Regulatory Instructions and Guidance published by the CSN to overcome some difficulties to apply the regulatory requirements

The objective is to present three binding Safety Instructions (IS) and one Safety Guidance (GS) issued by the CSN in relation with the transport of radioactive material, which try to fill gaps in the regulatory requirements or help to its application.The necessary training of workers involved in the transport of radioactive materials is not specify by the IAEA SSR- 6 and not sufficiently detailed by modal Regulations as the ADR, which applies to the road mode in the European Union (EU). The CSN IS-38 develops the ADR requirements on training and specifies which personnel should receive training, the minimum content of such training, their frequency and the characteristics of the training records.Neither SSR -6 nor modal Regulations establishes when a change on the package may involve a design modification that shall lead to the revision of its certificate of approval. The CSN IS-35 defines the procedure to be followed by designers, manufacturers or users to analyze whether a modification has enough impact on safety and then involves a revision of the design approval certificate. This IS also applies to non-approval packages and defines the analysis to be carry out by the user or consignor in case they decide to perform a modification on the packaging.The Regulations do not specify neither the structure nor the content of the documentation of compliance of regulatory requirements for non-approval packages (para. 801 of the SSR- 6). The CSN IS-39 defines the structure of that document, which is in line with that defined by the Technical Guide on Package Design Safety Report of the European Association EACA, and also establishes the procedure for periodic control of the packages manufacture.The SSG -33 IAEA Guide (Schedules) is a useful tool for helping to apply the requirements of SSR-6 Regulations; however, there is not a similar guidance referring to the modal  regulations. The CSN has issued the GS-6.5, which has a similar goal of SSG-33 but focused on helping designers, manufacturers, consignors, carriers and consignees to compliance with the ADR.