of protection and safety, including values of any relevant dose level that require investigation or specific authorization and the procedure to be followed in the event that any such value is exceeded, and making such rules and procedures and the protective measures and safety provisions known to those workers to whom they apply

8. Supervision of any work involving occupational exposure and taking all reasonable steps to ensure that the rules, procedures, protective measures and safety provisions be observed

9. For all workers, adequate information on the health risks due to their occupational exposure, adequate instruction and training on protec­tion and safety, and adequate information on the significance for pro­tection and safety of their actions

10. For female workers, appropriate information on (i) the risk to the embryo or foetus due to exposure of a pregnant worker; (ii) the impor­tance for a female worker of notifying her employer as soon as she

suspects that she is pregnant; and (iii) the risk to an infant ingesting radioactive substances by breast feeding.

Employers should ensure that workers exposed to radiation from sources that are not directly related to their work receive the same level of protec­tion as if they were members of the public. They should obtain, as a pre­condition for engagement of workers, the previous occupational exposure history of such workers and other information as may be necessary to provide protection and safety.

They should also be transparent with the information. In fact they should take such administrative actions as are necessary to ensure that workers are informed that protection and safety are integral parts of a general occupational health and safety programme in which they have certain obli­gations and responsibilities for their own protection and the protection of others, and in particular record any report received from a worker that identifies circumstances which could affect compliance, and shall take appropriate action.

As far as recording is concerned, employers should arrange for the assess­ment of the occupational exposure of workers, on the basis of individual monitoring where appropriate, and ensure that adequate arrangements be made with appropriate dosimetry services under an adequate quality assur­ance programme. They should also arrange for appropriate health surveil­lance based on the general principles of occupational health and designed to assess the initial and continuing fitness of workers for their intended tasks. Finally, they should maintain exposure records for each worker, which shall include (1) information on the general nature of the work in the response involving occupational exposure; (2) information on doses, expo­sures and intakes at or above the relevant recording levels and the data upon which the dose assessments have been based; (3) when a worker is or has been occupationally exposed while in the employ of more than one employer, information on the dates of employment with each employer and the doses, exposures and intakes in each such employment; and (4) records of any doses, exposures or intakes due to other emergency interventions or accidents, as well as providing for access by workers to information in their own exposure records and for access to the exposure records by the supervi­sor of the health surveillance programme, facilitating the provision of copies of workers’ exposure records to new employers when workers change employment, and preserving such records during the worker’s working life and afterwards at least until the worker attains or would have attained the age of 75 years, and for not less than 30 years after the termination of the work involving occupational exposure.

On their side, workers shall be responsible for following any applicable rules and procedures for protection and safety specified by the employer and using properly the monitoring devices and the protective equipment and clothing provided. They should cooperate with the employer with respect to protection and safety and the operation of radiological health surveillance and dose assessment programmes and provide to the employer such information on their past and current work as is relevant to ensure effective and comprehensive protection and safety for themselves and others.

Workers should abstain from any wilful action that could put themselves or others in situations that contravene the requirements. The should accept such information, instruction and training concerning protection and safety as will enable them to conduct their work in accordance with the require­ments of occupational radiation protection standards. Finally, they should be reporting to the employer, as soon as feasible, circumstances that could adversely affect compliance with the standards, if for any reason a worker is able to identify such circumstances.

It is interesting to note that according to the international labour norma­tive, conditions of service of workers shall be independent of the existence or the possibility of occupational exposure. Special compensatory arrange­ments or preferential treatment with respect to salary or special insurance coverage, working hours, length of vacation, additional holidays or retire­ment benefits shall neither be granted nor be used as substitutes for the provision of proper protection and safety measures to ensure compliance with the requirements of the relevant occupational radiation protection standards.

As indicated heretofore, a female worker should, on becoming aware that she is pregnant or if she is nursing, notify the employer in order that her working conditions may be modified if necessary. The notification of pregnancy or nursing shall not be considered a reason to exclude a female worker from work; however, the employer of a female worker who has notified pregnancy or nursing shall adapt the working conditions in respect of occupational exposure so as to ensure that the embryo or fetus, or the nursing infant, is afforded the same broad level of protection as required for members of the public. Taking account the above requirements and the unavoidable uncertainties surrounding accident-response measures, in practice it might be unfeasible to occupy female workers in those condi­tions as emergency responders undertaking life-saving or other urgent actions. Under these circumstances, employers shall make every reason­able effort to provide such potential workers with suitable alternative employment.

The general dose limits for occupational exposure have been described before. In more detail, the ‘normal’ occupational exposure of any worker shall be so controlled that more of the following limits be exceeded:

• An effective dose of 20 mSv per year averaged over five consecutive years

• An effective dose of 50 mSv in any single year

• An equivalent dose to the lens of the eye of 150 mSv in a year

• An equivalent dose to the extremities (hands and feet) or the skin of 500 mSv in a year. (The equivalent dose limits for the skin apply to the average dose over 1 cm2 of the most highly irradiated area of the skin. Skin dose also contributes to the effective dose, this contribution being the average dose to the entire skin multiplied by the tissue weighting factor for the skin)

• In special circumstances, the values for the single-year effective dose can be duplicated.

For ‘abnormal’ situations that may occur if an accident happens at an NPP, special conditions might be employed for volunteers engaged in recov­ery operations. For workers undertaking rescue operations that involve saving life, no dose restrictions are recommended in principle if, and only if, the benefit to others clearly outweighs the rescuer’s own risk. Otherwise, for rescue operations involving the prevention of serious injury or the development of catastrophic conditions, every effort should be made to avoid deterministic effects on health — by keeping effective doses below 1000 mSv to avoid serious deterministic health effects, or below 500 mSv to avoid other prompt health effects (the latter criterion leaves a margin for error in avoiding deterministic effects because of the possible difficulty in determining the exact exposure conditions immediately after an unex­pected abnormal situation and the possibility that the workers concerned may not have the level of training or experience usually required for responding to such an unexpected situation). For workers undertaking other immediate and urgent rescue actions to prevent injuries or large doses to many people, all reasonable efforts should be made to keep doses below 100 mSv of effective dose.

For emergency actions undertaken by workers engaged in recovery oper­ations, the doses received should be treated as part of normal occupational exposure and the ‘normal’ occupational dose limits apply, namely a limit on effective dose of 20 mSv/year, averaged over five years (100 mSv in five years), with the further provision that the effective dose should not exceed 50 mSv in any single year, and annual equivalent dose limits of 150 mSv for the lens of the eye, 500 mSv for the skin (average dose over 1 cm2 of the most highly irradiated area of the skin), and 500 mSv for the hands and feet.

It should be re-emphasized that those rescuers undertaking actions in which the dose may exceed 100 mSv of effective dose should be volunteers, and should be well prepared for dealing with the aftermath of a radiation emergency, i. e., they should be clearly and comprehensively informed in advance of the associated health risk and, to the extent feasible, be trained in the actions that may be required, including the use of protective measures.