LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT Finally, ASNR will implement the roadmap designed to take into account the Operating Experience Feedback from the event at the Louvre’s Centre de recherche et de restauration des musées de France (C2RMF), in order to strengthen radiation protection in facilities using particle accelerators (see Highlight No. 9). Oversight of the protection of radioactive sources against malicious acts ASN, and now ASNR, has been designated as the authority to oversee the provisions to protect radioactive sources against malicious acts in the majority of facilities. This essentially concerns activities associated with gamma radiography and brachytherapy. Publication of the Decree of 4 June 2018 brought into effect the first provisions in this respect in mid-2018: those Responsible for Nuclear Activities (RNAs) must more specifically give individual authorisations for access to the most hazardous sources, including for their transport, and for access to sensitive information. These initial provisions have been reinforced with the entry into effect on 1 January 2021 of part of the amended Order of 29 November 2019 which requires company functioning and organization to be adapted to these specific risks. Although these are new regulatory provisions, it is above all an additional risk to be managed and integrated in the corporate culture particularly through measures to raise awareness and inform the personnel, which must be renewed periodically. On this account, the quality management system must include measures to combat malicious acts, and senior management of the companies concerned must henceforth define and formalise a policy of protection against malicious acts implemented by the RNA. This person must be assigned the necessary resources and have the requisite skills (assisted if necessary by a person trained in this area) and sufficient authority. The measures adopted must also take account of the “cyber” aspect in order to fight against the compromising of sensitive information, a matter provided for explicitly by the Order of 29 November 2019 amended. All the company staff and external partners must be made aware of this subject. In order to have appropriate rules, the company’s sensitive information must be clearly identified. On 1 July 2022 the Order entered fully into effect and the technical provisions for the physical protection of sources should have been put in place, both within facilities and at worksites (utilisation, possession) and for road transport operations. Since 2019, the ASNR inspections address the protection of sources against malicious acts with more and more emphasis. Inspections devoted entirely to this question began in limited numbers in 2021 and reached “cruising speed” as of 2023 with more than 60 annual inspections. For the first time, the 2022-2025 inspection cycle has enabled all the facilities concerned to be inspected for all the provisions covered by the amended Order of 29 November 2019. The annual level of 50 to 60 inspections will be maintained in 2026. When reviewing the nuclear activity licence applications, ASNR also ensures that the necessary technical and organisational provisions have been put in place. The content of application takes this question into account. The effective entry into force of the licensing system for the transportation of category A, B or C sources by road (see point 2.3.2). ASNR has therefore issued its first authorisations to the carriers concerned and will begin the first inspections in this area in 2026. It has also continued the actions initiated to train its personnel in this new duty and has made in-house aids available (inspection guide, licence application review matrices, question-and-answer sheets, networks of regional correspondents). To conclude, some effects of the Order of 29 November 2019 amended have been clearly visible for slightly more than a year: reduction in the number of sealed radioactive sources possessed by some licensees, grouping of industrial radiography agencies and equipping of vehicles, improvement in the systems protecting the sources (physical protection, detection, access control, surveillance, etc.). However, the task is not over, as illustrated by the feedback on the inspections carried out (see Highlight No. 5). Work in 2026 will focus on three areas: ∙an initial minor amendment to the amended Order of 29 November 2019. Based on OEF taken from past inspections, it is more a question of clarifying or even relaxing certain provisions than adding requirements. Discussions must be held with the Ministry responsible for energy transition, signatory of the Order, to move forward on these points; ∙possible longer-term changes to the text on the subjects of cybersecurity, security culture and internal threats, which require the launch of in-depth discussions involving the Ministry, the DEND and ASNR; ∙the culmination of discussions on the protection of unsealed sources. DEND had been mandated by the Ministry responsible for energy transition to conduct field investigations to assess the overall level of protection of unsealed sources. These are mainly used in the medical or research sector, and very often have a radiological activity of no more than a few days, but can present points of concern (large quantities used in production, daily transport flows, etc.). Based on the result of the investigations, the Ministry is expected to issue a position statement on whether or not to regulate such sources. ASNR, which is directly concerned, particularly given its monitoring of the medical sector, will be involved at every stage of the process. 260 ASNR Report on the state of nuclear safety and radiation protection in France in 2025
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