Information for Class II licensed facilities

This page contains further information on topics that may be of interest to licensees including:

Documents relevant to Class II nuclear facilities

Act and regulations
Regulatory documents and licensing guides
Forms
Templates and Tools

Security of sealed sources

In 2014, REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources, was introduced to augment the security of sealed sources under the Nuclear Safety and Control Act (NSCA). The new requirements as set out in REGDOC-2.12.3 were implemented in 2015 for category 1 and 2 radioactive sources. The remaining categories (3–5) will be implemented in 2018. These augmented requirements are now a condition of Class II licences authorizing the use of sealed sources.

Below are the most commonly cited non-compliances by CNSC inspectors, based on the requirements set out in REGDOC-2.12.3.

  • Category 1–3 sources are required to have a minimum of two physical barriers to secure materials. (section 3.2.4)
    • Consistent and regular review of physical barriers is required to ensure barriers cannot be compromised. Guidance on implementing effective barriers can be found under additional resources.
  • Secure storage containers must be fastened to a wall or floor. (section 3.2.4)
  • Regular passcode updates are required, specifically for key or room access. (section 3.2.3)
  • Adequate mandatory security training (initial and refresher training) is required for all personnel handling and protecting radioactive sources and equipment. (section 3.3.2)
  • Employment verifications related to criminal records require review at least every five years. (section 3.3.3)

Licensees are encouraged to regularly review and update their security programs to ensure effectiveness and efficiency. When submitting new or updated security-related information to the CNSC, ensure it is properly protected. For questions or concerns, contact your project officer.

RSO certification

All licensees who operate Class II nuclear facilities or who service Class II prescribed equipment are required to appoint a certified radiation safety officer (RSO), in accordance with the Nuclear Safety and Control Act (NSCA) and its regulations. The RSO certification exam is tailored to the licensed activities and prescribed equipment at your facility. The intent of the examination is to assess whether you are “capable of performing the duties of the position” as per paragraph 15.04(1)(b) of the Class II Nuclear Facilities and Prescribed Equipment Regulations.

During a certification exam, RSO applicants (“candidates”) are tested on the following five areas of knowledge:

  • radiation physics
  • principles of radiation safety
  • general Class II operational activities and facilities that will be covered by the RSO certificate
  • relevant provisions of the NSCA and its ensuing regulations
  • radiation protection program of the facility and site-specific operations

The exam is conducted online and consists of a combination of multiple choice and short answer questions. The exam is open book and candidates may consult appropriate references as required.

Since certification of RSOs started in 2010, 22 candidates have failed the certification exam. Of these 22 candidates, 41% were requesting certification for a medical facility, 32 for a commercial third-party service company and 27% for an industrial facility. Following the exam, areas of weakness were identified by the examiner for each candidate. These have been examined globally to determine which topic areas give the most difficulty.

Figure 1 illustrates the percentage of the RSO applicants with weakness(es) identified in the five areas of knowledge, as indicated by the examiner.

Figure 1 – Common areas of candidate weakness, as indicated by CNSC Project Officer during exam

Overall, the most common area of weakness shared among all candidates was knowledge of the CNSC Act and Regulations. Another common weakness was related to the ability of the candidate to communicate their understanding of concepts, such as explaining the purpose of their radiation safety program and providing examples, as opposed to stating definitions or reading aloud the relevant regulations.

To better prepare for the RSO certification exam, candidates are encouraged to review any resources that might be useful in covering these topics, including their site-specific radiation safety program. Candidates must also be able to explain how their program aligns with the principles of radiation safety. In addition, a review of the NSCA and the relevant regulations, available on the CNSC website, is suggested.

Common non-compliances

When the CNSC performs an inspection at a facility, its inspectors assess the licensee's program against the applicable regulations and the licence conditions that appear in their licence. Any deficiencies that are noted are cited as non-compliances against the applicable regulation or licence condition. The frequency and types of non-compliances change as regulatory focus shifts or as different technologies are adopted. Regardless of these changes, inspectors have noted the most common non-compliances that occur from year to year. 

Figure 2: Top 10 regulations cited by inspectors during inspections of Class II nuclear facilities


NOTE: LC = Licence Condition / GN = General Nuclear Safety and Control Regulations / CII = Class II Nuclear Facility and Prescribed Equipment Regulations / RP = Radiation Protection Regulations

Figure 2 shows the top 10 cited regulations for Class II nuclear facilities between 2014 and 2016 and table 1 indicates what action would result in a non-compliance against each of these regulations. The frequency is represented by the percentage of inspections in which each regulation was cited at least once. It is possible for more than one non-compliance to be cited against the same regulation. However, for the purposes of figure 2, these were counted only once. It is clear from figure 2 that in many cases the same regulations are consistently cited from year to year.

Table 1: Description of the most commonly cited regulatory references

Regulatory reference Description of expectation Example of a non-compliance
GN 12(1)(c) All reasonable safety precautions are taken The licensee does not consistently ensure the room is empty when pressing the last person out button
LC 2917 Policies/procedures submitted to the CNSC are followed The licensee does not follow procedures listed in their licence
LC 2920 Policies/procedures are submitted to the CNSC The licensee has updated their procedures but has not informed the CNSC
CII 21(2) Required records are maintained The licensee has not maintained records of all servicing performed
RP 4 An adequate radiation protection program is in place The licensee does not have sufficient oversight of licensed activities
GN 12(1)(b) Required training is provided to staff The licensee has not provided ancillary staff with training commensurate with the role
RP 23 Radiation warning signs are posted as prescribed The licensee has not posted a warning sign on an enclosure containing nuclear substances
RP 21 Radiation warning signs are not posted where no radiation source is present The licensee has not removed the warning sign from an area where nuclear substances are no longer stored
CII 15(2) Door interlocks and last person out (LPO) are installed as prescribed The licensee has not installed a door interlock or LPO in an enclosure contained within the facility
CII 15.1 Replacement of radiation safety officer (RSO) is designated The licensee has not properly (in writing) designated a person who is qualified to replace the RSO

NOTE: LC = Licence Condition / GN = General Nuclear Safety and Control Regulations / CII = Class II Nuclear Facility and Prescribed Equipment Regulations / RP = Radiation Protection Regulations

Dose to workers

Each licensee that operates a Class II nuclear facility is required to have a radiation protection program. The radiation protection program ensures that contamination levels and radiation doses received by workers are monitored, controlled and maintained below regulatory dose limits, and kept at levels that are as low as reasonably achievable (ALARA). Licensees are expected to monitor worker doses and to designate as a nuclear energy worker (NEW) anyone who is likely to receive more than 1 millisievert (mSv) per year in the course of their work.

A total of 6,368 workers at Class II facilities had their occupational doses monitored in 2015. Of these, 4,978 workers were designated as NEWs. There are four main sectors in which Class II facilities can be categorized, the breakdown of which is given in figure 3.

Figure 3: Dose distribution by sector for all workers at Class II facilities reported in 2016


NOTE: BDL = Below detectable limit

Additional information relating to expectations for security while in transport was published in the Spring 2018 issue of the DNSR newsletter.

Additional resources

Presentations and Papers by staff in the Accelerators and Class II Facilities Division (ACFD)

Participating in outreach activities and disseminating information is an important aspect of the CNSC’s regulatory strategy. For technical presentations or papers, only the abstracts have been included here however copies of the presentations are available on request:

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