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| EDITORIAL |
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| Year : 2017 | Volume
: 40
| Issue : 1 | Page : 1-2 |
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Radiological protection issues of itinerant workers
Pushparaja
Ex-RSSD, BARC, Mumbai, Maharashtra, India
| Date of Web Publication | 24-Apr-2017 |
Correspondence Address:
Dr. Pushparaja
Ex-RSSD, BARC, Mumbai, Maharashtra
India
 Source of Support: None, Conflict of Interest: None  | Check |
DOI: 10.4103/rpe.RPE_19_17
How to cite this article:
Pushparaja. Radiological protection issues of itinerant workers. Radiat Prot Environ 2017;40:1-2 |
The meaning of itinerant worker as described in IAEA standards is the worker who is moving from one place to another place or from one country to another country to perform work or a duty. The workers are often called contract or temporary/transient or casual workers.
In establishments, a principal employer (registrants/licensee) hires a contractor to supply workers to complete a project or to meet temporary requirement of workforce. The workers, may have to travel from one place to another place during a calender year for the work. In general, the workers report to their employer, i.e., the contractor, on day-to-day basis. The principal employer may not have direct control over the workers and hence, it is difficult for the principal employer to track and monitor the work carried out by the contract workers.
The contribution of the itinerant workers to the workforce in the nuclear industry is continuously on the rise. The itinerant workers in radiation or nuclear facilities may be self-employed or employed by a contractor, at different sites and at different times and for varying durations. They work in supervised areas and often in controlled areas.
In fact, the collective dose due to exposures of the itinerant workers in planned exposure situations is becoming a major contributor to the total collective dose in: nuclear fuel cycle facilities; application of radioisotopes in industry; processing of ores/minerals/raw materials; facilities using radiation in medical diagnosis and treatment, and service/maintenance workers in oil and gas industry.
IAEA Safety Guide on Occupational Radiation Protection (1999) provided limited guidance on radiation protection aspects of the itinerant workers by way of cooperation to the extent necessary between employers of the workers (contractors) and the registrant/licensee (principal employer).
IAEA-BSS-GSR Part 3 (2014) - (requirement 23) give limited guidance on the procedures to be followed when the facilities are required to hire itinerant workers to carry-out work involving radiation exposures. Some of the well-trained/specialist workers (e.g., radiographers, welders) often move from one place to another for the work that involves exposures to radiation nearing the dose limits.
Although the primary responsibility for the radiological protection of workers lies with the management of the facility (registrant/licensee), the employer of the itinerant workers as well as the workers also bear certain responsibilities. IAEA Safety Report (2015) addresses the issues related to the use of itinerant workers and provides the necessary guidance based on GSR Part 3 for controlling radiation exposures. The important radiological safety concerns or issues are: lack of expected level of competence/training, level of information exchange, dose tracking and control, ethical aspect allowing workers to work in high radiation fields, medical follow-up of the exposed, and attitude of indulgence on the part of itinerant workers, and need to develop safety culture among the workers. The concerns are addressed in the Safety Report so that clear allocation of responsibilities to all the relevant parties, including the workers, can be established.
The new IAEA Safety Report (Safety Reports Series No. 84, Radiation Protection of Itinerant Workers, IAEA, Vienna, 2015) recommends maintenance of personal exposure records in a form to facilitate interstate/international itinerant workers, to keep their dose records i.e., individual radiological monitoring document (IRMD) while travelling from one site to another work site. Like passport, one must carry this IRMD while travelling to different worksites.
Forthcoming IAEA Safety Guide on Occupational Radiation Protection is expected to provide extensive guidance on radiation protection of itinerant workers for implementation of the BSS requirements for regulatory compliance.
In India, the Atomic Energy Regulatory Board (AERB) Radiation Protection Manual (2005) gives guidance on the dose limits for the occupational exposure of temporary workers. It states that the installation employing the temporary worker shall be responsible for compliance with the dose limits. The manual also gives in the appendix, the procedure for employing temporary workers, hired directly (called casual workers) by the department or through a contractor. Training requirements, format for submission of medical fitness certificate, responsibility for maintenance of dose records, etc., are also given. It is stated that the responsibility for the radiological safety of the temporary workers during their work at site shall be the responsibility of the installation employing them. It further states that the work shall be carried out under the direct supervision of regular employees.
Appendix-I of the AERB Radiation Protection Manual provides (in “shall” statements) procedure in some detail for employing temporary workers, management of the radiation exposures, training requirement of the supervisors employed by the contractor, etc. If the mandatory requirements, as stated, are met through the radiation protection program designed by the facilities employing them, there is not much scope for any deficiency in the radiological protection of the temporary workers.
However, among others, the following points may be considered to ensure the workers safety, environmental safety and to avoid any possible medico-legal and ethical issues arising out of linear no-threshold approach followed in radiological protection.
- Amendments to the Contract Labour Act (1970) in India, is fast evolving, which greatly reduces the differences between contract workers and regular workers. The temporary staffing industry is likely to grow to 9 million workers by 2025
- The primary responsibility to radiological safety of the workers during the work at site will be of the management
- Implementation of IRMD, to facilitate exposure management and demonstrate compliance with the regulatory dose limits
- Hiring of temporary workers through well-established contractor, with adequate capability to train the workers in radiation protection, and has his own radiation protection officer (RPO) to ensure the radiological safety of the contract workers at the site. The contractor's RPO will ensure that the workers are not over-exposed and the exposures remain within the annual dose constraint of 15 mSv
- Facility management can provide the training support to the contractor in radiological protection, initially, as part of technical assistance
- The current dose limit of 15 mSv/y can be treated as dose constraint and the dose limit could be an effective dose of 20 mSv/y. Any exposures exceeding the local regulatory constraint will be investigated by Exposure Investigation Committee. The recommendations are binding on the workers and contractor
- The contractor should be made responsible to medical follow-up of the workers and ensure providing bioassay samples of the workers to the department as and when required
- Medical surveillance of the contract workers will be of the responsibility of the contractor
- The security of the source owned by the contractor is the responsibility of the contractor (e.g., radiography source, gauging devices). He should ensure that the exposures of the regular workers likely to be caused by operating the source owned by the contractor should be avoided
- Providing only limited access to controlled areas, particularly those of high hazard with potential for criticality accident and high levels of acute exposures
- Radiation exposure records will be maintained by the contractor as well as the facility management/authorized agency, in addition to IRMD
- The responsibilities of the contractor, the workers, the facility RSO, and the facility management should be well documented before the commencement of the work.
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