LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT by a service under the authority of the Defence and Security High Official (HFDS) of the Ministry responsible for energy. The changes in regulations adopted since early 2016 have led to an organisation for oversight of the protection of ionising radiation sources against malicious acts which takes into account the existing organisation by entrusting this oversight: ∙to the service of the HFDS of the Ministry responsible for energy in facilities whose security is already under its control; ∙to the Ministry of the Armed Forces in the locations placed under its authority; ∙to ASNR for the other nuclear activities. The process necessary to set up this oversight, initiated by the Government in 2008 with the assistance of ASNR, resulted in Ordinance 2016‑128 of 10 February 2016 and then Decree 2018‑434 of 4 June 2018 introducing various provisions concerning nuclear activities. These texts, which amend the Public Health Code, divide up the oversight duties in the various installations as indicated above, by including protection against malicious acts in the risks that must be taken into account by the persons/entities Responsible for Nuclear Activities (RNAs) and by the regulatory bodies when reviewing the licensing applications. The sources and installations concerned Oversight of source protection against malicious acts concerns all sources of ionising radiation, that is to say all the devices that could cause exposure to radiation. The majority of the regulatory measures are however taken to increase the security of the sources presenting the greatest radiological risks: this concerns sealed radioactive sources of categories A, B and C as defined in the Public Health Code, which stems directly from that of the IAEA. The protection requirements are proportionate to the intrinsic dangerousness of the sources. The graded approach therefore implies stricter obligations for the sources (or batches of sources) in category A than those in category C. Sealed sources that are not in categories A, B or C and whose activity exceeds the exemption threshold, and the other ionising radiation sources such as X-ray generators, are classified in category D. In France, 273 facilities in the civil sector hold just over 6,230 radioactive sources of category A, B or C presenting real security risks. These sources are used essentially for industrial purposes (irradiation, radiography, measurements, etc.) or medical purposes (such as telegammatherapy and brachytherapy. Due to their frequent movements when on worksites, industrial radiography sources present particular security risks. If sources of different categories are stored together, the lower category sources may be subject to the stricter security measures applicable to the higher category sources. Regulations The Decree modifying the regulatory part of the Public Health Code taken in application of Ordinance 2016‑128 of 10 February 2016 (Decree 2018‑434 introducing various provisions with regard to nuclear activities) was published on 4 June 2018. It contains several provisions concerning the protection of sources against malicious acts, and more specifically: ∙the classification of ionising radiation sources and aggregation (batching) of radioactive sources into category A, B, C or D according to the intrinsic level of risks presented by these sources or batches of sources. The category A sources are the most dangerous and the category D sources the least dangerous (Article R. 1333-14 of the Public Health Code); ∙the obligation to notify promptly the various administrative authorities, particularly the regionally competent law enforcement agencies, of any actual or attempted malicious act or loss concerning a source of ionising radiation or a batch of radioactive sources of category A, B or C (R. 1333‑22); ∙the sending of sensitive information, that is to say elements that could facilitate malicious acts by separate, specially identified mail (R. 1333‑130); ∙the issuing of a nominative and written authorisation to the persons having access to ionising radiation sources or batches of radioactive sources in category A, B or C, transporting them, or having access to information concerning their protection against malicious acts (R. 1333‑148). Subsequently, the Ministerial Order setting the organisational and technical requirements to protect sources of ionising radiation (or batches of radioactive sources) against malicious acts was signed on 29 November 2019 and published in the Official Journal of the French Republic on 11 December 2019. Its provisions were brought progressively into effect over a period extending to the end of 2022. Today they are all applicable. The Order of 29 November 2019 amended also applies to the transport of category A, B and C sources, whether individually or in batches. The main requirements of this Order aim, by adopting a graded approach based on categories A, B, C (and D for two items), to have the licensee put in place physical barriers and equipment, along with a policy and an internal organisation to protect sources against malicious acts. These technical and organisational provisions are intended to: ∙prevent or delay the theft of radioactive sources through access control measures, reinforcement of physical barriers and their openings (doors, windows, etc.), alarms and crossing-detection; ∙protect sensitive information (access limited to duly authorised personnel, promotion of good information technology security practices); HIGHLIGHT No. 2 Categorisation of international transfers of radioactive sources: the prior consent procedure It is of crucial importance to ensure the control of sealed radioactive sources and to protect them against malicious acts during their import or export. The IAEA has published a document entitled “Guidance on the Import and Export of Radioactive Sources”, with the aim of providing its members with a consistent international framework. This framework is not mandatory, but is intended to be taken into account by the IAEA member states in their regulations. It aims to ensure regulatory control that is as harmonised as possible throughout the transfer of the sources between the originating and destination countries. The guidelines are complementary to those of the IAEA’s Code of Conduct on the Safety and Security of Radioactive Sources. To date, 135 countries, including France, have undertaken to take up these principles in their regulations. The Guidance on the Import and Export of Radioactive Sources was first published in 2005, two years after the approval of the Code of Conduct. The current version, revised in 2012, focuses primarily on category 1 and 2 radioactive sources (the most dangerous), used predominantly in medical and industrial applications. Maintaining control of these sources during their import or export is vital given their high radioactivity, which makes them a threat in the event of accidental radiation exposure or illegal or unauthorised use. The guidance notably recommends that the consent of the importing country be obtained before export of category 1 sources is permitted and that the exporting company send notification to the importing country one week before the planned shipping date (for category 1 or 2 sources). The aim is to know the dates on which category 1 or 2 sources or batches of sources arrive in or leave the national territory, so that a rapid response can be made in the event of an actual or attempted malicious act or an emergency situation (accident, climatic event, etc.). ASN resolution 2015-DC-0521 of 8 September 2015 (see Highlight No. 4) has laid down these principles in French law. Forms have been drafted and “points of contact” have been appointed to streamline international information exchanges between competent authorities, as recommended in the IAEA guidance. Consent requests involving France mainly come from two countries: Canada and the United Kingdom. There are just under ten import consents per year, and about half as many export consents. ASNR Report on the state of nuclear safety and radiation protection in France in 2025 241 01 05 02 06 03 04 09 10 07 11 13 08 12 A / Z
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