In some areas in which people are present for occupational reasons, naturally occurring radioactive substances can lead to increased radiation exposure. Until now, separate regulations have applied to protect workers from such natural radiation sources (Natürliche Strahlenquellen-Verordnung – Natural Radiation Sources Ordinance – and the Strahlenschutzverordnung fliegendes Personal – Radiation Protection Ordinance for Flying Personnel).
With the new radiation protection law that entered into force on August 1, 2020, the radiation protection regulations concerning artificial radioactive substances and terrestrial natural radioactive substances have largely been harmonised. For this reason, the provisions for both areas are anchored in the Allgemeine Strahlenschutzverordnung 2020 (Radiation Protection Ordinance 2020 – AllgStrSchV 2020) with the Natürliche Strahlenquellen-Verordnung ceasing to be in force. This means, amongst others, that (unlike in the past) companies that carry out activities involving naturally occurring radioactive materials are now also subject to the licensing or notification requirements of the Strahlenschutzgesetz 2020 (Radiation Protection Act 2020 – StrSchG 2020), unless an exemption is granted by the AllgStrSchV 2020.
The areas of work where increased radiation exposure of workers to terrestrial natural radioactive substances is possible are listed in Annex 3 to the AllgStrSchV 2020. As in the past, these are, in particular, the following company sectors:
- Water supply enterprises
- Radon health resorts
- Industrial/commercial use of products containing thorium
- High-pressure liquid cutting and sandblasting
- Processing of raw phosphates, for example, in the fertiliser industry
- The zirconium and zirconia industry
In line with EU requirements, three industrial sectors have been added to this scope: cement production, including maintenance of clinker ovens, primary iron production, and tin, lead and copper smelting.
If residues enriched with natural radioactive substances accumulate during work processes, radiation protection measures must be taken as before.
If a company falls within the scope of the AllgStrSchV 2020, its owner must commission a certified monitoring service. The assignment includes a dose estimate for those workers who could be exposed to increased radiation exposure and, if necessary, the assessment of the activity concentration of residues and radioactive substances discharged with air or wastewater.
Please note
These estimates and assessments shall be repeated periodically, with cycles depending on the hazard potential (five or ten years). In addition, they must be repeated in the event of changes relevant to radiation protection. To ensure that from a radiation protection point of view there is still no increased official control effort, this also applies to companies that are not subject to licensing or notification requirements.
Depending on the results of the estimates and assessments, the companies are subject to either an authorisation requirement, a notification requirement or exemption from the notification requirement. The latter possibility exists if the results of the assessment and estimates suggest that radiation protection relevance is very low.
An enterprise is subject to licensing if workers are to be classified as "exposed workers" or if the discharges or residues exceed certain values specified in the AllgStrSchV 2020. In this case, the provisions for practices requiring a licence will apply.
A company is obliged to notify if the activity concentrations of the residues are increased but do not exceed the limits for the obligation to obtain a licence and the expected radiation doses of the workers and the discharge values are within the normal range. The AllgStrSchV 2020 specifies values for activity concentrations above which they are to be considered relevant to radiation protection.
If the company is subject to licencing or notification requirements, it must take appropriate technical and/or organisational measures to ensure that radiation exposure of persons and the environment is kept as low as reasonably achievable. The company is best advised to clarify which measures are appropriate with the monitoring service.
Compliance with radiation protection is periodically monitored by the authority. In the case of companies subject to licencing at least every three years and in the case of companies subject to notification at least every five years.
In the case of residues, the monitoring service determines whether they are harmless from the radiation protection point of view and can thus be disposed of or recycled in compliance with the provisions of waste management law. Otherwise, these residues must be disposed of as radioactive waste (see chapter "Disposal of radioactive waste").
The protection of workers from cosmic radiation is a special case. The regulations for the protection of this group of persons remain unchanged from the previous regulations. Air carriers are obliged to implement radiation protection measures for their personnel who are increasingly exposed to cosmic radiation during flights. These regulations are now also anchored in the StrSchG 2020. The previously applicable Radiation Protection Ordinance for flying personnel has been repealed.