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Training of the Radiation Protection Advisor

In order to carry out its missions, the CRP (Advisor in Radiation Protection) must follow the PCR (Competent Person in Radiation Protection) training.

The decree of December 182019 comes to definethe modalitiesof these PCR trainings. Thus, the content and duration of training, the conditions for issuing and renewing training certificates are notably provided for by the decree. It also sets the certification criteria for training organizations and competent organizations in radiation protection. This decree was issued pursuant to new item R4451-123 of the Labor Code,created during the overhaul of the regulations concerning the protection of workers against the risks due to ionizing radiation (Decree No. 2018-437 of June 4, 2018 relating to the protection of workers against the risks due to ionizing radiation). It repeals the former order of December 6, 2013 and has been applicable since January 1, 2020. Certain transitional provisions are provided for in this regard.

The object of thedecree of December 18, 2019  is also to determine the methods of training and exercise of the radiation protection adviser, whether the latter is a competent person in radiation protection or a competent organization.

I-Conidentifying the person cocompetent in radiation protection

1) Area of competence of the PCRs (article 2 of the decree):

Article 2 of the decree delimits the field of competence of the PCRs. The missions carried out by the PCRs are defined in aux articles R4451-123 of the Labor Code et R1333-19 of the Public Health Code (CSP) and vary depending on what is written on their training certificate. The PCRs are competent for the level listed on their certificate but also for the lower levels.

Here are the different missions that can be entrusted to une PCR :

  • Give advice on the design, modification or layout of workplaces and safety devices intended to prevent the risks associated with ionizing radiation; but also concerning the programs for checking work equipment and the procedures for monitoring the individual exposure of workers, their classification in categories A or B according to the dose of millisieverts to which they are exposed (article R4451-123 of the Labor Code); or concerning the conditions of access to supervised, controlled or radon zones (article R4451-24 of the Labor Code) or areas in which there is a device emitting ionizing radiation (article R4451-28 of the Labor Code).

  • Participate in the assessment of the risks resulting from the exposure of workers to ionizing radiation (article R4451-13 of the Labor Code), the definition and implementation of prevention against these risksand the development of monitoring measures for the individual exposure of workers.

  • Carry out or supervise measurements in the workplace when the results of the risk assessment reveal that worker exposure may be above a certain millisievert threshold (article R4451-15 of the Labor Code), as well as verifying the effectiveness of the means of preventing the risks of exposure to ionizing radiation.


2) Training of PCRs (articles 3 to 10 of the decree):

The training must enable candidates to implement the principles of radiation protection adapted to the nuclear activities implemented in the operation in which they are involved, and to apply the associated regulations.

At the end of the training, the candidates receiving the certification are able to identify the risks, to measure the consequences of the latter, and to implement the means of prevention to control them (article 3). This certification must be issued by a competent body and is valid for 5 years.

There are two levels of certification, resulting in the issuance of either a level 1 certificate or a level 2 certificate, structured as follows (article 4 of the decree):

Level 1 covers the sectors:

  • “artificial radiation”, namely:

a) The sealed radioactive sources and electrical devices emitting ionizing radiation mentioned inarticle R. 1333-104 of the public health code  and not requiring a delimited area beyond the blue supervised area, defined in article R. 4451-23;

b) The sealed radioactive sources and electrical devices emitting ionizing radiation mentioned inarticle R. 1333-104 of the public health code, requiring a delimited green controlled area, defined in article R. 4451-23, access to which is made impossible for workers during the emission of ionizing radiation, by means of primary prevention (physical means adapted to the risks, redundant and independent);
c) Activities carried out by employees of temporary employment companies within establishments falling under the provisions of Articles R. 4451-1 and following of the Labor Code.

  • and “naturally occurring radiation”, namely:

Human activities involving the presence of natural sources of ionizing radiation which lead to a significant increase in worker exposure, and in particular:

  • The operation of aircraft with regard to the exposure of the crews defined in article L. 6522-1 of the transport code as well as of spacecraft, with regard to their crew.

  • The activities or categories of professional activities dealing with materials naturally containing radioactive substances not used for their fissile properties, the list of which is set out in article D. 515-110-1 of the environment code.

  • Activities carried out in mines as defined in article L. 111-1 of the mining code.

  • And professional activities carried out in the basement or on the ground floor of buildings located in areas where exposure to radon is likely to affect the health of workers defined pursuant to Article L. 1333-22 of the public health code, in underground works in mines and quarries as well as in certain specific workplaces.


Level 2 concerns all activities not covered by level 1:

  • The medical sector (itself divided into two options: sealed and unsealed sources).

  • The industrial sector (itself divided into three options: sealed, unsealed and nuclear sources).


The initial training consists of two modules (article 5 of the decree): a theoretical module and an applied module. The duration of training varies according to the level of certification sought (level 1 or level 2). The training durations are explained in Appendices I and II of the order.

The training can also be provided within the framework of a course validated by a diploma from the national education system, from the general direction of education and research, under the authority of the ministry of agriculture, training in medical radiation physics provided by un decree of December 6, 2011 or higher education in radiation protection.

Reinforced training is also planned for PCRs holding a level 2 certificate, who wish to deepen their skills in terms of regulations, metrology, design of installations, environmental impact study and quality management ( article 6 of the decree). However, to benefit from this reinforced training, PCRs holding a level 2 certificate must demonstrate 6 months of exercise of the PCR function or 3 months of tutoring experience within a body competent in radiation protection. which intends them to act as radiation protection advisers for a third party.

Like the initial training, the enhanced training consists of a theoretical module and an applied module.

Article 7 of the order provides for the procedures for renewing the certification. The renewal training varies according to the levels, sectors and possible reinforced training mentioned on the training certificate held by the PCR. Before the renewal training takes place, the candidate must complete the form available in annex VI of the decree, and send it to the training organization. The exam must take place in the year preceding the expiry date of the PCR training certificate.

The knowledge test giving rise to the issue of the certificate takes different forms depending on the level, the sector of activity, the option or if the candidate has benefited from the reinforced training. All the examination procedures are provided for in article 8 of the decree.

Thus, for the theoretical part, the control of knowledge is done by MCQ, except within the framework of the reinforced training or a teaching validated by an adapted diploma for which the theoretical examination is presented in the form of written tests with answers. to open-ended questions.

For the technical part, candidates must in particular pass an individual oral test, except for candidates whose training is provided within the framework of a course validated by a diploma mentioned in article 5 of the decree.


3) Issuance of the certificate:

At the end of the knowledge check, and if the candidate passes, a certificate of training as a competent person in radiation protection is issued to him by the certified training organization, no later than one month after the date of the exam.

This certificate is valid for 5 years from the date of the knowledge check for initial training, and from the expiry date of the previous certificate for renewal training. The list of information that must appear on the certificate is set out in article 9 of the decree.

A “bridge” mechanism is provided for in article 10 of the decree, allowing persons holding a valid certificate to extend their fields of competence, after having followed a “bridge training”. If the candidate succeeds in this bridge training, a new, up-to-date certificate is issued to him. Note: the date mentioned on the new certificate corresponds to the expiry date of the previous certificate.


II- Concerning OCRs (Organizations Competent in Radiation Protection: Articles 15 to 18 of the Order)

1) Certification of the organization competent in radiation protection:

The missions and skills of the organizations competent in radiation protection are the same as those of the PCRs (articles R4451-123 of the Labor Code et R1333-19 of the Public Health Code).

The competent radiation protection organizations must meet the requirements defined in Appendices VIII and IX of the order. Annex VIII concerns in particular the administrative, legal and economic information or even the organizational and material criteria that the organizations must respect in order to be able to benefit from certification. Appendix IX sets the report model for services provided by a radiation protection adviser on behalf of a third party.

Finally, the certification process and procedures for organizations competent in radiation protection are set out in appendix VII of the order.

The certificate issued by the certifying body to the competent radiation protection body must be written in French and specify the scope of the latter (article 16 of the order).

Finally, the organization competent in radiation protection is responsible for identifying and listing the various PCRs as well as the people who coordinate all the actions implemented by the organization to fulfill the missions entrusted to it under thearticle R. 4451-123 of the labor code etarticle R. 1333-19 of the public health code  (article 17 of the decree). Once drawn up, this list must be communicated to the certifying body. It is the same with each modification of this list.


2) Radiation protection adviser acting under an OCR (competent organization in radiation protection):

Article 18 of the order provides for the terms of appointment as well as the skills of the radiation protection adviser acting as a body competent in radiation protection. The appointment of this adviser must be the subject of a written contract concluded with the company for which he works.

The organization competent in radiation protection must, in particular, send an annual report of the activities it conducts to each of the companies for which it intervenes.


3) Concerning the certifying bodies of bodies competent in radiation protection:

The terms and conditions for accrediting bodies certifying bodies with competence in radiation protection are provided for in article 14 of the order. They must be accredited by COFRAC or by another body provided for inarticle R4724-1 of the Labor Code.

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