Inspection

INSPECTIONS AND ENFORCEMENT

Introduction
 Atomic Energy Council (AEC) is a government Agency established under section 4 of the Atomic Energy Act. No. 24 of 2008 with the mandate of protecting people and the environment from dangers resulting from the peaceful applications of ionizing radiation, In Uganda ionizing radiation is used in the fields of medical, industrial, Agricultural, security and in Education and Research for various purposes.

MANADATE TO CONDUCT INSPECTIONS
Section 9(1)(d) of the Atomic Energy Act No.24 of 2008, empowers AEC to conduct inspections to assess radiation safety and security conditions and compliance with the Act and the regulations and other requirements specified in an authorization.

PRACTICES INSPECTED BY AEC

A. Medical Practices
Diagnostic Radiology (e.g. plain X-ray Machines, Mammography machines, Dental X-ray machines among others),
Interventional Radiology (e.g. Fluoroscopy Units, Computed Tomography (CT)), Radiotherapy, Nuclear Medicine, etc.

B. Industrial Practices
✔ Nuclear gauging (Level, Moisture, Density),
✔ Well logging, Industrial X-ray Scanners,
✔ Industrial Radiography,
✔ Industrial Computed Tomography,
✔ Baggage Scanners, etc.

C. Security (for screening baggage or cargo)
✔ Baggage X-ray machines,
✔ Cargo Scanners

REASONS FOR CONDUCTING INSPECTIONS

To ensure that:
i. Facility design and layout, equipment and work performance meet all necessary requirements,
ii. Relevant documents and instructions are valid and are being followed,
iii. Persons employed by the operator (including contractors) possess the necessary competence for the effective performance of their functions,
iv. Deficiencies and deviations are identified and are corrected or justified without undue delay,
v. The operator is managing safety and security in a proper manner
vi. Any lessons learned are identified and propagated to other operators and suppliers
vii. The authorized person is managing safety and security of sources in a proper manner

INSPECTIONS CONDUCTED

AEC has conducted inspections in 426 facilities out of the current 454 registered facilities giving a percentage of 93.8%.

TYPES OF INSPECTIONS CONDUCTED BY AEC
i. initial or pre-operational inspections (pre-authorization inspection) carried out prior to a practice commencing work with radiation;
ii. planned inspections (Routine) of existing authorizations usually at specified frequencies;
iii. Reactive inspections normally carried out with the purpose of making investigations when the regulatory body so deems necessary; and
iv. Final inspections; inspections carried out following cessation of the radiation practice or if an authorization is otherwise cancelled.

FREQUENCY OF INSPECTIONS

The frequency depends on the risk associated with the practice. Practices are generally put into three categories by risk i.e. High risk, medium risk and low risk
i. High risk practices such as teletherapy, irradiators, CT, fluoroscopy-Twice a year
ii. Medium risk such as use of plain and dental X-ray machines, nuclear gauges-once in two to three years
iii. Low risk such as bone densitometer, after 4-5 years and above

KEY ISSUES THAT ARE CONSIDERED DURING INSPECTION TO ENHANCE PROTECTION OF THE WORKERS, PATIENTS, THE PUBLIC AND THE ENVIRONMENT

Public Protection
i. Shielding of the premises
ii. Availability of control measures both administrative and physical to rooms housing sources
iii. Availability of radiation warning systems such as notices, symbols and lights
iv. Location of the rooms storing sources of radiation
v. Policy on pregnant workers

Worker protection
i. Availability of shielded cubicles
ii. Availability of work procedures and their implementation
iii. Availability of personal protective equipment
iv. Availability of radiation survey and monitoring devices
v. Existence of communication channels within the facility

Patient protection (medical)
i. Performance of the medical equipment-performance parameters
ii. Availability and use of personal protective equipment
iii. Medical request forms
iv. Availability and implementation of Policy on pregnant patients
v. Availability of consent to treatment or diagnosis policy or forms

Environmental protection
i. Waste management measures/plans at the facility

Enforcements conducted by AEC
i. One of the functions of Council under section 9(1)(e) of the Act is to take such an action as is necessary to enforce the requirement of the Act and the regulations
ii. Also, Regulation 11 of the Atomic Energy Regulations, 2012, Council may take a number of enforcement action.

TYPES OF ENFORCEMENTS CARRIED OUT BY AEC
i) Verbal
ii) Written
iii) Seizure of the radiation source
iv) Suspension of the services being offered using the radiation source
v) Suspension of authorization
vi) Revocation of the authorization
vii) Legal redress

MAJOR CAUSES OF ENFORCEMENT
A graded approach is used depending on the severity of the violation to the health and safety of people, threat to nuclear security, and possible environmental contamination. However, the following are considered severe and will lead to an onsite enforcement;
i) Release of uncontrolled radiation to the environment
ii) Use of unqualified staff
iii) Inadequately shielded premises
iv) Use of faulty radiation generating equipment or device
v) Lack adequate personal protective equipment
vi) Lack of occupational exposure monitoring program
vii) Unsecured radiation source
viii) Lack of radiation warning systems

Challenges faced during inspections
i. Facilities denying access to inspectors to conduct inspections.
ii. Inspectors having to wait for so long to be attended to.
iii. Unjustified exposure from inadequately shielded premises.
iv. Poor communication from facilities regarding change of location, addressing inspection requirements and recommendations, among others.
v. Unavailability of key staff at the facility.

General Message to the Public

The general purpose is called upon to support all Council activities and accept guidelines for ensuring radiation safety from time to time. Radiation is invisible and therefore unjustified exposures should be avoided.

DOWNLOADS FOR INSPECTIONS