CONTROL OF RADIATION PROTECTION PRACTICES
PAKISTAN NUCLEAR REGULATORY AUTHORITY
IAEA/RCA MID-TERM REVIEW MEETING
IAEA MODEL PROJECT RAS/9/026, RAS/9/027
Beijing, 7-11 June 2004
1. LEGISLATIVE AND REGULATORY INFRASTRUCTURE
1.1 Legislative and Regulatory Frame Work
In Pakistan the regulatory body has gone through a gradual process towards
independence from the owner of the nuclear installations it regulates. The activities related to
the promotion of peaceful uses of nuclear energy started in Pakistan as early as in 1955. In
1965, Pakistan Atomic Energy Ordinance was promulgated under which the Pakistan Atomic
Energy Commission (PAEC) became a statutory body. According to this ordinance, all
nuclear installations were owned and operated by the Federal Government through PAEC.
In 1984, the Directorate of Nuclear Safety and Radiation Protection (DNSRP) were
established as the Regulatory Authority. This was however part of the PAEC. In 1990, the
Pakistan Nuclear Safety and Radiation Protection (PNSRP) Regulations were promulgated.
The regulations were applicable to all establishments which dealt with radioactive materials.
These regulations allowed Director DNSRP to exercise powers of the PAEC viz., to specify
procedures of registration and licensing and define the license fee structure.
The Government of Pakistan (GOP) had signed the Convention on Nuclear Safety in
1994. According to Article 8 of this Convention, each Contracting Party is required to
establish an effective separation of regulatory functions from the promotional aspects of the
nuclear energy. A complete independence from the management of the operating
organization and utilities was essential for adequately exercising the control over the
licensees. As a first step towards this goal, the Government of Pakistan created the Pakistan
Nuclear Regulatory Board (PNRB) in 1994. The PNRB was semi-independent, from the
Commission, as four of its seven members had no link with the PAEC. The executive arm of
PNRB was DNSRP.
January 2001, the Federal Government promulgated the Pakistan Nuclear
Regulatory Authority Ordinance, through which the Pakistan Nuclear Regulatory Authority
(PNRA) was established as an independent entity to implement nuclear and radiation safety
regulations in the country and to control and supervise all matters pertaining to the safety of
The New Ordinance
The Pakistan Nuclear Regulatory Authority (PNRA) Ordinance has replaced the
PNSRP regulations of 1990 to provide more intrusive and effective regulation of nuclear
energy. The Ordinance separates the two functions of regulating and utilizing nuclear energy
in Pakistan and provides a distinct and legal identity to the regulatory authority. It also
provides the PNRA with a mandate to establish and enforce national regulatory standards.
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The organizational setup of the PNRA is at an advanced developmental stage. The
target is to establish a regulatory body that has sufficient staff, independent funding and legal
powers for controlling, regulating and supervising all matters related to nuclear safety and
radiation protection measures in Pakistan. The Authority is responsible for all the nuclear and
radiation safety measures in Pakistan.
To achieve these objectives, the Authority, has been given the power to:
• Make and enforce such rules, regulations orders or codes of practice for nuclear
safety and radiation protection as may, in its opinion be necessary.
• Plan, develop and execute comprehensive policies and programs for the protection
of life, health and property against the risk of ionizing radiation.
1.2 Radiation, Transport, Waste Safety and Emergency Regulations
The following regulations have been drafted in the light of IAEA’s Basic Safety
Standards (BSS-115), transport regulation TS-R-1 (ST-1 Revised), and TECDOC–1067
“Organization and implementation of a national regulatory infrastructure governing
protection against ionizing radiation and the safety of radiation sources.”
• Regulations for radiation protection-PAK/904. These regulations have already
been submitted for the final approval of Regulatory Authority.
• Regulations for licensing of radiation facilities other than nuclear installations-
PAK/908. These regulations have already been submitted for the final approval of
• Regulations for the safe transport of radioactive material-PAK/916. These
regulations have been submitted for further review and comments by PNRA
Directorates and the licensees.
• Regulations for waste management-PAK/915.These regulations have been
submitted for further review and comments by PNRA Directorates and licensees /
1.3 The Regulatory Authority Organization, staffing and funding
The Regulatory Authority and is headed by a Chairman who is also the Chief
Operating Officer. He is assisted by two full-time members, and seven part-time members
appointment by the federal government. The seven part-time members consist of three
technical members, three nominated members – one each from Ministry of Health, the
Pakistan Environmental Protection Agency, and the Pakistan Atomic Energy Commission –
and Director-General, Strategic Plans Division.
The Authority functions as regulatory and decision making body. The Authority
makes licensee decisions for both nuclear and radiation facilities, and sets policies directions
on safety and environmental issues that concern nuclear industry and the public. The
Authority usually meets three to four times a year to deal with matter of policies making.
PNRA currently has approximately one hundred (100) employees including:
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• Scientists, Engineers, Health/Medical Physicists
• Administration and Financial Officers
• Supporting staff
• Maintenance services personnel
PNRA also obtains services from external sources where it requires special expertise,
mainly through advisors and consultants, placed in the private sector and with other agencies
and regulatory organizations. The headquarters of the PNRA are located in Islamabad. There
are three Regional Directorates; one directorate is located in Chashma, to deal with matters
related to CHASHNUPP, one at Karachi to deal with matters related to KANUPP, and the
third is located in Islamabad/Rawalpindi. These Regional Directorates are responsible for the
implementation and enforcement of the safety regulations in their area of jurisdiction.
The funding for the execution of the responsibilities assigned to the Authority comes
from the allocated budget provided by the Government. The funding may be partially
supplemented through generated income from licensing and other advisory fees. The
Authority has adequate financial and other resources to meet its current requirement for staff,
staff training, buildings, facilities, equipment, use of consultants, etc to discharge its
responsibilities and maintain its independence. Purchase of large and expensive equipment
(such as cross border traffic scanners, etc.) would require supplementary funding.
1.4 Coordination and cooperation at the national / international levels
PNRA maintains a close liaison with all national organizations which are directly or
indirectly involved in the execution of its responsibilities. Pakistan is also a signatory to
international conventions on nuclear and radiation safety. It also participates in all IAEA
Regional and Interregional activities related to the enhancement of radiation protection
infrastructure in the country.
2 ACTIVITIES OF THE REGULATORY AUTHORITY
2.1 Notifications and authorization system
Pursuant to PNRA ordinance 2001, issuance of authorizations to a person (as defined
in the ordinance) to perform specified activities is one of the main functions of PNRA. These
authorizations are issued on the basis of review and assessment of licensee’s submissions.
Depending upon the potential magnitude and nature of the hazards associated with
nuclear/radiation installations, authorizations are required at various stages. PNRA
Regulations PAK/904 “Regulations For Radiation Protection” establishes these requirements
for authorizations and notifications procedures.
2.2 Inventory of sources
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A computerized inventory of radioactive sources in the country is being maintained in
the PNRA since 1990. The software is being upgraded to allow for better tracking and
Regional Directorates carry out physical verification inspections periodically and also
carry out assessment of safety and security measures.
Sources are physically verified by PNRA inspectors according to a checklist
developed in the light of IAEA TECDOC-1113 and -1367. Efforts are made to keep a
continuous track on the sources from their entry into the country till their return (export) or
disposal in one of the dedicated repositories.
PNRA is planning to further strengthen its inspection and review system for
specifying sources to ensure that all such sources remain under regulatory control.
2.3 Enforcement, inspection at review (compliance monitoring)
Under PNRA ordinance 2001, the regulatory authority is empowered to undertake
enforcement actions relating to the findings of its regulatory inspectors and their review and
assessment. To achieve this purpose, PNRA has established three Regional Directorates in
the country which are empowered to inspect, review and assess a radiation facility in their
area and provide recommendations to the licensee for implementation in the form of Post
Inspection Report (PIR). The PIR is based on a harmonized check list for Regulatory
Inspections of a radiation facility based on IAEA guides and standards.
2.4 Assessment and verification of the operational radiation programme
The PNRA Regional Directorates are fully responsible for the assessment and
verification of the operational radiation programme of a radiation facility. The compliance of
post inspection reports is verified by the Regulatory Inspectors after a due course of time. If
necessary, a non compliance action is also taken if the post inspection recommendations are
not complied with by the licensee.
2.5 Safety and Security of Sources
The safety and security of radioactive sources have been given utmost importance in
the PNRA activities. Radioactive sources are under strict regulatory control so that there is
very little chance that a source be lost, misplaced or stolen. A computerized inventory of
radioactive sources in the country is being maintained at PNRA since 1990. PNSRP
Regulations 1990 and PNRA Regulations (PAK/904) contain necessary clauses for initiating
legal action in case of loss, theft or destruction of radioactive material and radiation
apparatus. Operator of a facility is responsible to physically protect the sources and other
radioactive materials. A safety guide for the users of sealed radioactive sources has been
The regulatory inspections of the users of radioactive sources are carried out by
RNSDs. These inspections also include physical verification of radioactive sources,
verification of safety and security measures etc. Compliance with the recommendations is
PNRA gets guidance from the IAEA safety guides and standards while devising its
own regulations. In line with its support for the IAEA, Pakistan has conveyed to the D-G,
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IAEA (on 20th
April 2004 through our Permanent Representative at Vienna) a non-binding
political commitment for adoption of the “Code of Conduct on the Safety and Security of
2.6 Control of orphan sources
Keeping in view the risk associated while handling any type of radioactive source or
malevolent use of it, an action plan has been chalked out to strengthen the regulatory control.
This includes the imposition of checking levels at various stages, right from the import of
sources till their disposal. Clear guidelines are provided for all major aspects including
acquisition, storage, transportation, emergency preparedness, dealing with loss and the
disposal of radioactive sources. PNRA maintains a National Radiation Emergency
Coordination Centre (NRECC) and this set-up is available for contingencies in this regard.
Custom Authorities have been instructed to obtain “radiation-free” certificates from the
importers of metal scrap. Mechanism has been established to track the sources from their
cradle (entry into the country) to their grave (final disposal).
2.7 Communications with the Public and Quality Management System
PNRA has recently established an Information Services Directorate (ISD) for
developing and enhancing good communication links with the public and other related
organizations regarding the safety culture and requirements of national legislation on
radiation protection. In collaboration with a major reputed educational / management
institution in the country, PNRA is developing its own internal Quality Management Manual.
3 CONTROL OF OCCUPATIONAL EXPOSURE
3.1 Individual monitoring for external radiation
The Radiation Protection Regulations define the responsibilities of a licensee for
establishing and implementing the technical and organizational measures that are needed for
the protection of a radiation worker. Individual monitoring services – using both the TLD and
film badges – are provided by a central service provider in the country. In addition to this,
operators of nuclear power plants also provide the above service through their own
arrangement using TLD’s. The occupational exposure record of each radiation worker has
been centrally computerized and is kept available for verification of a Regulatory Inspector.
Adequate management system is available with the service providers and verified during
inspection of each facility. These services operate under the authorization of the Regulatory
Authority. However, PNRA is looking for ways to improve and strengthen these services by
encouraging other private entrepreneurs to enter this field. Thought is also being given to
PNRA itself providing these monitoring Dosimetry services.
3.2 Calibration of monitoring equipment for external radiation
Radiation measuring instruments are calibrated at Secondary Standard Dosimetry Lab
(SSDL) located at PINSTECH NILORE Islamabad. The laboratory maintains Secondary
Standard Instruments in adequate agreement with the international measuring system and
extends therapy dose level and radiation protection level calibration service to all the radio
therapy institutes in the country. The radiation beam output measurement is also verified by
Secondary Standard Dosimetry Laboratory personnel on country level. The SSDL also takes
part routinely in various TLD postal dose inter-comparison programmes arranged by
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IAEA/WHO network of Secondary Standard Dosimetry Laboratories. The calibration
services of protection dose level survey instruments were introduced at country level in
October 1991. All the Personnel Monitors, Dosimeters (Film Badges and TLD’s) are
calibrated at SSDL and calibration certificates giving details of calibrations is issued with
every survey instrument. The Regulatory Inspector verifies the certification during inspection
of a radiation facility. The SSDL intends to extend these calibration services to contamination
monitors and high level therapy in near future after the availability of necessary equipment.
We are very grateful to the IAEA for providing us the necessary secondary standards in this
3.3 Individual monitoring for assessment of intakes of radionuclide
The central individual monitoring service provider has the capability of assessing the
intake of radionuclide using both direct (whole body counter) and indirect method (Bioassay)
for radiation workers engaged in handling loose radioactive material during a radiation work..
The provision of these services (viz. individual monitoring for external and internal intakes)
is accredited through inter-comparison at international levels. PNRA has now allowed further
upgrading of these services after assessing the quality management of these facilities.
3.4 Workplace monitoring
Under the PNSRP Regulations 1990 (Revised version PAK/904), the licensee is
required to develop a workplace monitoring programme at its facility and maintain record for
verification by a Regulatory Inspector during routine inspection of the facility. The
workplace monitoring is carried out by using Survey Meter and Contamination Meters that
are kept by the licensee. Regulatory requirements demand that these instruments are regularly
calibrated at SSDL PINSTECH, and this is verified during each inspection.
3.5 Assessment of exposure to sources of natural radiation
No such system exists at the moment for the assessment of exposure to sources of
natural radiation in the country.
3.6 Central dose record keeping for external and internal exposure
The central service provider is responsible for maintaining and keeping dose record of
each radiation worker in the country. This record is verified by a Regulatory Inspector during
the inspection of the facility. The Regulatory Authority intends to maintain a copy of the
computerized individual dose record of each worker at its headquarters for ready reference.
4 CONTROL OF MEDICAL EXPOSURE
4.1 Patient Protection In Diagnostic Radiology
Regulations are in place based upon BSS-115 in the area of diagnostic radiology.
Lack of resources and available qualified experts is a major contributing factor to non
compliance by licensees. QA and QC procedures are presently not in place though a genuine
effort is being made to adopt and enforce some basic guidelines. Areas like image quality
assessments, retake evaluations, and reporting burden to PNRA are being hindered due to the
lack of proper QA/QC monitoring equipment and the lack of understanding on part of the
licensees as to the importance of such practices. Protocols for quality management, though an
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inherent requirement of the PNRA regulations, have generally not been implemented by the
licensees primarily due to lack of training and understanding of the safety culture philosophy.
Although some guidelines are followed based upon manufacturer-supplied criteria a
comprehensive TQM is not in existence. The areas of QA also includes surveys of patient
doses, image quality assessments, and provision of guidance levels including but not limited
to mechanisms for training, education of medical and paramedical personnel is inadequate.
Another area of consistent shortcoming is the unavailability of qualified experts in the field of
radio diagnostic physics. With such a large number of hospitals and medical centers
nationwide, the enormous task of tabulating each and every facility is still a thing of the
distant future. Implementation and compliance with these regulations varies widely between
licensees and often is in disarray. PNRA with its limited staff and resources and lack of
monitoring and QA/QC instruments, equipment, and trained workforce is doing its best and
continues to strife to rectify the situation but a dedicated and continued technical and
financial support from IAEA is a must for realization of these goals and objectives.
4.2 Patient Protection In Interventional Radiology
Regulations are in place based upon BSS-115 in the area of interventional radiology.
Most facilities falling under this category are operated by PAEC and have the required
equipment and qualified staff in place for day-to-day activities. Some facilities / hospitals /
centers operating in the private sector also offer such services, and due to the limited number
of such facilities, PNRA is able to enforce and get partial compliance with most of the basic
requirements under the regulations. It is expected that following of QA and QC procedures
will enhance a safety culture. Centers which are operated by the PAEC are cooperative and
are currently in the process of establishing procedures and guides which (upon approval by
PNRA) will further enhance the safety and reliability of the medical exposures.
4.3 Patient Protection In Nuclear Medicine
Regulations are in place based upon BSS-115 in the area of Nuclear Medicine. Most
facilities are operated by PAEC. All facilities are licensed and are regularly inspected for
compliance. Trained and qualified experts are available at these facilities and necessary
efforts are being made to establish comprehensive QA and QC guidelines. Education and
training of medical and paramedical staff is also being undertaken on an on-going basis. Most
facilities do have medical physics staff on hand but radio pharmacy is a highly understaffed
4.4 Patient Protection In Radiotherapy
Regulations are in place based upon BSS-115 in the area of Nuclear Medicine. Most
facilities are operated by PAEC and some by private enterprises. All facilities are licensed
and are regularly inspected for compliance. Trained and qualified experts are available at
most facilities and necessary efforts are being made to establish comprehensive QA and QC
guidelines. Continuing education and training of medical and paramedical staff is undertaken
on an ongoing basis. Most of the safety information is disseminated via PNRA/IAEA
organized workshops and in some cases PNRA staff has been sent abroad for advanced
trainings and scientific visits. PNRA is making effort to help bring in radio pharmacy experts
in these facilities also.
4.5 Type Approval Of Radiation Sources For Medical Use
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All radiation sources – sealed or unsealed – including radiation generators for medical
use are imported or produced locally under strict safety guidelines circulated by PNRA,
which in turn conform to IEC and ISO standards. This ensures that only trained and qualified
people handle such sources and that contingency plans in place in case of accidents. QA/QC
guidelines should to make the safety process transparent and to help avoid accidents.
5 CONTROL OF PUBLIC EXPOSURE
5.1 Control of radioactive discharges
Regulatory provision has been made in PAK/909 for nuclear installations to prepare
environmental monitoring program, however this does not cover quality management system.
Concentration and discharge limits for radionuclides have been approved by PNRA for NPPs.
Source monitoring and compliance with discharge and concentration limits is verified by the
regional directorates of PNRA. Concentration limits for radionuclides in gaseous and liquid
effluents have been prepared on the basis of BSS-115. Currently, these are awaiting final in-
5.2 Environmental and food monitoring
The major likely sources of public exposure are the operation of nuclear power plant,
nuclear fuel cycle and the waste generated by the radio therapy and the nuclear medical
centers in the country. A wide network of environmental and food monitoring has been
established in the country by the major nuclear energy promoter i.e. PAEC. Similarly, under
the radiation protection regulations, each nuclear facility/center is required to establish its
own environmental monitoring programme and keep surveillance over the releases made by /
from it. Each establishment develops its own derived release limits based on the public dose
of 1 mSv/year which is verified by PNRA inspectors. PNRA has also initiated steps towards
development of its own capabilities for environmental monitoring to meet the emergency
preparedness and planning requirements. This will also be useful to cross check and verify
the annual environmental monitoring results submitted to the authority by the licensee.
PNRA carries out food monitoring programme to assess radioactive contamination in
food before issuing of a Radiation Free Certificate to the exporters of food items.
5.3 Control of Exposure to Radon
No such mechanism for the control of exposure of Radon exists in the country at the
moment. However Research and Development programme for this activity is under way at
one of the major research institutes (PINSTECH). However, in a nuclear fuel facility, there is
a local monitoring programme for control of exposure to the radiation worker from Radon.
5.4 National waste management strategy
Regulations on Radioactive Waste Management (PAK/915) are in the final stage.
These regulations are in consistent with the IAEA Safety Fundamentals publication “The
Principles of Radioactive Waste Management”. Under these regulations, development of new
disposal facilities shall be under the regulatory control of PNRA. Regulations allocate
responsibility to the licensee for all aspects of safety of radioactive waste management.
5.5 General safety provisions for radioactive wastes
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Acceptance criteria and quality management system have not been developed so far;
however, the provision for waste management and storage or disposal has been provided in
the regulations. Waste classification has been established in the draft waste management
regulations. Spent sealed sources are adequately processed, stored and disposed of under
5.6 Treatment of radioactive waste
The procedures for the characterization and segregation of radioactive waste are
normally prepared by the licensee in accordance with the PNRA requirements. Provision has
been made in the draft regulations for the processing of radioactive waste to be performed
adequately to fulfill acceptance requirement for disposal as well as requirements for handling,
transport and storage of waste packages.
5.7 Control of discharges from the managements of radioactive wastes
Under PNRA Ordinance 2001, no person may discharge or dispose of radioactive
waste to the environment without obtaining authorization from PNRA. Criteria for discharges
need to be developed. There are usually administrative provisions in each facility to prevent
unplanned or uncontrolled release. The facility operator/licensee is required to inform PNRA
promptly if discharges exceed authorized discharge limits.
5.8 Clearance Regime by radioactive waste
Draft Regulations on Radiation Protection define clearance. Conditions and clearance
levels for gaseous, liquid and solid waste are still to be developed to enable the removal from
control of materials containing low levels of radionuclides.
5.9 Storage of radioactive waste
Radioactive waste is stored safely and can be retrieved (in the future) whenever
disposal is authorized. Clearance for disposal as ordinary waste has so far not been allowed.
Interim storage facilities are centralized on a minimum number of sites (currently only three).
Regulations for site evaluation of storage facilities however do not exist. Instead, IAEA
Guides and Standards are followed. At each facility, the licensee is required to allocate a
clearly demarcated and dedicated area and provide controlled access to the same for the
storage of radioactive waste. Safety of existing storage facilities is ensured through
inspections and this is upgraded to the extent necessary.
5.10 Disposal of radioactive waste
No disposal facility exists in the country as yet. Development of such facility is under
process and is the initial stage of site selection. According to the draft regulations on waste
management, the licensee shall have overall responsibility for the safety of the disposal
facility and shall carry out safety assessments. Regulatory requirements for the siting,
designing, construction, operation, closure and post-closure of a waste disposal facility will
need to be established, but currently we continue to follow the IAEA Guides and Standards
on the subject.
5.11 Decommissioning of waste management facilities and radioactive
waste from the decommissioning of nuclear and other facilities
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As previously pointed out, Pakistan does not have a waste disposal facility and an
assessment has not been made for the waste likely to be generated from the decommissioning
of nuclear and other large facilities. Work on the regulations on decommissioning of nuclear
installations is underway, and will cover the safe management of radioactive waste generated
as a result of decommissioning activities. These draft regulations will ensure that sufficient
capacities exist for storage and/or disposal of these wastes. The regulatory requirements for
decommissioning of storage facilities and closure of disposal facilities will eventually also
need to be developed.
PNRA has not made any assessment for potential risk posed by radioactive residues
from past practices primarily because there are few – if any – such residues. Regulatory
requirements for the safe management and cleanup of the affected areas and facilities will
eventually be developed.
6 TRANSPORT SAFETY
6.1 National competent authority for the safe transport of radioactive
Chairman, PNRA is the designated national Competent Authority for the safe
transport of radioactive material. PNRA has earmarked appropriate resources and efforts are
underway to improve the transportation of radioactive material in the country. It is likely that
a research contract may be issued to a university for studies in this regard.
6.2 Coordination and cooperation at national and international level
Presently, PNRA does not have any formal agreements/arrangement for co-ordination
with national/international regulatory authorities in the field of transport of radioactive
material. However, PNRA is following the latest IAEA transport regulations (TS-R-1). Our
own national emergency regulations are being drafted. These will dictate the measures,
responsibilities, role etc., of the consignor/carrier in case of accidents during transport of
6.3 Compliance assurance programme
Pakistan normally imports most of the radiopharmaceuticals and radioactive sources needed
for industrial and research applications. Under the PNSRP regulations 1990, the licensee is
required to first obtain a No Objection Certificate (NOC) from PNRA for the import/export
of radioactive material / sources. These NOCs dictate that the licensee has to follow the
IAEA transport regulations / national requirements for the transport of radioactive material.
Our regional Directorates carry out inspections of such consignments / shipments to ensure
that all the requirements are met regarding transport of radioactive material locally and
7 PLANNING FOR AND RESPONSE TO RADIATION
7.1 National level arrangements for emergency preparedness and response
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In Pakistan, the Federal Government is responsible for the overall management, co-
ordination, control, mitigation and liquidation of consequences from disasters, accidents and
calamities. The Pakistan Government has extensive emergency response plans for dealing
with different types of national emergencies. In addition to overall national emergency plans,
there are supporting plans at the provincial, district and local level. For co-ordination and
execution of protective measures, a National Crisis Management Cell (NCMC) is established
in Islamabad which works under the Cabinet Secretariat, Government of Pakistan.
Specific requirements on nuclear safety and radiation protection matters are regulated
by the Pakistan Nuclear Regulatory Authority (PNRA). PNRA is anticipated to play a
significant role in the national arrangements for response to a nuclear emergency. In case of a
nuclear accident or radiological emergency, the Chairman PNRA acts as an advisor to the
Government of Pakistan on actions undertaken to mitigate the consequences of the nuclear
accident or radiological emergency situation. PNRA functions include keeping Chairman
PNRA briefed on the emergency situation so that he can provide accurate advice to the
Government of Pakistan. The PNRA has established a National Radiation Emergency Co-
ordination Centre (NRECC) for receipt and dissemination of information in response to
nuclear accidents or radiological emergencies happening domestically or abroad. The
NRECC co-ordinates radiological monitoring in support of licensees and other off-site
authorities. PNRA has internal procedures for the conduct of operations of the NRECC.
In Pakistan the national emergency response plan to combat nuclear accidents or
radiological emergencies has been drafted. Efforts are under way at ensuring proper
integration of PNRA with the already existing disaster response infrastructure maintained by
NCMC and to make it a part of the overall national emergency plan.
7.2 Emergency preparedness and response for licensed facilities and
PNRA Ordinance 2001 provides the basis for establishment of regulations and guides
on emergency planning and preparedness for nuclear accidents or radiological emergencies in
Pakistan. Promotion or adoption of regulations and guides is on the basis of international
Conventions, IAEA Basic Safety Standards and requirements such as GS-R-2 “Preparedness
and Response for a Nuclear or Radiological Emergency.”
PNRA is in the process of developing or revising additional regulations and guides to
regulate licensee activities in relation to emergency planning and preparedness. For example,
the draft of PAK/914, Rev. 0, “Regulation on Nuclear Accident or Radiological Emergency
Management” has been prepared and presently is under departmental review. The PNRA is
also in the process of coordinating interfaces for prevention and management of nuclear
accidents or radiological emergency situations among the Federal government infrastructure.
The licensee i.e. PAEC which is the sole promoter of safe use of nuclear energy in Pakistan is
well aware of the requirements and its facilities including Karachi Nuclear Power Plant
(KANUPP) and Chashma Nuclear Power Plant (CHASNUPP) maintain well documented and
operational On-Site as well as Off-Site emergency plans. In the event of an emergency
situation at the facility, the licensee, in accordance with its on-site emergency plan, will
activate its emergency organization. Activation of the off-site emergency organization will be
in accordance with the off-site emergency plan.
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7.3 Medical preparedness for emergencies
PNRA regulations PAK/913 (Rev. 1), includes provisions for emergency
preparedness;. Section 2.26 (iv) of these regulations states that the emergency plan of the
licensee shall include: “Provisions for minimizing the exposure of individuals to ionizing
radiation and for ensuring medical treatment of casualties…”. PNRA has made educational
awareness presentations regarding nuclear matters to schools, medical doctors and district
health officials. PNRA also provide DNSRP/PAEC radiation information brochure to various
organizations and members of the public. The licensee has the capability and equipment to
implement actions to meet this requirement and the PNRA verify the licensee’s actions Both
the licensee and the PNRA have stocks of potassium-iodide (KI) medication, which can be
provided in an emergency to individuals that may be exposed to the radioactive plume during
the early phase of a large radioactive material release from a nuclear power plant.
8 EDUCATION AND TRAINING (E&T)
8.1 E&T of persons with comprehensive responsibilities in radiation
The available manpower in radiation protection has a lot of experience in the field of
radiation protection. Entry-level professionals have been imparted training in the field
through one year or two years course through conducted at PAEC’s major training institutes
viz. PIEAS and KINPOE. They are well versed in handling the safety aspects related to the
radiation practices in the country. PNRA has established its own training institute where
appropriate retraining / refresher courses will be conducted in near future.
8.2 E&T of manager and workers
There is no exclusive training programme for the education and training of managers,
workers and medical officers in the authorized facilities in the country. Thus, the education of
these personnel in radiation protection is carried out through delivering lectures / holding
short duration seminars and workshops in the country. Once the PNRA training policy is
fully established in its human resource directorate, it is planned to hold comprehensive
programme for the training of above personnel in the very near future.
8.3 E&T of medical and paramedical professionals
No such facilities exist at the general university level for education and training of
medical and paramedical professionals in the country. In recent years, PIAES has started
post-graduate degree courses in the field of nuclear medicine and medical physics. This has
helped in promoting the necessity of radiation safety to medical and paramedical
professionals. According to PNRA’s training policy, it is planned to hold separate short term
courses in the field of nuclear and radiation safety for medical professionals in our own
training institute. Often, the medical and paramedical staff (of licensees) involved in handling
radioactive sources / radiation generators are imparted training / awareness through personal
counseling during regulatory inspections, provision of necessary literature on radiation
protection and through arranging short duration on the job training. PNRA has made it
obligatory for all nuclear and radiotherapy centers to engage a qualified radiation officer /
medical physicist for each of these medical centers and their presence is verified by
regulatory inspectors during inspection of these centers. It is worth mentioning that almost all
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the large medical centers and hospitals now have qualified radiation protection personnel on
8.4 Training of peripheral persons
Currently there is no specific regulatory requirement for the training of peripheral
persons. A comprehensive training policy in the field of radiation protection awareness has to
be framed. However, for many years the Ministry of Commerce has imposed a restriction on
the import and export of radioactive material. The requirement of obtaining a no objection
certificate (NOC) from PNRA for engaging in the above activity is mandatory under
radiation protection regulations, and the peripheral persons involved at custom offices,
firefighting offices etc, are aware of the regulatory requirement. These personnel have been
provided necessary radiation safety advice in the handling of radioactive containments
through pamphlets entitled “safe handling of radioactive material”.
Although the existing radiation protection infrastructure is meeting the basic statuary
requirements of the country under existing country regulations, considerable improvements
are needed to make it more efficient. Radiation is a very vast field and requires accuracy and
precision at every stage of its application. The need for proper training of personnel, studies
and the importance of up-to-date information cannot be but emphasized. Pakistan has limited
resources at its disposal. Assistance from IAEA for improvement in the following disciplines
would be welcome:
• Quality Assurance/Quality Control system for diagnostic radiology and radiotherapy.
• Immobilization techniques for radioactive waste. (Milestone-4)
• Measurement of patient dose during Radiotherapy and assessment of chromosome
aberration thereafter. (Milestone-3)
• Radiation protection in diagnostic radiology. (Milestone-3)
• Development of standards for verification of available calibration facilities in the
nuclear medical centers. (Milestone-3)
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