THE GOOD, THE BAD, AND THE UGLY, OF THE TWO YEAR REVIEW CYCLE

With the adoption of the 1996 Edition of the “Regulations for the Safe Transport of Radioactive Material” IAEA began a biennial process for the review and potential modifications of the regulations. IAEA members are currently in the third review cycle; this experience provides a perspective of the benefits, the problems and the discord with this process. This paper presents a perspective of the nuclear industry on these issues. It also includes recommendations to make the process more meaningful and of greater value to all parties that involved. “The Good” will focus on the benefits, “The Bad” will identify the problems, and “The Ugly” will cover the discords. “The Good” An effective safety program/procedure includes a provision for periodic review and, if warranted, modifications. The 1996 Edition provides a schedule and a plan for executing that schedule. This provides for a logical review and modification and therefore a plan for keeping the regulations current. “The Bad” The benefit of a review of the regulations is lost when it is consumed by minor editorial changes that have minimal positive impact on safety. The use of limited resources to address insignificant changes results in a reduction of resources for safety in other aspects of the transportation area. The two year review should capture these minor changes but the implementation should be deferred until prompted by a significant change requirement or the volume of minor changes warrants a revision of the regulations. “The Ugly” The ugly part of the process is the adoption of the changes by the various competent authorities. In some competent authorizes it is a simple dictate that this is the way it will be, while other authorities have a very open public process with public participation and open meetings. The result is there is not uniform adoption of the changes either in timing or in consistency.