LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT by the French Accreditation Committee (Cofrac). All of these verifications (Labour and Public Health Codes) were carried out under the previous regulations solely by the AORPs. In addition, the Public Health Code verifications no longer concern the BNIs. The number of AORPs has significantly fallen as a result of these changes to the regulations. In 2023, the regulations concerning the verifications and services performed by the AORPs changed. Since 1 January 2023, the Order of 24 October 2022 relative to the procedures and frequency of the verifications of the rules put in place by the RNAs, abrogated ASN resolution 2010-DC-0175 of 4 February 2010 defining the AORP verification procedures. This text modifies the scope of the AORP verifications. The Order applies to medical and industrial nuclear activities subject to the systems set out in Article L. 1333-8 of the Public Health Code when these activities generate effluents or waste contaminated by radionuclides or likely to be contaminated, including by activation. It does not apply to nuclear activities from which the only waste generated is inseparable activated parts of a particle accelerator, as defined in Appendix 13-7 to the Public Health Code. ASN resolution 2022DC-747, which entered into force on 5 February 2023, supplements this Order. 1. The intervention is the representative unit of activity traditionally used by the labour inspectorate. This resolution defines the rules specified in the Order of 24 October 2022, that the party in charge of a nuclear activity is required to have verified by an AORP. This resolution is based on rules defined in ASN resolution 2008-DC-0095 of 29 January 2008, specifying the technical rules to be met by the elimination of effluents and waste contaminated by radionuclides, or liable to be so contaminated as a result of a nuclear activity, as well as resolution 2014-DC-0463 of 23 October 2014 relative to the minimum technical rules for the design, operation and maintenance of in vivo nuclear medicine facilities. Finally, ASN resolution 2010-DC-0191 of 22 July 2010 was replaced by resolution 2022-DC-0748, which came into force on 5 February 2023. This resolution lays down the conditions and procedures for approving the organisations responsible for the verifications referred to in Article R. 1333-172 of the Public Health Code. In 2025, as noted in chapter 5 on the medical sector, ASNR observed that certain Radiation Protection Organisations (RPOs) were offering radiation protection consultancy services without holding the certificate of competence as a radiation protection organisation. ASNR has informed more than a hundred employers and RNAs likely to be concerned by these practices, and inspection measures are underway. The certifications of the RPOs can be consulted on the websites of the three certifying bodies. 3 – Performing efficient regulation and oversight 3.1 Inspection 3.1.1 – Inspection objectives and principles The inspection carried out by ASNR is based on the following principles: ∙The inspection aims to verify compliance with the provisions that are mandatory under the regulations. It also aims to assess the situation with regard to the nuclear safety and radiation protection implications; it seeks to identify best practices, practices that could be improved and assess possible developments of the situation. ∙The scope and depth of the inspection adopts a graded approach to the risks inherent in the activity and the way they are effectively taken into account by those responsible for the activity. ∙The inspection is neither systematic nor exhaustive; it is based on sampling and focuses on the subjects with the highest potential significance. 3.1.2 – Inspection resources implemented To ensure greater efficiency, ASNR action is organised on the following basis: ∙inspections, at a predetermined frequency, of the nuclear activities and topics of particular health and environmental significance; ∙inspections of other nuclear activities decided on the basis of topical events (OEF, whistle-blower reports, context demonstrating difficulties, etc.); ∙inspections of approved organisations and laboratories. The inspections may be unannounced or notified to the licensee a few weeks beforehand. They take place mainly on the site or during the course of the activities (work, transport operation, etc.). They may also concern the head office departments or design and engineering departments at the major nuclear licensees, the workshops or engineering offices of the subcontractors, the construction sites, plants or workshops manufacturing the various safety-related components. ASNR carries out various types of inspections: ∙routine inspections, usually two inspectors for one day; ∙reinforced inspections, which consist in conducting an in-depth examination of a targeted topic by a larger team of inspectors than for a routine inspection; ∙in-depth inspections, which take place over several days, concern a number of topics and involve about ten or so inspectors. Their purpose is to carry out detailed examinations and they are overseen by senior inspectors; ∙inspections with sampling and measurements. With regard to both discharges and the environment of the facilities, these are designed to check samples that are independent of those taken by the licensee; ∙event-based inspections carried out further to a particularly significant event; ∙worksite inspections, ensuring a significant ASNR presence on the sites on the occasion of reactor outages or particular work, especially in the construction or decommissioning phases; ∙inspection campaigns, grouping inspections performed on a large number of similar installations, following a predetermined template. Labour inspectorate work in the NPPs entails various types of interventions(1), which more particularly involve: ∙checking application of the Labour Code by EDF and outside contractors in the NPPs (verification operations that include inspections); ∙participation in meetings of the Health, Safety and Working Conditions Commissions (CSSCT), of Social and Economics Committees and the inter-company committees on safety and working conditions; ∙conducting inquiries on request, following complaints or based on information, further to which the inspectors may take decisions as specified by the labour regulations, such as cessation of the works or the obligation to have the work equipment verified by an accredited organisation. Remote inspections can be performed by the inspectors, in conjunction with on-site inspections. This tool is suitable for certain 146 ASNR Report on the state of nuclear safety and radiation protection in France in 2025
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