Year
2010
File Attachment
Abstract
The transport of radioactive materials has to comply with the requirements of the modal regulations for the transport of dangerous goods. These are based on the “Regulations for the Safe Transport of Radioactive Material” set forth by the International Atomic Energy Agency (IAEA). When analysing these Regulations, it appears that the requirements can be roughly classified in three categories: - (very) general requirements, - “normal” requirements, - (very) detailed requirements. The second category does not induce any difficulty, by the definition of this level of requirements. The first category leads to difficulties when implementing the Regulations. The industry may not know exactly what is expected by the Regulations and the regulators. Also, as these requirements are (too) general, they may be interpreted differently in various countries. Eventually, it can also be considered that they are not really requirements, but clauses establishing the background of the “true” requirements. The third category may lead to safety issues. They can generally be considered as giving examples of what is requested in a “normal” requirement. But this may also be understood as clarifying a “normal” requirement: the detailed requirement is no longer understood as an example but as the true (and limiting) requirement. The paper provides examples of these three levels of requirements and the issues which are linked to these examples. There is a will within the IAEA to improve the wording of the Regulations, to make the Regulations more easily understandable. This initiative should be strongly supported and the issues described above should be carefully taken into account when rephrasing the text. In parallel, there is also a trend within the IAEA to define overarching requirements. The paper explains our views on what could be overarching requirements, how they should interact with the other requirements (i.e. non overarching requirements), and what should be the limits with companion documents including explanatory and / or guidance material.