[ RadSafe ] Is radiation work in any way special?

[parthasarathy k s]

To the list members
 
In
India,  the promotional and regulatory
activities in the field of atomic energy and radiation applications, are being
carried out by the Department of Atomic Energy (DAE) under the provisions of
the Atomic Energy Act 1962
 
In
November 1983, the Central Government set up the Atomic Energy Regulatory Board
(AERB) and delegated to it  powers under
relevant Sections of the Atomic Energy Act to enforce radiation and nuclear
safety in the country and industrial safety in the installations owned and
operated by the Department of Atomic Energy.
 
AERB
enjoys  functional autonomy and is able
to initiate regulatory actions on defaulting installations of DAE or other installations
based on inspections and regulatory reviews. These restrictions  included shutting down nuclear power stations,
reducing their power levels, directing retraining of workers etc.
 
Recently,  the Central Government  decided to enhance the legal status of AERB by
making it a statutory organization. For this, the Indian Parliament is currently
considering the Nuclear Safety Regulatory Bill 2011. Once the Bill is passed
AERB will be reorganized as the Nuclear Safety Regulatory Authority . The Bill
is presently under review by a Parliamentary Committee which may recommend
changes in the Bill after public consultation.
 
One
of the sub sections of the Bill on Powers and Functions of the Authority  reads thus:
 
“The
Authority shall  specify hours of work,
minimum leave and requirements for periodical  medical examinations of such employees”. This clause is
almost a verbatim reproduction of a clause existing in the Atomic Energy Act 1962.
 
Some
of us felt that the provision makes radiation work as something special. In
fact , radiation workers employed by the State Governments enjoy such
conditions as compulsory leave , radiation allowance etc. Radiation workers in
the Central Government are not extended any such benefits because it has taken
a principled stand against such incentives which have no scientific basis.
 
We
believe that the proposed provision is not consistent with  the IAEA document titled “Radiation
Protection and Safety of Radiation Sources: International Basic Safety
Standards General Safety Requirements”,  GSR part 3 Interim Edition 2011:”
 
“Requirement
27 Conditions of service
 
3.111.
The conditions of service of workers shall be independent of whether they are
or could be subject to occupational exposure. Special compensatory
arrangements, or preferential consideration with respect to salary, special
insurance coverage, working hours, length of vacation, additional holidays or
retirement benefits, shall neither be granted nor be used as substitutes for
measures for protection and safety in accordance with the requirements of these
Standards”.
 
We
believe that giving any special status to radiation work is not based on any
scientific principle . I shall greatly appreciate receiving the views of the
list members on this issue.
 
The
presently existing Atomic Energy Act 1962 and the text of the Nuclear Safety Regulatory
Authority Bill, 2011 can be accessed  in
the following addresses

1. http://www.dae.gov.in/rules/aeact.pdf

2. http://www.prsindia.org/uploads/media/Nuclear%20Safety/Nuclear%20Safety%20Regulatory%20Authority%20Bill%202011.pdf



With best regards
K S Parthasarathy
Former Secretary, Atomic Energy Regulatory Board


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