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Article 13. Protection against accidents and in emergencies. The Committee notes that the Government’s report does not contain the information requested in its 2004 direct request. In that direct request, the Committee noted the Government’s indication that under section 166, relating to the preparation of emergency plans, of the 1998 Regulations respecting technical protection against ionizing radiations, the recommendations used are those contained in the October 2003 document “Method for developing arrangements for response to a nuclear or radiological emergency: Emergency preparedness and response”. It noted that the definition of “emergency” contained in this document justifies the exceptional exposure of workers in the event of occurrences which require, inter alia, interventions to reduce the adverse effects on property. The Committee observed that this definition appears incompatible with section 189 of the 1998 Regulations respecting technical protection against ionizing radiations, which provides that workers participating in an intervention may undergo exposure resulting in the maximum permissible dose for occupational exposure in a single year being exceeded solely for the purpose of saving lives or preventing serious injury, avoiding a high collective dose or preventing the development of catastrophic situations. In this respect, the Committee drew the Government’s attention to the information contained in paragraphs V.27 to V.32 of the 1994 Basic Standards of Radiation Protection and paragraph 35(c)(iii) of its 1992 general observation under the Convention, namely that exceptional exposure of workers is not justified for the purpose of rescuing “items of high material value”. Consequently, the Committee invited the Government to take the necessary measures to correct the apparent contradictions between the legislation and the recommendations of the October 2003 document entitled “Method for developing arrangements for response to a nuclear or radiological emergency: Emergency preparedness and response”, with a view to limiting the exposure of workers to what is strictly necessary for the purpose of limiting acute danger to life and health. The Committee once again requests the Government to indicate the manner in which it is ensured that the workers participating in an intervention cannot be exposed to such an extent that the maximum permissible dose for occupational exposure in a single year is exceeded for the purpose of rescuing items of high material value, but only in order to save lives or prevent serious injury, avoid a high collective dose or prevent the development of catastrophic situations.
Part V of the report form. Application in practice. In its previous comments, the Committee noted the Government’s indication that, under section 206 of the 1998 Regulations respecting technical protection against ionizing radiations, all inspections and audits are documented and, emphasizing that inspectors’ reports constitute an important component in assessing the application of the Convention, it requested the Government to provide extracts from the reports drawn by the Directorate-General for Occupational Safety and Health, which is the competent authority to monitor the application of the provisions of the Convention. Noting that the Government has not provided the requested information, the Committee once again requests it to provide this information and to indicate the number of workers engaged in activities involving exposure to ionizing radiations and who are accordingly covered by the Convention.
The Committee notes the Government’s report in response to its previous comments. It would like to draw the Government’s attention to the following points.
1. Article 13. Protection against accidents and in emergencies. The Committee notes that instead of the term "emergency" the term "accident" is used, which corresponds to the definition laid down by the 1994 International Basic Safety Standards for protection against ionizing radiation and for the safety of radiation sources. It also notes the Government’s indication that, under section 166 of the 1998 Regulations concerning Technical Protection against Ionizing Radiations relating to plans for emergencies, the recommendations contained in the October 2003 document entitled "Method for developing arrangements for response to a nuclear or radiological emergency - Emergency preparedness and response" are being used. It notes that the definition of "emergency" contained in this document justifies the exceptional exposure of workers in the event of occurrences which require, inter alia, interventions to reduce the adverse effect on property. The Committee observes that this definition appears incompatible with section 189 of the 1998 Regulations concerning Technical Protection against Ionizing Radiations, which stipulates that workers participating in an intervention may undergo exposure resulting in the maximum permissible dose for occupational exposure in a single year being exceeded solely for the purpose of saving lives or preventing serious injuries, avoiding a high collective dose or preventing the development of catastrophic situations. In this respect the Committee once again draws the Government’s attention to the information in paragraphs V.27 to V.32 of the 1994 International Basic Safety Standards and paragraph 35(c)(iii) of its 1992 general observation under the Convention, namely that exceptional exposure of workers is not justified for the purpose of rescuing "items of high material value". Consequently, the Committee invites the Government to take the necessary measures for correcting the apparent contradictions between the legislation and the recommendations of the October 2003 document entitled "Method for developing arrangements for response to a nuclear or radiological emergency - Emergency preparedness and response", aimed at limiting the exposure of workers for the purpose of meeting an acute danger to life and health to what is strictly necessary.
2. Part V of the report form. The Committee notes the Government’s indication that there are no mechanisms for facilitating the collection of information on the practical application of the Convention in the country and that the Labour Ministry hopes to provide such information in the future. Noting that, under section 206 of the 1998 Regulations concerning Technical Protection against Ionizing Radiations, all inspections and audits are documented and emphasizing that inspectors’ reports constitute an important component in assessing the application of the Convention, the Committee requests the Government to send at least extracts of these reports drawn up by the Directorate-General for Safety and Health at Work, which is the competent authority for monitoring the application of the Convention.
The Committee takes note of the reports of the Government in response to its previous comments.
1. Protection against accidents and in emergency situations. The Committee notes with interest the provisions contained in sections 74 and 165 et seq. (Chapter XIV) of the 1998 Regulations concerning Technical Protection against Ionizing Radiations, prescribing the measures to be taken in emergency situations which reflect the indications provided by the Committee in paragraphs 16 to 27 and 35(c) of its 1992 general observations under the Convention, and the indications contained in paragraphs V.1. to V.30. of the 1994 International Basic Safety Standards. The Committee however notes that the above Regulations refer to emergency situations, but do not provide a definition of what is considered as an emergency. In this respect, the Committee draws the Government’s attention to the matters raised in paragraph 35(c)(iii) of the conclusions to its 1992 general observation under the Convention, according to which provisions should be made in law and practice for adopting a strict definition of circumstances in which exceptional exposure of workers, exceeding the normally tolerated dose limit, is to be allowed for immediate and urgent remedial work; that work must be strictly limited in scope and duration to what is required to meet an acute danger to life and health; exceptional exposure of workers is neither justified for the purpose of rescuing items of high material value, nor, more generally, because alternative techniques of intervention, which do not involve such exposure of workers, would involve excessive expense. The Committee therefore requests the Government to indicate, in its next report, the measures adopted to take into consideration the recommendations formulated in this respect by the Committee in its abovementioned general observation under the Convention.
2. Part V of the report form. The Committee requests the Government to supply information on the manner in which the Convention is applied in practice in the country, including, for example, extracts from inspection reports or from other official reports on practical difficulties encountered in the application of the Convention.
The Committee notes with satisfaction that the National Commission on Atomic Energy (CONEA) adopted in May 1998 the Regulations concerning Technical Protection against Ionizing Radiations, giving effect to the provisions of the Convention, and in particular to Article 3, paragraph 1, Article 6, paragraph 2, and Article 7 of the Convention.
The Committee notes the information supplied by the Government in its report covering the period 1992 to 1994.
1. Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention. The Committee drew previously the Government's attention to the revised dose limits adopted by the International Commission on Radiological Protection (ICRP) in 1990 and asked the Government to indicate steps taken to ensure effective protection of workers against ionizing radiation in the light of current knowledge. The Committee takes note with interest of Act No. 156 of 1993 on ionizing radiation and of Decree No. 24-93 establishing the National Commission on Atomic Energy. It also notes that the Government indicates in its 1994 report that regulations on radiological protection were being drafted. The Committee hopes that the Government will provide information on the provisions adopted in the light of the 1990 above-mentioned recommendations and the 1994 International Basic Safety Standards for protection against ionizing radiation and for the safety of radiation sources, and that it will supply a copy of the regulations when adopted.
2. Article 7. The Committee requests the Government to provide information on the provisions of laws or regulations or other means that prohibit the employment of persons under the age of 16 in work involving exposure to ionizing radiation.
3. Protection against accidents and in emergency situations. Referring to the explanations given in paragraphs 16 to 27 and 35(c) of its 1992 general observation under the Convention and in the light of paragraphs 233 and 236 of the 1994 International Basic Safety Standards, the Committee hopes that the Government will provide information on the measures taken or contemplated in relation to emergency situations.
4. Provision of alternative employment. With reference to paragraphs 28 to 34 and 35(d) of its 1992 general observation, and the principles reflected in paragraphs 96 and 238 of the 1994 International Basic Safety Standards, the Committee requests the Government to provide information on measures taken or contemplated to ensure effective protection of workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur and who may thus be faced with the dilemma that protecting their health means losing their employment.
In its previous direct request, the Committee noted that the Judicial Department of the Ministry of Labour was in the process of preparing draft regulations to give effect to the Convention. The Government has indicated in its latest report that a draft Labour Code is being prepared, with the technical assistance of the ILO, which will ensure the application of ratified conventions. The Committee notes from the Government's report that this draft Code should be studied by all social partners during a tripartite seminar to be held in March and, upon its approval, will be presented to the Legislative Assembly for adoption. The Committee reiterates the hope that the necessary measures be taken, either in the form of regulations, as mentioned previously by the Government, or in the Labour Code, in order to give full effect to the provisions of the Convention.
In this regard, the Committee would recall that, under Article 3, paragraph 1 and Article 6, paragraph 2 of the Convention, all appropriate steps shall be taken to ensure effective protection of workers against ionising radiations and to review maximum permissible doses of ionising radiations in the light of current knowledge. The Committee would call the Government's attention to its General Observation under this Convention which sets forth, inter alia, the revised exposure limits established on the basis of new physiological findings by the International Commission on Radiological Protection in its 1990 Recommendations (Publication No. 60). The Committee hopes that the Government will take these new findings into account when drafting the legislation necessary for the application of the Convention. The Government is requested to provide information in its next report on the progress made in adopting the legislation necessary for the application of the Convention, and in particular, on the steps taken or being considered in relation to the matters raised in the conclusions to the General Observation.
1. The Committee thanks the Government for the labour inspection report supplied in reply to its previous direct request.
2. The Committee notes with interest that the Judicial Department of the Ministry of Labour is in the process of preparing draft regulations giving effect to the Convention. The Committee hopes that the regulations will be adopted in the near future and that they will ensure the application of all the Articles of the Convention.