DAOD 4002-0, Nuclear and Ionizing Radiation Safety Management

Table of Contents

1. Introduction
2. Definitions
3. Policy Direction
4. Consequences
5. Authorities
6. References

1. Introduction

Date of Issue: 2000-05-31

Date of Last Modification: 2020-03-31

Application: This DAOD is a directive that applies to employees of the Department of National Defence (DND employees) and an order that applies to officers and non-commissioned members of the Canadian Armed Forces (CAF members).

Supersession:

• DAOD 4002-1, Nuclear and Ionizing Radiation Safety
• NDHQ Policy Directive P3/93, Nuclear Energy and Technology

Approval Authority: Assistant Deputy Minister (Infrastructure and Environment) (ADM(IE))

Enquiries: Director Nuclear Safety (D N Safe)

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2. Definitions

as low as reasonably achievable (ALARA) (niveau le plus bas que l’on peut raisonnablement atteindre)

A principle of radiation protection that refers to an exposure level to ionizing radiation as far below the dose limits as possible, consistent with the purpose for which the nuclear activity is undertaken, taking into account the state of technology, social and socioeconomic considerations, and military operational factors. (Defence Terminology Bank record number 695959)

authorization (autorisation)

A written document issued by ADM(IE) or D N Safe confirming that an office holder has the capability and obligation to ensure that a nuclear activity is safely managed in accordance with DAOD 4002-0, Nuclear and Ionizing Radiation Safety Management, Nuclear Safety Orders and Directives, and nuclear safety standards issued by D N Safe. (Defence Terminology Bank record number 695960)

authorization holder (détenteur d’autorisation)

An office holder in possession of an authorization issued by ADM(IE) or D N Safe for the conduct of a nuclear activity. (Defence Terminology Bank record number 695961)

international obligations with respect to nuclear non-proliferation (obligations internationales en matière de non-prolifération nucléaire)

Measures to which Canada has agreed respecting international control of the development, production and use of nuclear energy, including measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons, the Agreement Between the Government of Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons and the Protocol Additional to the Agreement Between Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons. (Defence Terminology Bank record number 695962)

military equipment (équipement militaire)

Any equipment used or to be used in connection with any military operation. (Defence Terminology Bank record number 43141).

military operation (opération militaire)

Any operation, training exercise, trial, manoeuvre, deployment, combat or related activity carried out by the CAF, and any activity of the DND or the CAF that is in direct or indirect support. (Defence Terminology Bank record number 43142).

nuclear activity (activité nucléaire)

Any activity that involves a nuclear substance or could result in the creation of a nuclear substance, any fission or fusion process, any emission of ionizing radiation by an X-ray device or other equipment, and any visit or associated transit of a nuclear-powered or nuclear-capable military platform of a foreign country. (Defence Terminology Bank record number 43155)

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3. Policy Direction

Context

3.1 Nuclear activities in Canada are regulated under the Nuclear Safety and Control Act (NSCA) and its regulations. The DND and the CAF are excluded under specific conditions from the application of the NSCA and its regulations. The exclusion order made by the Governor in Council states that “The Minister shall, taking into account the operational requirements of the Canadian Forces and the Department, establish and maintain requirements for the conduct of the military operations and the use of military equipment excluded by the Order that, to the extent practicable, are consistent with the requirements for health, safety, security and the protection of the environment established under the Act and the regulations made under the Act.”

3.2 The obligations of the Minister of National Defence under the NSCA exclusion order are met by the DND and the CAF self-regulating:

1. in accordance with this DAOD, Nuclear Safety Orders and Directives (NSODs) and nuclear safety standards; and
2. by conducting compliance assessments of DND organizations, CAF units and facilities that perform any nuclear activity.

3.3 DND managers and CAF commanders and commanding officers are responsible for:

1. exercising due diligence when conducting nuclear activities; and
2. ensuring compliance with this DAOD, NSODs and nuclear safety standards.

3.4 The safe management of nuclear activities requires the capability to respond promptly to incidents and accidents that could threaten human health or the environment. The degree of emergency response capability depends upon both the assessed probability of occurrences and the associated consequences. Due diligence is required in identifying hazards and implementing a response capability that maintains risks at levels as low as possible. It is equally important to demonstrate in a convincing manner to DND employees, CAF members and the public that:

1. nuclear safety is a priority for the DND and the CAF; and
2. the DND and the CAF can be relied upon to responsibly conduct nuclear activities.

3.5 Nuclear and ionizing radiation safety management responsibilities for DND employees and CAF members are set out in NSODs.

3.6 This DAOD does not apply to:

1. nuclear activities regulated by the Canadian Nuclear Safety Commission (CNSC) at the Royal Military College of Canada;
2. defence against the hostile use of nuclear and radiological weapons;
3. the medical exposure of a patient to ionizing radiation for diagnostic or therapeutic purposes;
4. equipment governed by the Radiation Emitting Devices Act, which produce only low intensity ionizing radiation during normal operation, e.g. television receivers; or
5. unprocessed naturally occurring radiation or nuclear substances.

Policy Statement

3.7 The DND and the CAF are committed to:

1. regulating, planning, committing resources for, managing and conducting nuclear activities within a safety framework consistent with the practices and standards of the CNSC and Health Canada, to the extent practicable in a military context;
2. protecting nuclear substances, and military equipment and information related to nuclear substances, from unauthorized possession or use, in accordance with Canada’s international obligations with respect to nuclear non-proliferation;
3. having nuclear expertise to effectively manage its obligations under this DAOD, NSODs and nuclear safety standards; and
4. establishing and maintaining an emergency response capability commensurate with the risks of conducting nuclear activities.

Requirements

3.8 The DND and the CAF must:

1. establish a comprehensive nuclear safety program that:
   1. minimizes human exposure to ionizing radiation and protects the environment;
   2. provides oversight at all organizational levels by appropriately qualified personnel;
   3. is suitably resourced; and
   4. has an emergency response capability for any nuclear activity;
2. foster a nuclear safety culture that encourages personnel at all levels in an organization to make nuclear safety a priority in all nuclear activities and that is characterized by:
   1. a positive attitude toward all aspects of nuclear safety, human health and safety, the environment and security;
   2. recognition of the invisible nature of ionizing radiation hazards and the responsibilities placed upon those personnel who have care and control of the sources of ionizing radiation;
   3. procedures to ensure that problems are promptly identified and corrected;
   4. the clear identification of nuclear safety responsibilities for all personnel at all levels;
   5. appropriate training and qualification programs; and
   6. an appropriate flow of information about nuclear safety amongst all levels in the organization;
3. ensure compliance with Canada’s international obligations with respect to nuclear non-proliferation, including the accounting of nuclear material to the CNSC for the purposes of meeting Canada’s safeguard obligations to the International Atomic Energy Agency;
4. promulgate NSODs and nuclear safety standards that provide detailed direction, responsibilities, instructions and requirements governing nuclear and ionizing radiation safety management;
5. ensure DND organizations and CAF units obtain authorizations for any nuclear activity before commencing it;
6. establish a compliance management process that assesses compliance with this DAOD, NSODs and nuclear safety standards;
7. ensure nuclear and ionizing radiation safety assessments, commensurate with the probability of occurrences and potential consequences of nuclear and ionizing radiation accidents, are conducted and that such assessments:
   1. determine the nuclear safety requirements and control measures to be implemented in order for the nuclear activity to occur safely; and
   2. are reviewed periodically within a timeframe directed by ADM(IE) in order to reflect changes that would invalidate the previous assessment conclusions, e.g. changes in technology understanding and the demographics of surrounding areas affected by non-normal conditions;
8. ensure responsibility for nuclear safety is understood and applied at all levels in organizations involved in nuclear activities;
9. establish radiation dose limits that recognize the unique operational mandate of the DND and the CAF, taking into account:
   1. the requirement to justify the overall benefit of a nuclear activity prior to authorizing its conduct;
   2. Canadian radiation protection regulations and standards established pursuant to the NSCA and the Radiation Emitting Devices Act, to the extent practicable; and
   3. the obligation that doses are kept as low as reasonably achievable (ALARA);
10. control ionizing radiation sources and emitting devices, including their procurement, use, storage, decommissioning and disposal, in accordance with this DAOD, NSODs and nuclear safety standards; and
11. radiologically decommission associated real property and immovables on completion of a nuclear activity.

3.9 D N Safe must notify ADM(IE) of any non-compliance with this DAOD, NSODs or nuclear safety standards.

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4. Consequences

General

4.1 Should clarification of the policy statement, requirements or authorities set out in this DAOD be required, DND employees and CAF members may seek direction through their channel of communication or chain of command, as appropriate. The anticipated results set out in the policy statement may not be achieved by the DND and the CAF if the requirements specified in this DAOD are not properly implemented. Not achieving the anticipated results could affect the ability of the DND and the CAF to ensure that the CAF is prepared to undertake missions for the protection of Canada and Canadians and the maintenance of international peace and stability.

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5. Authorities

Authority Table

5.1 The following table identifies the authorities associated with this DAOD:

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6. References

Acts, Regulations, Central Agency Policies and Policy DAOD

• Canada Labour Code, Part II
• Canadian Environmental Protection Act, 1999
• Export and Import Permits Act
• Nuclear Safety and Control Act and its Regulations
• Radiation Emitting Devices Act
• Transportation of Dangerous Goods Act, 1992
• Order-In-Council P.C. 2000-1421 of 13 September 2000
• Treaty on the Non-Proliferation of Nuclear Weapons
• Agreement Between the Government of Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons (INFCIRC/164)
• Protocol Additional to the Agreement Between Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons (INFCIRC/164/Add.1)
• DAOD 1000-8, Policy Framework for Safety and Security Management

Other References

• Nuclear Safety Orders and Directives
• D N Safe intranet site