Appendix 08A Country Report Bangladesh.doc


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Appendix 08A Country Report Bangladesh.doc

  1. 1. Bangladesh Country Report Current status of Radiation Protection Country Report: Bangladesh* 1. Introduction The activities involving nuclear and radiation techniques in Bangladesh now encompass the needs of a number of sectors of national economy, such as healthcare, industry, construction, water resources, isotope production, food preservation, oil and gas exploration, etc. The trend suggests that the role of radiation practices will increase significantly in the future. In such a situation, the issues of radiation control assume inordinate importance. A set of proactive action programs and procedures, and commitment from the stakeholders concerned are required for evolving and implementing an effective nuclear regulatory regime. Inadequacy of resources, and other constraints make it difficult to face the challenges of the progress of regulatory enforcement. The IAEA Model Project and projects under the RCA are providing useful support and assistance to the national efforts on the strengthening of the radiation and waste safety infrastructure. 2. Legislative and Regulatory Infrastructure The Nuclear Safety and Radiation Control Act No. 21 of 1993 and the Nuclear Safety and Radiation Control Rules of 1997 are the main legal and administrative instruments in force in the area of nuclear safety and radiation control. The Nuclear Safety and Radiation Control Rules are in general consistent with the International Basic Safety Standards for Protection Against Ionizing Radiation and for the Safety of Radiation Sources (BSS). In the legislation the Competent Authority has been given effective empowerment including the introduction of enabling rules and regulations to facilitate implementation of different provision of the law and the rules. The existing Law entrusted BAEC with the responsibility to enforce it. BAEC in turn has established the Nuclear Safety and Radiation Control Division (NSRCD) to implement the Act. The regulatory body has about 40 personnel, more than half of * Presented in IAEA/RCA Review Meeting of National Focal Points on Radiation Protection, 7-11 June, 2004, Beijing, China 1. Dr. C. S. Karim, Member Physical Science, Bangladesh Atomic Energy Commission, 4, Kazi Nazrul Islam Avenue, Ramna, Dhaka, Bangladesh. e- mail Page 1 of 14
  2. 2. Bangladesh Country Report who are professionals. An amendment to the law is envisaged, which, among others, aims at establishing an independent regulatory authority. Enforcement of regulatory obligations is made difficult due to paucity of funds. The Government is providing block allocation for implementing regulatory control in the form of grants. The other sources of funding include license fees and expert (advisor) services. A fresh project has been initiated to strengthen the infrastructure. The financial situation is expected to improve further when the project is completed and the activities are included in the subsequent annual budgets. The co-ordination and co-operation between the Regulatory Authority and other governmental organizations is effective. Two Statutory Regulatory Orders of the Ministry of Health and Family Welfare have established a framework for cooperation and coordination between national agencies involved in the operation of regulatory programmes in Bangladesh (Ministry of Health and Family Welfare, Ministry of Commerce, and professional associations, etc.). BAEC is included in the high level national committee on disaster management, and other committees of the Health Ministry on establishment of therapeutic units in the hospitals. In addition, the WHO office in Bangladesh is providing assistance and support to BAEC in improving regulatory control over radiation practices in medicine. 3. Activities of Regulatory Authority The Law and the Rules on nuclear safety and radiation control have given adequate powers to the regulator to enforce its obligations without any discrimination or let off. Salient features of the regulatory process are described in the following paragraphs. 3.1. Notification and Authorization System Existence of a proper notification system and also public information is a pre- requisite for identification of radiation sources, facilities and practices that are subject to regulatory control. The national inventory of radiation sources was made possible through a combination of advertisements in the media (electronic and printed), involvement with professional associations, as well as with the help of the related Ministries and agencies and the district administration. The authorization systems are delineated in the Nuclear Safety and Radiation Control Rules of 1997. Prescribed application forms for licences in 8 different categories have also been developed. Evaluation is conducted on the basis of Page 2 of 14
  3. 3. Bangladesh Country Report information provided by the licensee and gathered by the inspectors in course of inspection of the facilities concerned. In future, a more effective evaluation procedure including the matching criteria needs to be developed. 3.2. Inventory of sources and licensing The regulatory survey and inspection program, conducted by a team of NSRCD inspectors, was performed during the period of May 1999 and July 2001. Information was collected in standard format and authenticated with inputs from the installation concerned. The validated information was analyzed, compiled and published in 77 volumes of reports. Eventually this would be made available through a Web Site. As a result of this exercise, detailed information on nearly the entire inventory of all radiation sources used in health services, industry, construction, mineral-exploration, agriculture, research and education, and X-ray installations are now available (Table 1 and Fig. 1). The spent sources are inspected and verified intermittently. Efforts are under way to transport such source to the central facility of BAEC for conditioning and safe intermediate storage Table 1. Inventory of radioactive source by practice as of May, 2004 Practices Number Licences Issued Diagnostic radiology 2392 1350 (52%) Radiotherapy 9 8 (90%) Nuclear medicine 17 17 (100%) Industrial radiography 10 9 (90%) Industrial irradiator 3 3 (100%) Nuclear gauges and well logging 18 18 (100%) Research reactor and neutron generator 5 4 (80%) Radioisotope production 1 1(100%) Waste storage(under construction) 1 0 Beach sand processing 1 0 Total 2457 1420 (60%) Notes: 1. Application for licensing of the facility separation of heavy minerals prevalent in the sand is being processed. Page 3 of 14
  4. 4. Bangladesh Country Report 0 2 4 6 8 10 12 14 16 18 20 Radiotherapy Industrial radiography Nuclear gauges and well logging Radioisotope production Beach sand processing Practices NumberofPracticesandLicenses Issued Number License Issued Figure 1. Status of licensing of radiation facilities 3.3. Compliance Monitoring Inspectors carry out the tasks to assess responsiveness of activities to the related requirements as stipulated in the legal instruments. The inspections are always carried out by two inspectors, equipped with radiation detection instruments, personal dosimetry and the appropriate audit form and licence file. Weakness/ deviations, if any, are conveyed during the visit and followed-up by letters specifying the actions that licensee should take actions that would help improving the situation to an acceptable level. 3.4. Enforcement and Verification, Safety and Security Enforcement actions are taken by the regulatory authority to rectify deficiencies and non-compliance with regulatory requirements. One of the most effective elements of the verification of compliance is in situ inspection, which is also the main way for establishing personal contact between the users and the regulatory authority's personnel (inspectors). The regulatory authority should have an inspection plan. The priority and frequency of inspections will be influenced by the risk and complexity of the practice and by whether the operation is conducted under a notification or license. Table 2 shows a proposal for frequency of inspection based on the risk of practice. Inspections can be announced or unannounced, and should be based on inventories brought up to date from the information given by the users. Radiation practices have been classified depending on their respective potential risks and frequency of verification and inspection defined for each group of radiation Page 4 of 14
  5. 5. Bangladesh Country Report practices as shown in Table 2. Table 2. Suggested frequency of inspection for verifying the facilities Practice Risk Frequency (months) Industrial radiography Stationary Medium 24 Movable High 12 Medical Teletherapy High 12 Brachytherapy High 12 Diagnostic X-ray Low 36 Nuclear Medicine Therapy High 12 Diagnosis Medium 24 Industrial practice Irradiators High 12 Level gauges Medium 24 Agriculture Density gauges Medium 24 Research, Education, Services, etc. X-ray fluorescence Low 36 Activation analysis Medium 24 Calibration Medium 24 Analytical work, calibration work, etc. Low 48 3.4.1.Verification of Compliance The verification of compliance is implemented by the regulatory authority in order to determine if sources are used according to the requirements established by regulations and by the conditions reflected in the license granted to the user. The verification of compliance gives the confidence that radiological safety requirements have been met or gives the opportunity or demanding corrective measures in case of non-compliance with these requirements. The most important elements for verification of compliance are: • in-situ inspections • radiological safety assessment • notification of incidents and accidents • reports of licensees • the systematic assessment of licensees 3.4.2. Security of Radioactive Materials Page 5 of 14
  6. 6. Bangladesh Country Report The security of radioactive materials is one of the prerequisite to good practice with radiation sources. According to the law, the licensee has the primary responsibility for the safe use, control and security of the licensed radioactive materials. It is his responsibility to prepare and maintain a detailed accountability system that includes a comprehensive record for all the licensed sources under his control. The record should include description of each source or radioactive material for which he is responsible, such as its activity, quantity and form, its use, location and movement and all measures that have been undertaken to ensure security of the source. The licensees are obliged that radiation sources are adequately marked to indicate radioactive material and to provide their storage in a secure location such that people in the vicinity are not inadvertently exposed and that unauthorized access and/or intrusion was minimized so as to prevent tempering with or removal of the sources. The regulatory authority verifies the security of the radiation sources periodically. The owner/licensee of radioactive sources are recommended to ensure safety of radioactive sources by keeping the sources under lock and key and maintain movement records about location so that unauthorized removal of the sources from their locations could be minimized. 3.5 Technical Services In Bangladesh, availability of various technical services of relevance to nuclear regulatory activities is overwhelming. Infrastructure and capacity is being built to meet the demands for such services both by the users and regulators. Most of the technical support, such as individual monitoring, calibration, radioactivity measurement, quality control output dose measurement, especially radiotherapy, etc. is now provided by BAEC laboratories. 3.6. Information dissemination Enforcement of the legal requirements is an important aspect of regulatory regime. as these have far reaching impacts on the society in general and the facilities, and practices and the workers in particular. It is difficult for a developing country to effectively enforce such a technical law where the words “safety culture” and “quality assurance” are new even to most of the management. The perception and understanding of invisible radiation is too shallow among the workers or even to the management. The attitude of the users, at least in the beginning, is usually hostile, as they perceive that such actions would entail additional costs and control. This attitude is especially true for such practices and facilities, which were established before the law was promulgated. Substantial efforts on motivation and support of the Page 6 of 14
  7. 7. Bangladesh Country Report stakeholders are essential to eliminate the initial apathy. A variety of activities, like participatory dialogues, training, workshops, etc. arranged by the regulator are gradually creating some awareness, understanding and motivation among the management and workers. The activities will continue. The corrective actions and the penalty in cases of non-compliances are the other two important aspects of enforcement that deserve serious consideration. 3.7 Quality management system Quality management system has not yet been developed, though in individual practices such as nuclear medicine, isotope production and NDT quality assurance program are being formulated. Effects are underway to improve QA. further IAEA QA guides are in general followed. 4. Control Of Occupational Radiation Exposure 4.1. Occupational Exposure Control Individual monitoring of occupational radiation workers handling X-ray, gamma ray, and beta radiation was previously carried out using film dosimeters. In the mean while, there has been a steady growth in the number of radiation workers, which in its turn has made the task of individual monitoring complex and involved. In view of the limitations, film badge is being replaced by TLD’s due to its better sensitivity, accuracy, reusability and better stability against environmental conditions. Individual Monitoring Service (IMS) is being provided since 2000 by using basic TL dosimeter (BG 0110, i.e. two elements TL Card) as a central monitoring unit. The unit has over 6000 such cards and two readers. The services are provided centrally. Software for the Individual Monitoring System has been developed and periodical reports are sent to radiation worker as well as the licensee. The dose records in electronic form are being backed up on a quarterly basis. BAEC participates in the IAEA/RCA inter- comparison program and the results so far have been satisfactory and within acceptable limits. Page 7 of 14
  8. 8. Bangladesh Country Report At present about 45% of the total workers are covered under routine monitoring services. It may be mentioned that almost the entire critical groups of workers engaged in industrial radiography, radiotherapy, nuclear medicine, reactor, isotope production are covered by the program. Efforts are being made to improve upon the situation through different types of interventions, such as making it mandatory for obtaining license, issuance of directives by the ministries, motivation, incentive, etc. The effects of the intervention are evident from the trend in growth of IMS coverage (Figure 2). The quality of exposure readings is being improved through quality control and inter-comparisons. Number of Issued TLD and Number of Organizations for the Year 2003 42 22 24 24 16 12 25 13 20 8 14 19 58 32 70 48 23 33 41 21 34 51 29 27 0 10 20 30 40 50 60 70 80 Jan'03 Feb'03 Mar'03 Apr'03 May'03 Jun'03 Jul'03 Aug'03 Sep'03 Oct'03 Nov'03 Dec'03 Mont hs No of Organization No of TLDbadge issued Figure 2. Growth in the coverage of occupation workers under IMS coverage 4.2 Calibration In 1991, a Secondary Standard Dosimetry Laboratory (SSDL) was established, which is traceable to the Primary Standard Dosimetry Laboratory (PSDL) of National Physical Laboratory (NPL), UK. This facility is used for the purpose to calibrate and standardize the field instrument employed for radiation monitoring and dose measurement for nuclear safety and radiation control throughout the country. Comparisons and calibrations are performed within the international measurement system to ensure the consistency of physical measurements. The SSDL network contributes to this by improving accuracy in applied radiation dosimetry. A variety of radiation measuring instruments such as survey meter, TLD, film badge pocket dosimeter, ionization chamber etc. Programs exist for the direct calibration of cobalt heliotherapy beams in radiotherapy departments in Bangladesh, and for calibration of survey instruments. Page 8 of 14
  9. 9. Bangladesh Country Report SSDL participates in different protection level postal inter-comparison programs (JAERI, Japan under RCA, the IAEA/WHO TLD postal dose quality inter- comparison program by using Co-60 teletherapy unit). The results of inter- comparison indicate the accuracy of the measurements achieved by the SSDL and conform to the respective acceptance limit (±3.5%) of dose deviation (Fig. 3). Fig.3: Intercomparison of Dose Quality 4.3. Internal dosimetry Efforts are being made to assess the internal radiation doses by using bioassay technique at critical installations such as radioisotope production facility, nuclear medicine facilities and beach sand processing plant. 4.4. Workplace monitoring The main objective of the workplace monitoring is to control the unwanted occupational exposure caused by radiation sources in use and also to ensure a safe working condition in a facility. The respective facilities have to perform this task on a regular basis. BAEC had conducted a nationwide workplace monitoring survey program, which included all Nuclear Medicine Centres (16 nos.), Radiotherapy Departments (7 in numbers) and industrial radiation practices like Non Destructive Testing (NDT), Nucleonic Gauge, Research facilities of BAEC, including the research reactor facility, etc. This program was envisaged to obtain an idea about the general status of the working facility, create awareness among the licensees on the Page 9 of 14 Intercomparison of Dose Quality -3 -2.5 -2 -1.5 -1 -0.5 0 0.5 1 1.5 2 2.5 3 1997 1998 1999 2000 2001 2002 2003 Year %deviation
  10. 10. Bangladesh Country Report need to routinely conduct their workplace monitoring and to introduce the facility operators with a systematic format for performing the same in future. The licensees were helped to classify their respective workplaces according to Basic Safety Series no. 115. In future, the licensees shall have to establish, maintain and keep under review a program for the monitoring of the workplace under the supervision of a qualified expert and a Radiation Control Officer (RCO). Licensees were also advised on the instruments and gadgets needed for sustaining the monitoring process. 4.5. Assessment of exposure Countrywide background radiation and radioactivity levels (soil, water, vegetation, etc.) are determined and updated from time to time to assess public exposure. These are conducted by three laboratories of BAEC. Such assessment is also conducted in different directions of the area lying within a radius of 25 Km. around the research reactor. 4.6. Central dose record Keeping Management Information System (MIS) group of BAEC has developed a software for Individual Monitoring Service (IMS) record keeping. Using this, records of all sorts of data of individual monitoring service (IMS) are maintained centrally. Data is stored in printed form, CD’s and also backed up in the central server. 4.7 Quality Assurance The Quality Assurance program for various radiation practices has not yet been developed. Licensees, especially those engaged in radiation practices in the health sector, have been instructed to prepare their respective Q.A programs. The regulator will review the Q.A programs. 5. Medical Exposure Control The X-ray imaging is by far the largest of all radiological practices. The practice is the main contributor to the population dose. Radiotherapy and Nuclear Medicine practices are potentially much more risky and can cause high individual dose. The authorized Radiation Control Officers (RCO) are responsible for the occupational exposure control in the respective facilities. Feedback and interactions with medical facilities, concerned authorities and persons are organized to improve the situation with medical exposure. The Ministry of Health and Family Welfare and the World Health Organization (WHO) are now being involved in the process. Page 10 of 14
  11. 11. Bangladesh Country Report Establishment and implementation of quality assurance programs and control of exposure of patients in radiotherapy, nuclear medicine and diagnostic radiology practices have been identified as important controlling medical exposure. Government commitment to medical exposure control in manifested in its decision to create two centers of excellence, namely the National Institute of Cancer Research and Hospital in Dhaka and the radiology unit at the Osmani Medical College in Sylhet. An initial budget of USD 320,000 has been allocated for this purpose. Another centre of excellence in Nuclear Medicine is also planned for the future. Qualified personnel are needed, in particular qualified medical physicists in the medical sector. So far as interventional radiology is concerned, one physician has been trained through IAEA assistance. It is planned that national training courses would be arranged utilizing his expertise. Subsequently such trained personnel will form the core group for implementation of radiation practices in the interventional radiation facilities. So far as type approval of radiation sources is concerned, Bangladesh is yet to initiate a national type approval procedure/ methodology. At present such activities are conducted using ISO/ IEC prescriptions/ guideline. 6. Public Exposure Control Environmental monitoring, as a routine, is carried out around 3 MW TRIGA reactor facility. The program is being expanded to include the isotope production and nuclear medicine facilities. In addition to this, environmental radiation monitoring is routinely conducted by BAEC laboratories throughout the country (soil and vegetable samples) and also on the marine environment. All known radium sources of the country were collected, conditioned and stored safely in November 2000 with the technical assistance and support of the IAEA. BAEC is constructing a Central Radioactive Waste Processing and Storage Facility at AERE, Saver. It will be used for conditioning and temporary storage of all radioactive wastes in the country. At present, BAEC maintains two temporary storage facilities at Dhaka and Savar, respectively. A national policy and program for radioactive waste management in Bangladesh, including the legal instruments is going to be formulated. Page 11 of 14
  12. 12. Bangladesh Country Report A high-resolution gamma spectrometry system is used to analyze food and environmental samples. A certificate of radioactivity level is provided to customers for import and export foodstuffs. The Government empowered BAEC to conduct radioactivity testing in all food items for human as well as animal consumption. Ambient level radiation measurement is currently carried out by TLD technique on a quarterly basis. 7. Transport Safety BAEC as of now is the competent authority for safe transport of radioactive materials and radioactive wastes in the country. The IAEA Transport Regulation has been adopted in the NRSC Rules of 1997 for this purpose. The transport agencies are issued with licenses based on the provisions of the rules. At the national level, the activities are coordinated with the transportation regulator of the country. Four persons were trained to facilitate safety of transportation and coordination with relevant government department, such as the Ministries of Communication and Science and the BAEC. 8. Planning for and response to Radiation Emergencies The role and functions of the BAEC in radiological emergencies are prescribed in the Nuclear Safety and Radiation Control Rules of 1997. BAEC is the contact point in the event of radiological emergencies. It is also empowered by the law to intervene and take appropriate action if required in the event of accidents or chronic exposure situations. Recently, BAEC has been included in the Committee of the National Disaster Management Bureau. Such participation would enable the regulator to involve all other concerned in mitigation of a situation arising from nuclear and radiation induced emergency situation. An organized structure for emergency response does not exist. BAEC is planning to design a national radiological emergency preparedness and response plan and elaborate the mechanism for subsequent approval by the appropriate bodies in the near future. License facilities have prepared their respective emergency plan. Efforts are underway to identify medical facilities with capability to attend to radiation sickness. Two medical doctors have been trained, who will be the eventual resource persons for training doctors on emergency response arising from radiation accidents. At the multilateral level, Bangladesh has ratified the Convention on Technical Page 12 of 14
  13. 13. Bangladesh Country Report Assistance in the Event of a Nuclear Accident or a Radiological Emergency as well as the Convention on the Prompt Notification of Nuclear Accidents. The Agency is providing assistance related to emergency response when requested. Mention may be made of a major explosion and fire initiated during the drilling for natural gas by an expatriate company. BAEC obtained technical assistance from the IAEA in locating and salvaging radioactive sources from the site of the accident. 9. Education and Training Training in radiation protection in Bangladesh are conducted in three strings, namely: • Training of regulatory personnel • Radiation Control Officers of the licensed facilities • Training of users/ practitioners In case of the regulatory personnel, training is imparted primarily under IAEA/ RCA initiatives. Training takes the forms of post graduate diploma in radiation protection (five have completed and other two are now taking this course in Malaysia), group training courses, on-the-job-training abroad, fellowship, etc. Feed back workshops are organized to disseminate knowledge within the regulator’s group. Such personnel also participate as resource persons in local training courses for users and practitioners. A National Training Policy on Radiation Protection is being formulated to strengthen and streamline the on-going efforts. Separate training courses of durations of one to three weeks are organized for the Radiation Control Officers of licensed facilities based on the practices involved. Feed Back workshops are also arranged to (a) assess the impact of the related training courses, (b) identify the need for revising contents, and (c) sharing experience and expertise in enforcing obligations of the RCO’s. For the third category, training courses are by and large arranged by the regulator. It is, however, encouraging to note that such training courses are now being arranged by different user groups (nuclear medicine for example). During the last five years, 43 training courses were organized in the above areas, including 16 during the last year. The number of trainees is 1756, including about 900 in 2003-2004. Page 13 of 14
  14. 14. Bangladesh Country Report In the beginning, the IAEA had provided support in organizing the training courses in the form of resource persons. Now training courses are based exclusively on local resource persons. WHO has co-sponsored seven training courses on medical practices, while 4 more courses with its financial assistance is planned for this year. BAEC is planning to build a separate full-fledged residential Training Institute. Considering the overwhelming importance of radiation control, this institute, when completed, will organize training courses on radiation protection in the future, including degree/ diploma programs for the medical physicists. 10. Conclusion Bangladesh is still in the nascent stage in radiation control. Achievements of last three/ four years are significant compare to the past. But a lot more needs to be done to attain the goal of sustainable radiation control. The proposed amendment to the legal framework, which among others will improve transparency and independence, will be a vital instrument for enforcing regulatory regime effectively. The strategic relationship with the IAEA/RCA and the opportunities offered under the model project will be the single largest external contributor to supplement government initiatives and interventions in gradually improving enforcement of radiation control in the country. Page 14 of 14