4 Regulatory Framework for Nuclear and Radiation Safety in Kyrgyzstan
4.4 Radiation Safety
4.4.1 Radiation Safety Regulations on the Use of Radiation Sources
In the Kyrgyz Republic, the use of radiation sources in industry, agriculture, medicine, education and scientific research is subject to state regulation (the Law of the Kyrgyz Republic Technical Regulations
"On Radiation Safety" [12]). The following deficiencies are noted with regard to this Technical Regulation [12]:
Classification of radioactive sources is not detailed and there is no reference provided to a document where such classification is provided.
There is no provision for the separation of exposure situations to the categories of planned, emergency and existing exposure.
There is no requirement for parties responsible for ensuring protection and safety to ensure the application of radiation protection principles in all exposure situations.
There are no requirements to ensure the control of radioactive sources that were left unattended, lost, misplaced, stolen or transferred without official permission.
There is no information on practical activities and sources of ionizing radiation to which the requirements relating to planned exposure situations apply.
There are no requirements for a differentiated (commensurate with radiation risks) approach to ensuring radiation safety and the optimization of protection.
There is no requirement for licensing activities when dealing with sources of ionizing radiation.
The terms “out of control” and “release from control” are not used and the criteria for removal and release do not fully comply with the recommendations in IAEA Basic Safety Standards, GSR Part 3 [14].
The IAEA removal criteria for unlikely scenarios are not considered in Annex I.
There are no provisions for exclusion, exemption or exemption of sources, or related activities from regulatory control.
There is no requirement for registered persons and licensees to be responsible for the implementation of emergency plans drawn up by them and for ensuring readiness to take all necessary actions to ensure an effective response.
Requirements for ensuring the safety of radiation generators during production, supply and use are not given.
There is no requirement that the use of a protection and safety system be extended to the use of ionizing radiation for visualizing a person for purposes other than medical diagnosis, treatment or biomedical research.
There are no requirements placed on employers, registered persons and licensees to protect staff from occupational exposure, to optimize radiation protection and safety and to ensure dose limits set for occupational exposure are not exceeded.
There is no requirement for diagnostic reference levels, dose constraints, and patient discharge criteria and guidelines to be established.
There is no requirement for the justification of medical exposure of patients to be carried out through consultations between the radiologist and the attending physician in appropriate cases, and especially in the case of pregnant patients or breastfeeding women and their children, taking into account:
expediency of a request for radiation exposure
the urgency of the radiological procedure
characteristics of medical exposure
characteristics of the patient; and
relevant information about the patient’s previous radiological procedures.
There is no requirement to take measures to protect members of the public and family members of patients undergoing a course of treatment using radionuclides prior to their discharge, in particular, for the patient or legal guardian of the patient to be given information on radiation risks and
specifically written instructions for preventing the spread of radioactive contamination and for limiting contact with other persons to a reasonably achievable low level.
There is no requirement to take all practical measures to minimize the likelihood of unintentional or accidental medical exposure.
There is no requirement for periodic inspections at medical exposure facilities or for the maintenance of records.
One of the priority tasks within the standard-setting activities of the SAEPF, together with the DDPSSES, is the development and approval of regulatory sanitary documents for the regulation of medical sources, examinations and equipment for patient diagnostics and the provisions on the procedures for registering sources, including:
Sanitary rules and regulations. Requirements for ensuring radiation safety during radiation therapy with closed radionuclide sources.
Sanitary rules and regulations. Requirements for ensuring radiation safety during radionuclide diagnostics using radiopharmaceutical preparations.
Sanitary rules and regulations. Requirements for the placement and operation of electron accelerators with an energy of up to 100 MeV.
Sanitary rules and regulations. Requirements for ensuring radiation safety when handling radiation inspection installations.
Regulation “On the National Register of Ionizing Radiation Sources”.
These rules and regulations need to be developed and approved only after the main and basic policies (laws) on radiation protection and radiation safety standards (updated in line with the IAEA Basic Safety Standards [14] instead of the technical regulation) have been developed and approved. This is necessary to ensure that the new documents do not contradict the basic provisions on radiation protection.
In the field of radiation safety of the population and personnel, the regulatory bodies (SAEPF and DDPSSES) need to take the following actions:
to increase the level of radiation protection of personnel and the public through the introduction of basic safety requirements for handling radiation sources based on current IAEA standards
to optimize personnel exposure by establishing dose restrictions and a unified state system for recording and monitoring individual doses from occupational exposure
introduce criteria and systems for the recognition of experts on radiation protection, and also provide for training courses to improve the skills of specialists in the field of protection
to improve the system for the safe handling of radiation sources before their transfer to specialized enterprises for the management of radioactive waste
implement programs for the radiation protection of personnel of enterprises associated with naturally occurring radionuclide material (e.g. coal mines and quarries, oil refineries, etc.) and aircraft crew
develop and implement an action plan to reduce the impact of radon and its decay products on the population, to minimize the long-term risks of spreading radon in residential and non-residential buildings, and in the workplace from any source of radon penetration from soil, building materials or water
develop safety standards for radiation sources used for inspection and non-medical imaging.
The Kyrgyz Republic is a party to the Code of Conduct for the Safety and Security of Radioactive Sources [15], having sent to the IAEA notification No. 254m of June 6, 2016 on joining this Code.
4.4.2 Radiation Protection of Personnel and Dosimetry Services
In the Kyrgyz Republic, the basic principles of radiation protection: justification, limitation and optimization are established in the Law “On Radiation Safety” [3] and the Law of the Kyrgyz Republic Technical Regulations “On Radiation Safety” [12]. There are no expensive technical dosimetry services available (full-body counters and dosimeters for individual organs), which is largely due to the lack of nuclear facilities in the country, and there are no relevant regulatory documents that oblige operators to monitor the effective radiation dose of personnel. Regarding internal exposure, there are no manuals or technical means of monitoring, and there is also no competence of personnel of state bodies and operators about this type of exposure monitoring for personnel.
The following shortcomings are noted in the Law of the Kyrgyz Republic Technical Regulation “On Radiation Safety” [12] with respect to radiation protection of personnel and dosimetry services:
There is no requirement for employers, registered persons and licensees to be liable for protecting staff from occupational exposure, for optimizing protection and safety and for not exceeding the dose limits set for occupational exposure.
There are no requirements for the regulatory body to establish requirements for monitoring and recording occupational exposure under planned exposure situations and to ensure compliance with these requirements.
There are no requirements, with the exception of medical care, for employers of workers employed in jobs during which they are, or may be, exposed to occupational exposure:
to control occupational exposures and ensure the relevant dose limits for occupational exposure specified in Appendix III of the GSR Part 3 [14] are not exceeded
to optimize protection and safety in accordance with the requirements of GSR Part 3 [14] and to document decisions taken on measures to ensure protection and safety, and to transfer of information about them in appropriate cases to the relevant parties through their representatives, as determined by the regulatory body;
to apply policies, procedures and organizational measures aimed at ensuring protection and safety in order to fulfill relevant requirements, with a focus on design and technical measures to control occupational exposure
to have acceptable and adequate facilities, equipment and services designed to ensure protection and safety available, which by type and scale correspond to the expected probability and
magnitude of occupational exposure
to ensure the availability of appropriate monitoring instruments and personal protective equipment and to adopt appropriate measures for their proper use, calibration, testing and maintenance; and
to ensure the availability of adequate human resources and to provide adequate training in safety and security, as well as periodic retraining of personnel as necessary to ensure the necessary level of competence.
There is no requirement for employees to fulfill their obligations with regard to ensuring protection and safety, including: compliance with all applicable rules and procedures to ensure protection and safety established by the employer, a registered person or the licensee; using their monitoring equipment and personal protective equipment properly; and cooperating with an employer, a registered person or a licensee in matters of protection and safety, as well as in connection with the implementation of health monitoring programs and employee dose assessment programs.
There is no requirement for organizational, procedural and technical measures to be established and implemented by employers, registered persons and licensees in order to define controlled zones (and not only the sanitary protection zone) and observation zones, to introduce local rules and monitor workplaces as part of a radiation protection program as applied to occupational exposure.
There is no relevant information on procedures and personal protective equipment.
There are no requirements to minimize the need to apply administrative measures and personal protective equipment using well-developed engineering measures and ensuring satisfactory working conditions in accordance with the following hierarchical order of preventive measures:
engineering measures
administrative measures
personal protective equipment.
There is no requirement to provide workers with acceptable and adequate personal protective equipment that meets relevant standards or specifications, including protective clothing. respiratory protection (the characteristics of which must be communicated to users) or protective aprons, protective gloves, mittens and screens to protect individual organs.
There is no requirement that employees receive appropriate instructions on the proper use of respiratory protection, including checking the individual fit of these products.
There is no requirement for the development and implementation of a workplace monitoring program by registered persons and licensees.
There is no requirement for employers, registered persons and licensees to be responsible for taking measures to assess and register occupational exposure to conduct individual dosimetry monitoring.
It is necessary to create a TSO, whose competence will include consulting, technical and methodological support for determining occupational exposures. It is also necessary to create national registries of occupational doses for medical workers, for personnel at factories and fields with natural radionuclide content and for exposure of aircraft crews, etc. However, it should be noted that, since 2012, control of occupational exposures has been carried out for medical personnel (whole body and skin exposure) using TLDs. Individual dose control for personnel in the economic sectors exposed to NORM is not carried out;
and for flight staff and staff of prisons and military units such monitoring is currently outside of regulatory control.
According to international standards, the licensing and accreditation of laboratories in accordance with ISO / IEC 17025 “Basic requirements for testing and calibration of laboratories” [16] should be
implemented in the country. This will be difficult, however, as currently there is no calibration laboratory present in the country to provide metrological services or services for interlaboratory comparisons. At the present time, all work in this field is conducted in collaboration with laboratories in neighboring
Kazakhstan. Working groups organized by SRCEPES SAEPF and DDPSSES are however discussing plans for the development of laboratories. The creation of a dose register to record information on the exposure of personnel and the population is also under discussion.
Thus, in the Kyrgyz Republic it is considered appropriate:
to improve national legislation by revising the radiation safety standards in the implementation of such concepts as planned, existing and emergency exposure situations
to develop a regulation on a unified state system for recording doses of radiation under planned exposure situations
to develop a national interface for the exchange of dosimetric information of established quality between manufacturers (laboratory of individual dose control), depository (registry) and licensees (i.e.
the users of data on individual doses); and
to strive to create a national calibration laboratory and repair base for metrological service testing laboratories.
During a visit of the Deputy Director General of the IAEA to the Kyrgyz Republic on 19-21 June 2019, it was noted that draft regulatory documents aimed at harmonizing Kyrgyz legislation with the requirements of IAEA safety standards would need to be approved to prevent problems with ongoing and future national projects aimed at restoring the use of nuclear medicine, improving radiation therapy and developing brachytherapy of the National Oncology Center (NCO). It was also noted that, for the IAEA, the situation with the stagnation of the work of the SPECT-CT device in the Department of Nuclear Medicine of the NCO since 2011 is an indicator of ineffective management and low control and that the Ministry of Health needed to increase its work in personnel training and other support for the Department. The supply of a TC-99m generator, under the guarantee of the regulator of the Kyrgyz Republic, has been approved.
However, the threat of a device launch failure may occur not only due to the lack of a technetium
generator, as happened in 2011, but also due to a lack of trained personnel. Due to poor management and the difficult economic situation in the country, retaining competent staff is one of the most important problems for the NCO.