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Direct Request (CEACR) - adopted 2000, published 89th ILC session (2001)

Radiation Protection Convention, 1960 (No. 115) - France (Ratification: 1971)

Other comments on C115

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The Committee notes that the Government’s report contains no reply to previous comments. It hopes that the next report will include full information on the matters raised in its previous direct request, which read as follows:

Referring also to its observation under the Convention, the Committee requests the Government to supply supplementary information on the following points.

1.  Article 8 of the Convention.  The Committee notes the Government’s indication that there is no distinction between the exposure limits applicable to workers directly engaged in radiation work, on the one hand, and those who are not, on the other. The Government also indicates that the radiation protection arrangements are identical for all workers whether they are employed by enterprises working directly with radiation or by external enterprises, as the regulatory provisions rely on the existence of the hazard (presence of a source of radiation) and its intensity (work in controlled zones or supervised zones). Under Article 8 of the Convention, appropriate levels must be fixed for workers who are not directly engaged in radiation work, but who remain or pass where they may be exposed to ionizing radiation or radioactive substances. In this connection, the Committee is bound to draw the Government’s attention once again to paragraph 14 of its 1992 general observation. It recalls that the dose limits for such workers must be the same as those applied to individual members of the public, namely, according to the 1990 ICRP Recommendations, 1 mSv a year averaged over five consecutive years. It requests the Government to indicate the measures taken or contemplated so that workers who are not directly engaged in radiation work, but who remain or pass where they may be exposed to ionizing radiation or radioactive substances, are not exposed to doses higher than those applied for the public.

2.  Provision of alternative employment.  The Committee notes with interest the information supplied by the Government to the effect that a draft reform designed to enhance protection for workers who have been subjected to cumulative exposure is being prepared. The Government indicates that this draft should make it possible for workers on short-term contracts to avoid an accumulation of problems linked with their temporary employment and those resulting from exposure close to annual limits. The Committee requests the Government to supply information on the measures contemplated with regard to the provision of alternative employment to workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur.

3.  In regard to the provisions designed to ensure the provision of data regarding exposure of workers on which the French Democratic Confederation of Labour (CFDT) commented, the Committee notes the information supplied by the Government to the effect that the draft reform mentioned above is intended to clarify the arrangements for transmitting such information to workers themselves and to the Occupational Safety and Health and Conditions of Work Committee. It requests the Government to continue to supply information on measures taken in this respect.

4.  Protection against accidents and during emergency situations.  The Committee notes the information supplied by the Government on measures relating to emergency situations. It requests the Government to supply further information on the circumstances in which exceptional exposure of workers may be authorized as well as on the measures intended to optimize the protection against accidents and during emergency operations, particularly in regard to the design and protective features of the workplace and equipment and the development of techniques which, during emergency interventions, would avoid exposure of persons to ionizing radiation.

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