Observation (CEACR) - adopted 2010, published 100th ILC session (2011)

The Committee notes the information in the Government’s latest report, including references to the availability of legislation online. The Committee also notes the inclusion of observations made by the Confederation of Industry and Transport on the importance of occupational safety and health (OSH) policy in the sector of radiation protection, despite the high costs, and that surveillance of workers in this area is undertaken by the Czech authorities, and also the strong pressure of both the Czech Republic and the international community. The Committee further notes the responses by the Government to its previous comments, which appear to show effect given to Articles 1 and 12 of the Convention. The Committee asks the Government to continue to provide information on the relevant measures undertaken with regard to the Convention.

Article 5 of the Convention. Exposure to ionizing radiation. The Committee notes the response provided by the Government indicating that the principle of optimization and other basic principles of radiation protection are enshrined in Act No. 18/1997 Coll., the Atomic Act, as amended. The Government indicates that limiting the exposure of workers to the lowest level possible is done using the system of quality assurance, and that such a system requires each workplace involved in disposing ionizing radiation to submit the so-called evidence of optimization as well as a quality assurance programme according to section 13(5) of the Atomic Act, which forms a part of the approval documentation for a permit to dispose of ionizing radiation. Section 17(3) of Decree No. 307/2002 Coll., as amended, takes into account the economic and social factors to assess the benefits of measures for introducing graded radiation activities, medical radiation, natural and accidental exposure. The Committee notes that the Government has not referred to any efforts made to restrict the exposure of workers to ionizing radiation to the lowest practicable level, and that any unnecessary exposure is to be avoided. The Committee reiterates its request that the Government indicate the measures taken or envisaged to apply Article 5 of the Convention, in law and in practice.

Article 7. Prohibition against engaging workers under the age of 16 in work involving ionizing radiation. The Committee notes the information provided by the Government indicating that section 21 of Decree No. 307/2002 sets limits for apprentices and students (16–18 years of age), but that the Government does not specify the provisions which ensure that workers under the age of 16 are not engaged in work involving ionizing radiation. The Committee asks the Government to specify the exposure limits set for apprentices and students
(16–18 years of age); and to indicate the measures taken or envisaged to ensure that no worker under the age of 16 shall be engaged in work involving ionizing radiation.

Article 8, in accordance with Article 6. Levels to be set for workers who are not directly engaged in radiation work. The Committee notes the information provided by the Government which indicates that section 23 of Decree No. 307/2002 limits the exposure of individuals in special cases, including exposure of individuals who care for patients exposed to medical radiation beyond their duties or who live in the same household (persons older than 18 years), and that the limit for such exposure is 5 mSv per calendar year and 1 mSv per calendar year for other persons. The Committee, referring to paragraph 35(a)(ii) of its 1992 general observation on the Convention which specifies that external and internal exposures of workers not directly engaged in radiation work, as well as of members of the general public, are to remain below 1 mSv a year, asks the Government to keep the Office informed of any measures taken to bring national laws into line with these requirements.

Part V of the report form. Application of the Convention in practice. The Committee notes the response provided by the Government indicating that the reduction of risk of accidental exposure of workers to a dose exceeding the maximum permissible limit (occurring in only extremely rare incidents) is dealt with in the document “On-site Emergency Plan” that is part of the approval documentation for permission to use ionizing radiation sources (in the annex to the Atomic Act), and that the focus of inspectors of the State Office for Nuclear Safety is also to prevent such situations. The Committee notes the detailed information provided by the Government in its report regarding the application of the Convention, including on inspection activities in the area of radiation protection. The Government indicates that a total of 1,078 inspections were carried out in the area of radiation protection in 2009, of which 33 were identified as grade 3 (meaning an inspection in which deficiencies were detected preventing a safe manner in the carrying out of activities leading to exposure). The Committee also notes the information that 22,500 workers were monitored by dosimetric services in 2009. The Government indicates that the issuing of personal radiation cards has helped ensure an accurate and a complete assessment of doses for workers entering the controlled area. The Committee notes the information that, based on an analysis of the findings from investigations of higher doses, the critical group of workers with high occupational exposure (apart from uranium miners) are doctors conducting medical intervention radiology procedures. The Government also indicates that since 2002, radiation exposure of workers has been monitored in workplaces where there may be a significant increase in radiation from natural sources, and that the most important professional groups, whose doses are regularly evaluated, are airline staff and tour guides in caves open to the public. The Committee asks the Government to continue to provide information on the application of the Convention in practice.