Alternative activity limits for exempt consignments in Belgium – Feedback and lessons learned

The 2012 Edition of the IAEA Regulations for the Safe Transport of Radioactive Material (SSR-6) [1] has introduced the concept of alternative activity limit for an exempt consignment of instruments or articles, which requires multilateral approval by the competent authorities involved. These requirements have been transposed into the latest edition of the modal regulations (ADR, RID, ADN, ICAO TI, IMDG). Applicants and authorities from several countries are therefore currently dealing with applications for this new type of approval.On the other hand, European Council Directive 2013/59/Euratom of 5 December 2013 laying down basic safety standards for protection against the dangers arising from exposure to ionising radiation [2] requires that the use of radioactive substances in consumer products be justified and subject to licensing by the competent authority. These requirements have been transposed into Belgian regulations [5].For consumer products that are used in Belgium, both regulations apply. The Belgian competent authority (Federal Agency for Nuclear Control, FANC) has set up a joint expert group to deal with the consumer product licence. In order to facilitate the regulatory process, applications for the approval of an alternative consignment exemption limit are simultaneously reviewed by the joint expert group on the basis of a single application submitted through the consumer product licensing framework.In 2015, the FANC received applications for the approval of an alternative activity limit for an exempt consignment of lamps containing Kr-85 or Th-232. Difficulties and recurring misunderstandings between the FANC and the applicants, but also good practices have been identified during the review of these applications.This paper discusses the FANC's feedback on the joint expert group from the transport's perspective and the lessons learned regarding the approval of an alternative activity limit for an exempt consignment.