Protecting workers from the risks of ionizing radiation

A 2018 decree transposes the Radiation Protection Directive. It reduces the limit value for the crystalline lens, lowers the radon reference level and creates the function of radiation protection advisor.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
10.07.2018
Contents
Example H2
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In the workplace, workers may be exposed to ionizing radiation through the use of radiation-emitting equipment (X-ray quality control, etc.) or sealed (food irradiation, gamma radiography, etc.) or unsealed radioactive sources. Protecting workers against these risks is therefore essential.

A decree dated June 4, 2018 [1] amends the rules for preventing health and safety risks due to ionizing radiation. It thus transposes, in Articles R. 4451-1 to R. 4451-135 of the Labor Code, Directive 2013/59/Euratom on radiation protection [2].

As part of this transposition, other provisions were amended by other decrees: administrative regime for nuclear activities with the introduction of the registration regime, inventory of ionizing radiation sources, protection against malicious acts, radiological emergencies, etc. We will not deal with these subjects in this article.

Rules for the protection of workers against the risks of ionizing radiation

Preventive measures apply whenever workers are likely to be exposed to ionizing radiation of natural (uranium, radium, radon, etc.) or artificial (californium, americium, plutonium, etc.) origin.

In summary, the employer's main obligations in terms of worker protection are :

  • Application of general prevention principles: implementation of preventive measures to eliminate or minimize exposure risks
  • Assessment of risks arising from exposure of workers to ionizing radiation (with the help of the radiation protection advisor)
  • Measurement when risk assessment concludes that exposure is likely to reach or exceed certain thresholds
  • Recording of this assessment in the single document and transmission of the assessment and measurement results to the CSE
  • Identification of exposure zones (blue supervised zone, green/orange/red controlled zone, extremity zone, radon zone)
  • Signposting and restricting access to these areas
  • Identification of each source of ionizing radiation
  • General coordination of preventive measures in the event of intervention by an external company
  • Inspections of work equipment, ionizing radiation sources and workplaces. Initial checks are carried out by accredited organizations.
  • Communication of an annual report on these checks to the Works Council Individual assessment of certain workers, particularly those working in identified exposure zones
  • Classification of workers in category A or B, with the advice of the occupational physician, according to the dose likely to be received.
  • Appropriate information for workers and, for category A and B workers, training renewed every 3 years
  • Individual dosimetric monitoring of category A and B workers and those exposed to radon (effective dose likely to exceed 6mSv
  • Reinforced individual health monitoring for these workers
  • Annual presentation to the CSE of a statistical report on the monitoring of worker exposure and its evolution.
  • Setting up an organization to manage significant events and exceedance of exposure limit values (ELVs)
  • Authorization from labor inspectorate to exceed ELVs on an exceptional basis
  • Organization of radiological emergencies Designation of a radiation protection advisor (see below)

Main changes

Modification of the exposure limit value for the crystalline lens

According to IRSN, the crystalline lens of the eye is a radiosensitive tissue that can be affected by ionizing radiation, leading to the development of opacities that can lead to cataracts. The exposure limit for the crystalline lens is reduced to 20 mSv/year (instead of 150 mSv/year) from July 1, 2023. In the meantime, from July 1, 2018 to June 30, 2023, the cumulative value for the crystalline lens is set at 100 mSv, provided that the dose received during the year does not exceed 50 mSv.

Note: the Sievert (Sv) is the name of the unit of equivalent dose or effective dose, used to assess exposure to ionizing radiation.

Modification of the radon reference level

The reference level for radon activity concentration in air has been set at 300 Bq/m3 annual average (previously 400 Bq/m3). The risk assessment must determine whether this level is likely to be exceeded. If this threshold is exceeded despite the preventive measures put in place, the employer must communicate the results of the measurements to the Institut de Radioprotection et de Sûreté Nucléaire (IRSN).

Note: the reference level is defined as the activity concentration level above which, in a radon exposure situation or in a radiological emergency, it is deemed inappropriate to allow worker exposure to ionizing radiation.

Creation of the function of radiation protection advisor

Employers are now required to appoint a "radiation protection advisor" to advise them on radiation protection matters. Except for INBs (Installations Nucléaires de Base), there are two possible choices:

  • or, as at present, use the services of a Radiation Protection Competent Person (RCP); a natural person employed by the establishment and holding a recognized training certificate;
  • or appoint an external advisor, known as a "Radiation Protection Competent Body (RPCB)". This organization must be certified.

In addition to advising on worker protection issues, the role of the PCR and OCR has been extended to include public and environmental protection. Similarly, at the employer's request, they will be able to carry out certain internal technical inspections previously entrusted to ASN-approved technical inspection bodies (e.g.: periodic general inspections of installations and work equipment). The radiation protection advisor has access to all worker dosimetric data, including data covered by medical confidentiality.

Details of risk assessment and workplace measurements

Analysis of workstations, as part of risk assessment, was already provided for, but now the French Labor Code sets out the 15 criteria that employers must take into account when assessing the risks associated with ionizing radiation.

Measurement is mandatory if the risk assessment shows that exposure is likely to exceed one of these levels: 1 mSv/year for the body, 15 mSv/year for the crystalline lens, 50 mSv for the extremities of the skin, or 300 Bq/m3 as an annual average in the case of radon exposure.

The results of the risk assessment must be recorded in the single document. They must be kept for 10 years, and communicated to the occupational physician and the CSE in the same way as the results of measurements.

Changes to zoning rules

The principle of supervised and controlled zones is maintained, with new definitions of these zones based on effective dose: blue supervised zone, green controlled zone, orange controlled zone, red controlled zone, extremity zone, radon zone.

A new concept has been introduced: the extremity zone. This zone is to be defined when supervised and controlled zones are not sufficient to control extremity exposure and guarantee compliance with occupational exposure limit values.

Replacement of the individual exposure sheet by an individual assessment

The exposure sheet is replaced by a worker's individual exposure assessment, which must be carried out prior to assignment to the workstation. In addition to the nature of the work, the characteristics of the ionizing radiation to which the worker is likely to be exposed and the frequency of exposure, this assessment must contain:

  • the equivalent or effective dose that the worker is likely to receive over the next twelve consecutive months (taking into account potential exposures and foreseeable incidents);
  • the effective dose exclusively related to radon that the worker is likely to receive over the twelve consecutive months.

This assessment must be recorded by the employer and updated as necessary, and must be available for consultation for 10 years. It is accessible to the worker concerned.

Personal exposure monitoring and access to restricted areas

Workers classified as category A or B, as well as those exposed to radon (effective dose likely to exceed > 6 mSv), must benefit from appropriate individual dosimetric monitoring to ensure traceability of internal and external exposure.

Workers entering restricted zones must be monitored by appropriate means. Unclassified workers may therefore enter a regulated zone without dosimetric monitoring, with the exception of orange and red zones, provided that the employer uses appropriate means to ensure that their exposure remains below the dose values that would lead to classification in category B.

Worker protection: enhanced individual health monitoring for radon-exposed workers

Reinforced individual monitoring of workers' state of health is extended to workers whose effective dose is likely to exceed 6 mSv forradon exposure.

Retention period for occupational health medical records

The occupational health medical file of each worker under reinforced individual monitoring must now be kept until the worker has or would have reached the age of 75, and in any case for a period of at least 50 years from the end of the professional activity involving exposure to ionizing radiation.

Entry into force

These provisions come into force on July 1, 2018, with the exception of the dose limit for the crystalline lens, which comes into force on July 1, 2023. However, the following transitional provisions apply:

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[1] Decree No. 2018-437 of June 4, 2018 on the protection of workers against the risks due to ionizing radiation [JORF of June 5, 2018].

[2] Council Directive 2013/59/Euratom of December 5, 2013 laying down basic safety standards for health protection against the dangers arising from exposure to ionizing radiation [JORF of January 17, 2014].

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