Interfaces with transport safety regulatory organizations

Many organizations have interfaces with radioactive material transport. These include all the United Nations regulatory bodies, as well as other international, governmental, industrial and public organizations. The interfaces between the IAEA and other regulatory bodies and agreements are summarized here, and described in more detail in Chapter 14.

Several of these bodies are specialized UN agencies that fall under the umbrella of the Economic and Social Council (ECOSOC). Internationally, the responsibilities tend to be split according to the nature of the hazardous material, and according to the transport mode.

Figure 1.4 provides a perspective of the worldwide transport of dangerous goods by all modes of transport. This figure also indicates how small the fraction of radioactive material shipments is in the overall picture.

D a n g e ro us G o o d s

FIG. 1.3. Worldwide perspective of the transport of dangerous goods.

1.5.4.1. United Nations Economic and Social Council Committee of Experts (ECOSOC) The development of recommendations on a broad international basis to assist national authorities in ensuring the safe transport of hazardous material by different modes of transport was initiated by the United Nations. Under the authority of the Economic and Social Council (ECOSOC), the Committee of Experts on the Transport of Dangerous Goods supervises the work.

The UN Committee of Experts issues Recommendations on the Safe Transport of Dangerous Goods. These Recommendations have been universally accepted as the basis for national and international regulations covering various modes of transport. The current

“Recommendations of the Committee of Experts”, commonly known in the transport world as the “Orange Book”, were developed from an original version approved by the ECOSOC in 1957.

As early as 1959, the ECOSOC adopted a resolution entrusting the IAEA with the task of establishing recommendations for the safe transport of radioactive material. Therefore, the

“Orange Book” and IAEA Safety Series No. 6 [6] have developed on a consistent basis, ensuring full compatibility between the treatment of radioactive material and other dangerous goods. On restructuring, the Orange Book will contain the body of the text of TS-R-1.

1.5.4.2. International Commission on Radiation Protection (ICRP)

Because of the vital importance of radioactivity and radiation in modern life and its potential impact on persons, property and the environment, the International Commission on

Radiation Protection (ICRP) has served as the global technical body in this field. It is tasked with the responsibility of ensuring that activities that utilize radiation or radioactive material are undertaken in a safe manner with respect to persons, property, and the environment. The ICRP issues periodic documents related to radiation protection, and the IAEA in turn considers and adopts the principles in these documents into its own safety-related publications.

Recent IAEA documents, which embody these actions, deal with radiation protection and safety of radiation sources [26] and basic safety standards for protection against ionizing radiation [12]. In turn, the principles set forth in these documents were considered in the development of TS-R-1, as is noted in paragraph 101 of TS-R-1.

1.5.4.3. International Maritime Organization (IMO)

Since its organization more than five decades ago, the International Maritime Organization (IMO)², which is a United Nations organization, has become recognized as the maritime community's forum for all matters affecting the safety of shipping. The transport of dangerous cargoes has been one of IMO’s responsibilities since it came into being. The regulations, standards and recommendations that it has developed, are recognized, followed, and observed by ships of many nations.

1.5.4.4. International Civil Aviation Organization (ICAO)

The International Civil Aviation Organization (ICAO) is also a United Nations organization. It deals with all aspects of international civil aviation. ICAO develops standards and recommends practices covering all areas of civil aviation and these are produced as annexes to the Convention on International Civil Aviation. A set of Technical Instructions has been published that set out in detail the requirements for carrying dangerous goods by air.

These Technical Instructions reflect the IAEA Regulations with regard to the carriage by air of radioactive material. A standard in the relevant annex requires States to ensure compliance with the Technical Instructions for all international air transport. There is also a recommendation for the Instructions to be used for domestic air transport.

1.5.4.5. International Air Transport Association (IATA)

IATA is a trade association representing airlines throughout the world. Its objectives are the promotion of safe, regular and economical air transport. In 1950, IATA set up a Restricted Articles Board (RAB) comprising experts acting on behalf of all member airlines to develop requirements for the transport of restricted articles by air. The requirements are now embodied in the Dangerous Goods Regulations, and these are generally consistent with the ICAO’s Technical Instructions.

It is noted that close co-ordination exists between IAEA, ICAO, and IATA. Changes have been made in the IAEA's Regulations regarding packages to be transported by air at the request of ICAO and IATA. Liaison continues to assure accurate and timely implementation of the IAEA’s Regulations.

1.5.4.6. Universal Postal Union (UPU)

The UPU was established in 1894 and is now a specialized agency of the United Nations, with its headquarters in Berne, Switzerland. The UPU Congress meets routinely to review and approve any changes to the Universal Postal Convention and the Detailed Regulations for Implementing the Convention.

Under the UPU Convention [27] and Detailed Regulations, a consignment of radioactive material in which the activity does not exceed one tenth of the activity limit allowed in an excepted package, may be accepted for international transport by post if certain requirements are met.

1.5.4.7. Regional agreements for modal transport

The transport of dangerous goods by rail, road, and inland waterway modes is not covered by an international organization on a worldwide basis. Rather, these are covered by several regional agreements such as:

- The Regulations Concerning the International Carriage of Dangerous Goods by Rail (RID);

- The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR);

- The European Agreement concerning the International Carriage of Dangerous Goods on Inland Waterways (ADN); and

- The Regulations for the Transport of Dangerous Goods on the Rhine (ADNR).

These organizations were established in Europe because of the large economic potential, which is concentrated on a confined area, and is distributed over many states. In addition, there is the MERCOSUR/MERCOSUL agreement that affects road, rail, air and sea transport among certain South American countries. The exchange of economic goods, including radioactive material and other dangerous goods, requires many transport operations, as well as sound regulatory control of these operations.

1.6. IAEA Regulations for the Safe Transport of Radioactive Material 1.6.1. History and development

Although radioactive material has been used for more than a century, significant use for beneficial purposes only began in the later 1940s and early 1950s. At that time, since the utilization of this material was increasing dramatically, it was recognized that safe and effective transport arrangements were required in order to properly protect man and the environment.

To assure safety during the transport, handling, and storage of radioactive material, it was recognized early on that a very strict set of standards would be required. The need for international acceptance was recognized as being vital since transport is usually the only aspect of any nuclear-related activity in which the radioactive material itself may directly cross international borders. Even for transport within one country, international carriers or packagings may be involved.

Prior to 1959, the various national and international controls for transport safety were largely based on the United States Interstate Commerce Commission regulations. These were essentially aimed at facilitating the movement of radioactive ores and concentrates, as well as packages containing relatively small amounts of radionuclides for medical and industrial use.

The rapid expansion of the nuclear industry required that these early regulations be further developed. Thus, one of the first activities undertaken by the IAEA after its formation was the development of methods for controlling and assuring safety during the transport of all kinds and quantities of radioactive material.

While it was expected that the basic principles underlying the Regulations would remain acceptable for a long period, it was also understood that feedback from experience, advances in technology, changes in the modal transport environments, and sociopolitical forces would result in improvements. This has proven true and five comprehensive revisions have subsequently been published: in 1964, 1967, 1973, 1985, and 1996.

The procedure used by the IAEA for the preparation of its Regulations is largely responsible for their extensive national and international application. Each stage of regulatory development involves the convening of panels. The panel members represent not only an extensive coverage of Member States and international transport organizations, but also personnel having experience in the various administrative and technical problems requiring solution. Based on proposals co-ordinated by the IAEA Secretariat, these panels prepare draft Regulations for comment by all Member States and all international organizations concerned.

Then, following panel consideration of such comments, final drafts are prepared for approval by the IAEA’s Board of Governors.

The process and its controls have changed in detail periodically over the years. In order to provide a structured approach, the Standing Advisory Group on the Safe Transport of Radioactive Material (SAGSTRAM) was established by the IAEA in 1978 to advise on the IAEA's transport programme and on the development and implementation of the Regulations.

Recommendations concerning procedures and a schedule for a further comprehensive review of the Regulations and other supportive documents were made at SAGSTRAM meetings. As mentioned earlier, TRANSSAC was formed in 1996 (and renamed to TRANSSC in 2000) replacing the function of SAGSTRAM. This advisory body ultimately endorses the text for a revision to the Regulations, and recommends submission of that text to the IAEA Board of Governors for approval. Following approval by the Board, the transport secretariat responds to comments made by the Board, and then publishes a new edition of the Regulations in the official languages of the IAEA

The main body of the Regulations is structured topically in terms of:

- Introduction;

- Definitions;

- General Provisions;

- Activity Limits and Material Restrictions;

- Requirements and Controls for Transport;

- Requirements for Radioactive Material and for Packagings and Packages;

- Test Procedures;

- Approval and Administrative Requirements.

As such, a user desiring to transport a specified type of radioactive material consignment must study and assimilate requirements from all sections of the Regulations pertaining to that specific type of material although much of the information and requirements may not apply.

In response to an expressed need, a set of schedules listing the requirements to be met for the transport of specific types of consignments was developed and appended to the 1973 and 1973 (As Amended) Editions of the Regulations. Those schedules were intended to serve only as a practical aid to users. In endorsing the 1985 Edition of the transport Regulations, SAGSTRAM recommended that these schedules be published as a separate Safety Series document. Consequently, the “Schedules of Requirements for the Transport of Specified Types of Radioactive Material Consignments” was published separately from the Regulations in 1986 as Safety Series No. 80 [31].

[8] includes schedules of requirements following the main body of the regulatory requirements. It is noted in the foreword to TS-R-1 that “the requirements to be met for the transport of specified types of consignments are included in an abbreviated form as Schedules in this publication.” The Preface to the Schedules in TS-R-1 emphasizes that they are included “as an aid to users of these Regulations,” and that they “reproduce some of the provisions of these Regulations.”³ Thus, the Schedules are not the complete and binding set of regulatory requirements, but can be used as a basic aid or “guide to national authorities and international organizations that may wish to adapt these Regulations [8] in schedule form.” It is essential to note that while the Schedules address requirements for transport in some detail, they simply refer to the package and testing requirements as described in the main body of the Regulations.

With time, as knowledge and experience has been gained, the details in the Regulations have become more defined, and more controls have been placed on the packaging and operational requirements. The focus has always been to ensure radiological and nuclear criticality safety while also striving to ensure that transport operations are feasible.

The need to continually work to keep the transport Regulations consistent with the radiation protection standards has caused changes to be made in almost every revision. For example, in the 1985 Edition, specific General Principles for Radiation Protection were added. Similarly, in the 1996 Edition, radionuclide-specific activity concentrations for exempt material, and activity limits for an exempt consignment were both added (replacing the simple definition of radioactive material that had existed previously). These changes were prompted by changes in basic radiation protection principles promulgated by the International Commission on Radiation Protection (ICRP), which then were implemented into the IAEA’s basic radiation protection standards such as those in Reference [12].