A Guide to Field Inspection — Preparation

June 29, 2023

With the increased costs associated with non-compliance, it is more important then ever to ensure your authorized users are prepared to face a CNSC inspector out in the field.  Having a successful inspection starts with being well prepared. 

Let’s start with the gauge itself.  Nuclear gauges used in the field are required to display the following labels.

• Radiation warning symbol (trefoil) and the words “Rayonnement – Danger – Radiation”.
• The name (Cs-137 / Am-241/Be)
• The quantity (radioactivity)
• Date of measurement (assay date)
• The form of the nuclear substance (solid)
• Contact name or job title and telephone number for emergencies

The emergency contact name or job title and telephone number must be an internal number or contracted emergency response provider. You cannot use CANUTEC for this number.  CANUTEC can only be used for transport and only after you have registered with them. 

Next, let’s focus on the transport package.  The transport package is designed to meet the requirements of what is called a Type A package.  A Type A package is a relatively simple package designed, tested and certified to meet normal conditions of transport, by the manufacturer of your gauge.   This documentation is required to be maintained on file at the licenced location.  It does not need to accompany the gauge into the field. The transport package will maintain its certification as long as it is in good condition.  Cracks, holes, broken hinges or clasps may void this certification and can lead to non-compliances. Train your workers to look after these cases!  The case is required to be labelled in accordance with the IAEA and TDG regulations.  The required labels are:

• Yellow-II hazard labels with radioisotopes, radioactivity and transport index indicated on two opposite sides of the package
• UN Number and proper shipping name.  This label must appear beside the Yellow-II hazard label on both sides of the package
• The words “Type A”
• The VRI code, “USA”
• Consignor and consignee address

Do not put any more or different labels on the exterior of the package.  All labels must be legible and visible at all times. 

Hang this poster at your storage area so that your employees can confirm all labels are present before heading out into the field.

Download 11" x 17" Poster

Download 8.5" x 11" Poster

Field documents: There are only 4 documents required to accompany your gauge out into the field.  These are:

• Complete copy of current CNSC licence
• Current emergency procedures
• TDG shipping document
• TDG training certificate

The TDG training certificate, which is typically formatted as a wallet card, is required to be on the person of the individual who is transporting the device.  Under Section 6.3(3) of the TDG regulations, this certificate is required to be signed by both the employee and employer in order to be valid.

Lastly, let’s ensure the authorized user heads out into the field with all of the required equipment. This could include:

• Dosimeter or shot count sheets for tracking dose
• Extendable mirror or survey meter for checking for shutter closure
• Survey meter.  Mandatory if going further then 2 hours from where survey meter is stored

If within your radiation safety program you have committed to other equipment, make sure to include that as well.

Finally, lets prepare the worker themselves.  The following items are expectations of the CNSC for the worker.

• Is the gauge under direct surveillance at all times? Must be always within a couple of meters of the device.
• Is the device secure when not in use. Locked in vehicle.
• How do they ascertain radiation doses? Are they assigned and wearing a dosimeter or keeping track of shot counts.
• Is the worker a Nuclear Energy Worker (NEW) and have they been informed in writing of their status?
• Are they limiting exposure to all persons while handling or operating the gauge.  Control the area around the work.
• Is the worker following company policy and procedures.  A standard operating procedure makes this easier.
• Was the Type A package secured when being transported.
• Does the worker have a survey meter and is familiar with how it works?  If not, how are they confirming shutter closure?
• If no survey meter, is one available within two hours of need?
• When in transport, is the transport binder within arms reach of the driver?

Inspectors are not mean or nasty people, but there is an expectation that the worker knows what they are doing and can speak knowledgeably about these items.  Go over these questions with your workers until they know the answers to each of them without fail.  Better they stumble a couple of times with you then when they are getting inspected.  Successful inspections start with preparation!