POL-G-032, Version 0.m, 9 August 2013
Radiation safety policy
The National Museum of Australia (the Museum) is a major cultural institution charged with researching, collecting, preserving and exhibiting historical material of the Australian nation. The Museum focuses on the three interrelated areas of Aboriginal and Torres Strait Islander history and culture, Australia’s history and society since European settlement in 1788 and the interaction of people with the environment.
Established in 1980, the Museum is a publicly funded institution governed as a statutory authority in the Commonwealth Arts portfolio. The Museum’s building on Acton Peninsula, Canberra opened in March 2001.
This policy covers the safe management of radiation hazards found within the Museum’s collections as well as radiation hazards existing in non-collection assets, such as analytical equipment.
The Museum holds controlled collection material containing ionising radiation (for example, radium paint on luminescent dials). The Museum also uses controlled analytical equipment involving ionising radiation (for example, x-ray fluorescence), and analytical equipment involving non-ionising radiation (for example, UV lamps).
The National Museum of Australia Radiation safety policy has been developed to:
- promote sound practice in dealing with radiation; and
- ensure that any activities undertaken at the Museum that involve the use of radiation are conducted in a manner which protects people and the environment from the harmful effects of both ionising and non-ionising radiation.
This policy is to be read and acted upon in compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 and Regulations.
This policy also works in conjunction with the National Museum of Australia Radiation safety procedures and covers:
a) controlled source collection material
b) controlled apparatus analytical instruments using ionising and non-ionising radiation.
This policy and the related National Museum of Australia Radiation safety procedures cover, but are not limited to:
- collection management
- access and security procedures relating to the management of radioactive items
- analysis of collection items and storage materials employing non-ionising and ionising radiation.
It is a fundamental requirement of the Museum that its activities involving ionising and non-ionising radiations be undertaken without undue risk to the health and safety of people and the environment, and be in compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 and Regulations and other relevant legislation and community standards (see Section 8).
4. Principles or guidelines
Museum activities involving radiation follow the three general principles below, as required by legislation:
No radiological practice should be adopted unless it is assessed to produce a net benefit to society.
ii. Optimisation of protection
In relation to a particular radiation source, the magnitude of the individual exposure and the number of people exposed should be kept as low as reasonably practicable.
iii. Exposure standards and dose limits
Any exposure to radiation must comply with exposure guidelines set by the Australian Radiation Protection and Nuclear Safety Act 1998.
The Museum will maximise compliance with the Act and Regulations and any special licence conditions by:
a) adherence to statutory regulations through implementation of the Museum’s policies and procedures
b) ensuring that no hazardous research or operational work is undertaken with radiation unless a risk assessment of the work is completed and the Manager of Conservation is satisfied that the hazards associated with the work are controlled as far as is reasonably practicable
c) provision of an adequate financial budget for compliance with legislation and agreed procedures
d) provision of sound workplace planning, design and operation (the Museum’s generic requirements are given by AS2243.4-1998 Safety in Laboratories – Ionising Radiations)
e) provision of administrative resources for advice and support
f) consultation with staff, the Work Health and Safety Committee and Work Health and Safety representatives in the workplace
g) clear statement and delegation of Work Health and Safety responsibilities to all levels of staff
h) provision of information, instruction, training and supervision for staff, researchers, interns and visitors working with radiation, as applicable
i) provision of procedures and protective equipment for the safe use of ionising radiations (XRF), and non-ionising radiations (ultra-violet)
j) provision of an incident and hazards notification system, including follow-up to prevent a repeat of a dangerous occurrence
k) clear direction for supervisors and managers in case of procedural non-compliance by staff
l) provision and regular monitoring of Work Health and Safety performance indicators, and regular reviews of policy in line with mandatory reporting
m) provision of rehabilitation and counselling where necessary
n) provision of a positive and consistent example of work health and safety at all levels of administration and supervision.
5. Definition of terms
Australian Radiation Protection and Nuclear Safety Agency
Source of either ionising or non-ionising radiation – within the Museum usually associated with a collection object requiring licencing with ARPANSA
Analytical apparatus or equipment utilising either ionising or non-ionising radiation requiring licencing with ARPANSA
Director, National Museum of Australia
Assistant Director, Collections, Content and Exhibitions, National Museum of Australia
National Museum of Australia’s collection management system
Work Health and Safety Representative as defined in the Museum Health and Safety Management Agreement and the Work Health and Safety Act 2011
The consultative work health and safety forum as defined in the Museum Health and safety management arrangements and the Work Health and Safety Act 2011
Australian Radiation Protection and Nuclear Safety Regulations 1999
Radiation Safety Officer
Radiation Awareness Safety Officer
Workers who deal with controlled sources or ionising and non-ionising radiation apparatus have been approved to be a ‘radiation worker’ allowing them to be exposed to higher annual dose limits of radiation than are allowed for members of the public
6. Definition of responsibilities
Specific duties and responsibilities of these positions are outlined in Appendix 1.
The Director of the Museum applies for and holds the Source Licence issued by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) as required under section 33 of the Australian Radiation Protection and Nuclear Safety Act 1998. The Licence Holder is responsible for ensuring compliance with ARPANSA regulations.
If the applicant is sufficiently removed from the source dealing that they cannot demonstrate effective control, the name and contact details of a person more directly in control of the source dealing (the nominee) must be provided to ARPANSA.
Assistant Director, Collections, Content and Exhibitions
The Museum’s Licence Nominee is the Assistant Director, Collections, Content and Exhibitions. Once delegated by the Director, the Licence Nominee is responsible for ensuring compliance with ARPANSA regulations.
Radiation Safety Officer Manager (RSO Manager)
Has the effective control of the dealings in controlled sources and apparatus. This position is appointed by the ARPANSA License Holder or License Nominee and is responsible for managing and reporting on the Museum’s compliance with the Act, the Regulations, the special licence conditions under which the Museum holds its ARPANSA licence and the Museum’s Radiation materials policy and procedures. At the National Museum of Australia this is the incumbent in the position of Manager Conservation.
The RSO Manager ensures a complete and current register of all controlled sources and apparatus is kept. The RSO Manager, working with the Museum WHS committee and staff, advises Museum Executive on how to provide a workplace that is, as far as reasonably practicable, safe and healthy for staff, researchers, interns and visitors; and without risk to the environment.
Is responsible for the documentation, storage, movement and tracking of the Museum’s collection items. Controlled source collection items are managed in a manner consistent with the day-to-day duties of the NMA’s Registrar, but with consideration of the radiation policy and procedures.
Is responsible for managing the security of Museum property, including controlled source collection items and controlled ionising and non-ionising apparatus for use in analysis. These controlled collection items and controlled apparatus are managed in a manner consistent with the day-to-day duties of the Museum Security officers and contractors, but with consideration of the radiation policy and procedures.
Radiation Safety Officer/s (appointed as appropriate)
Radiation Safety Officer (RSO)
Provides advice on the management of radiation sources and assists in fulfilling the obligations under the Australian Radiation Protection and Nuclear Safety Act 1998. This includes monitoring, reviewing and reporting on all activities involving radiation, including radiation safety training, the use of dosimeters, assessment of risks and hazards associated with radiation safety, radioactive waste management and Work Health and Safety incidents. The Radiation Safety Officer is appointed by the Radiation Safety Officer Manager.
Radiation Awareness Safety Officer/s (appointed as appropriate)
Radiation Awareness Safety Officer (RASO)
Assist the Radiation Safety Officer with the provision of advice and information to staff. They are appointed by the Radiation Safety Officer Manager as required.
Business unit managers and supervisors of Radiation Workers
All Museum supervisors of Radiation Workers are responsible for ensuring their staff receive appropriate training in radiation safety; a safe and healthy workplace in which documented safe work procedures (SWPs) are provided to staff they supervise; that staff understand and are aware of the need to implement these SWPs; and that any radiation incidents, exposures, hazards or concerns within their jurisdiction are reported as soon as practical and within 24 hours to the Radiation Safety Officer (see section 7 Reporting).
Radiation Workers (appointed as appropriate)
Museum staff members, researchers, interns, volunteers or contractors who work with radiation must be trained to an appropriate level as radiation workers. They are required to do all that is reasonably practicable to ensure that their actions or omissions do not create or increase the risk to the health and safety of themselves or others. Safe work practices must be observed and implemented at all times, and equipment must be used in accordance with safe work procedures and manufacturer’s instructions. As part of their work radiation workers are required to support any work health and safety risk management procedures regarding radiation exposure that are put in place by the Museum.
All workers, including staff, contractors, students and volunteers are required to support any work health and safety risk management procedures regarding radiation exposure that are put in place by the Museum.
7. Reporting an incident
The Museum must take all reasonably practicable steps to prevent an accident involving controlled materials or controlled apparatus (Regulation 46). If an accident does occur, the Museum must take all reasonably practicable steps to control the accident and to minimise the consequences, including injury to any person and impact on the environment.
Any radiation incidents, exposures, hazards or concerns within the workplace must be reported as soon as practical and within 24 hours to the RSO. Where required by the Regulations the RSO will further report these events to the Museum licence holder and ARPANSA.
If considered a ‘Notifiable Incident’ under WHS Act 2011 then Comcare must be notified in accordance with Part 3 Section 38, Incident Notification – of the Work and Safety Act 2011.
Australian Radiation Protection and Nuclear Safety Act 1988 and Regulations
Australian Standard AS 2243.4-1998 Safety in Laboratories Part 4: Ionising Radiations
- Recommendations for Limiting Exposure to Ionizing Radiation (1995) and National Standard for Limiting Occupational Exposure to Ionizing Radiation (republished 2002)
- Code of Practice for the Safe Transport of Radioactive Material (2008)
- Radiation Protection Standard for Occupational Exposure to Ultraviolet Radiation (2006)
The National Museum of Australia Radiation safety procedures guide the implementation of this policy.
This policy covers radiation sources contained within the Museum’s collections and within non-collection assets, such as analytical equipment used by the Conservation Section that are considered to be controlled sources by ARPANSA.
9.2 Other related policies
Asset management policy POL-C-002
Environmental management policy POL-G-021
Risk management policy POL-C-019
Security policy POL-C-009
Health and Safety Management Arrangements
This policy does not cover radiation emitted from collection material or apparatus not considered by ARPANSA to be controlled sources or apparatus, such as:
a) radiation emitted by welding
b) electromagnetic radiation with wavelengths longer than ultraviolet.
9.4 Superseded policies
This is a new policy.
The policy will be reviewed annually by the RSO in accordance with the regulations.
The next review is scheduled for July 2014.
All supervisors and staff must comply with the duty of care set out in the Museum’s Health and Safety Management Arrangements.
Duties of the Licence holder or Licence Nominee
The licence holder must ensure compliance with ARPANSA regulations in particular Regulations 44 to 53:
- Regulation 44 – The prevention of breaches of licence conditions
- Regulation 45 – Investigate and rectify breaches of licence conditions and inform ARPANSA CEO as soon as practical
- Regulation 46 – The prevention, control and minimisation of accidents and inform APRANSA CEO within 24 hours
- Regulation 48 – Compliance with recommendations and codes of practice
- Regulation 49 – Compliance with plans for managing safety
- Regulation 50 – Review and update plans and arrangements annually
- Regulation 51 – Apply to ARPANSA CEO approval for relevant changes to licence that have significant safety implications
- Regulation 52 – Inform ARPANSA CEO about other changes
- Regulation 53 – Inform ARPANSA CEO about movement of controlled apparatus, controlled materials and controlled facilities.
Duties of the RSO Manager – Manager Conservation
- Ensure radiation operations are in compliance with the Act, the Regulations, the licence conditions under which the Museum holds ARPANSA Licence Number S0077, and the Museum’s Radiation Materials Policy and Procedures.
- Ensure compliance with all reporting requirements under Regulations 45, 46, 50, 52 and 53 for annual and incident reporting.
- Ensure compliance with all internal reporting requirements under the Director’s instruction, legislation and regulations including, National Museum of Australia Radiation policy and procedures and National Museum of Australia Health and Safety Management Arrangements.
- Ensure proper liaison between the National Museum of Australia Licence Holder or Licence Nominee and the National Museum of Australia WHS Committee, the RSO and National Museum of Australia staff with regard to radiation safety related matters, and any alterations to the Radiation Inventory affecting licences and registrations.
- Ensure workers (including supervisors of staff, contractors, researchers, and volunteers) are fully aware of the need to comply with the Museum’s Radiation Safe Work Procedures and the consequences of not complying.
- Ensure that all policies and procedures governing the safe use, care, handling and security of controlled sources and apparatus within the Museum are reviewed and up-dated annually.
- Ensure that current copies of all policies and procedures relevant to the safe use, care, handling and security of controlled sources and apparatus are distributed to the Museum’s radiation workers and their supervisors annually.
- Ensure a complete and current register is kept of all controlled sources and apparatus including, where relevant, the accession number, location, title, and activity level in millisieverts (mSv) and Becquerel (Bq) of each collection item.
Duties of the Radiation Safety Officer (RSO)
A Radiation Safety Officer (RSO) is appointed to provide advice on the management and assist in fulfilling the Museum’s obligations under the Australian Radiation Protection and Nuclear Safety Act 1998. In particular:
- review regularly the work place and radioactive material collection management activities for safety, and purchase appropriate safety equipment
- in liaison with National Museum of Australia Security staff, review regularly security related management and activities related to ionising and non-ionising radiation sources and apparatus
- in collaboration with National Museum of Australia Registration section, oversee the recording of all movements of radioactive sources and maintain records for at least 2 years in line with Section 6.7.1 of AS2243.4-1998
- oversee the measurement and recording of the radiation levels of collection items on the collection management system, including the annual calibration of radiation monitors
- provide appropriate training and instruction to workers in the use of personal dosimeters
- maintain an official file of dosimeter records and retain copies of personal dose logs in accordance with legislation
- advise staff through training and provision of SWPs of the need to comply with current Museum standard dose limits for radiation workers for an annual whole body effective dose of 1mSv per year during normal operations
- monitor dosimeter results to ensure staff do not exceed standard dose limits
- oversee contamination clean-up and arrange for the disposal of radioactive waste in accordance with advice from ARPANSA
- prepare and submit an annual report to the RSO Manager – Conservation Manager and the National Museum of Australia WHS committee regarding:
a) alterations to the Radiation Source Inventory Workbook affecting licences and registrations
i. object accession number or name of apparatus
ii. description of source and source location
iii. description of object/apparatus appearance
iv. the dose-rate and activity level of the radioactive material
b) training and safety procedures implemented
c) radiation incidents and emergencies
- report to the RSO Manager and the WHS Committee any deficiencies in agreed safe systems of work
- ensure immediate action is taken in the event of unsafe practices, accidents or emergencies including notification of Comcare as soon as practicable by the line manager if a ‘Notifiable Incident’ occurs, and, in compliance with ARPANSA regulation 46, inform the RSO Manager, the Museum Director and the ARPANSA CEO within 24 hours of the occurrence and provide a written report to the ARPANSA CEO within 14 days
- investigate accidents in consultation with Safety and Risk Manager and provide a written report to the RSO Manager, Museum Director and ARPANSA with 14 days of the happening
- review safety and security plans as follow-up to any incident or emergency to prevent reoccurrence of a dangerous incident
- provide reports to the RSO Manager in compliance with Licence condition 2 for annual reporting.
Additional Radiation Awareness Safety Officers (RASO) are appointed to assist the RSO with the provision of advice and information to staff as required by the RSO.
Duties of business unit managers and supervisors of Radiation Workers
Business Unit Managers and Supervisors of Radiation Workers must:
- attend appropriate radiation safety training course(s) and oversee implementation of the SWPs for collection management activities for radioactive material and use of ionising and non-ionising apparatus
- ensure that radiation workers receive training in safe working practices and emergency procedures in compliance with the relevant SWPs
- oversee the adequate resourcing and implementation of safe working procedures in accordance with agreed SWPs
- supervise radiation workers in their daily work
- assist with the implementation of emergency procedures as necessary
- ensure that copies of the personal logs of radiation exposure of all supervisees are sent to the RSO on a quarterly basis
- be aware of, and consistently apply any disciplinary measures relating to non-compliance of agreed procedures.
Duties of Radiation Workers
All workers are required to support any work health and safety risk management procedures regarding radiation exposure that are put in place by the Museum. Museum staff members, researchers, interns, volunteers or contractors who work with radiation must be trained to an appropriate level as Radiation Workers.
Radiation Workers must:
- attend relevant radiation training course(s) as required in the course of their work
- read, follow and sign off on the appropriate National Museum of Australia Radiation SWPs in the course of their work
- discuss the procedures and available risk controls with their supervisor
- ensure that controls are in place before commencing work, i.e. use protective equipment appropriately
- advise their supervisor and the RSO as soon as possible in the event of any accident, spillage or potential hazard (e.g. broken cover glass in an object containing radiation) and, if this is a ‘Notifiable Incident’, line managers are to contact Comcare as soon as practicable
- wear a personal dosimeter whenever working with or in the vicinity of radioactive material, ensuring that their exposure is kept to a minimum
- keep a record of their own exposure times, and send a copy of their personal log to the RSO on a quarterly basis
- advise other workers of risks by leaving signs or clearing away work in accordance with the Museum’s Radiation Safety Procedures
- use the monitoring equipment in accordance with the relevant Radiation Safety Procedures to measure the radioactivity of suspect items and if contamination of a work space is suspected
- update collection management documentation on the collection management system as required and detailed in the Museum’s Radiation Safety Procedures
- know what to do in case of an accident in accordance with the Museum’s Radiation Safety Procedures.
 If particular radiation-related work is required, exposure limits may be raised to 5mSv per year which is still one quarter the Standards Australia dose limits for radiation workers (annual whole body effective dose of no more than 20 mSv per year based upon work attendance of 50 weeks per year and 40 hours per week). This work would need to be approved by Senior Management and would be subject to a strict control and monitoring system.
9 August 2013
Executive approval date
22 August 2013
Public and all staff
Health, Safety and environment, Work health and safety
Director, National Museum of Australia
or the National Museum of Australia ARPANSA Licence Nominee - Assistant Director, Collections, Content and Exhibitions
Asset management policy POL-C-002
Environmental management policy POL-G-021
Risk management policy POL-C-019
Security policy POL-C-009
Health and safety management arrangements (HSMA)
Procedures and guidelines
Radiation safety procedures
Risk management manual (August 2011)
WHS Procedures and Guidelines
Collections emergency response and recovery plan
Environmental Management System procedures manual (November 2008)
Incident/Hazard Report Form (August 2011)
Hazard, risk and control report
National Museum of Australia
Tel: (02) 6208 5000
Reapproved by Executive 22 August 2013