Editorial

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• Better safe than sorry
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Better safe than sorry 

Back in 2001, Publication 86 (ICRP, 2002a) dealt with the prevention of accidental exposures of radiotherapy patients. In a sense, that report touched upon two important areas that were somewhat outside our ordinary turf, but definitely worth the attention. One of these areas concerns the nature and philosophy of regulating risks, and the other area concerns the responsibility for safety within a licensee organisation.

The Commission is an advisory body, not a regulatory organisation, so while many ICRP members are or have been regulators, the Commission is not primarily concerned with regulatory methodology. Nevertheless, the 1990 Recommendations in Publication 60 (ICRP, 1991) did include a chapter on national (regulatory) infrastructure. Publication 75 (ICRP, 1998a) on occupational exposures provided some more comments, Publication 86 (ICRP, 2002a) dwelled on the same concepts, and the present report also touches on this.

The main message in the present context of accident prevention is that successful regulation requires mutual trust between trustworthy and equal parties. In other words, prescriptive regulations can never work in the long run. The operator, not the regulator, must take the primary responsibility for safety, and the job of the regulator is to ensure that the operator is capable of taking that responsibility, not to handle the actual safety cases.

In Publication 86 (ICRP, 2002a) and in the present publication, the importance of incidence reporting is underscored. A successful programme of incidence reporting obviously requires that licensees are reasonably convinced that regulators will use such reports to improve safety, not to find culprits for punishment. Very few operators would be likely to display their shortcomings publicly if their candour were ‘rewarded’ with punishments. Conversely, as amply shown in the aviation industry, real and significant safety improvements are achieved if people learn of problems encountered by their peers and how these problems can be tackled.

This is not to say that punishments are unnecessary. Regulators (and legislators) need to have a full complement of tools, including punishments when required but that tool should be reserved for those who try to hide problems, and not for those who turn to the regulator for help and advice in an honest effort to improve their ways.

So, who is responsible for safety in a licensee organisation? The first reply should, of course, be ‘everybody’. Safety culture is defined in the International Basic Safety Standards as ‘the assembly of characteristics and attitudes in organisations and individuals which establishes that, as an over-riding priority, protection and safety issues receive the attention warranted by their significance’. This requires that every employee feels that they have a personal share of responsibility. In Publication 55 (ICRP, 1989) on optimisation methods and later in Publication 81 (ICRP, 2000) on disposal of long-lived radioactive waste, this was described as ‘to engender a state of thinking in everyone … such that they are continually asking themselves the question: ‘Have I done all that I reasonably can to reduce these radiation doses?”.

Another type of reply focuses on power, and specifically the power to change unsatisfactory conditions. We can all contribute to safety, but individual employees are not always able to take corrective action. Thus, while everybody has a responsibility, the management has a particular role.

Publication 60 (ICRP, 1991) emphasises that ‘The primary responsibility for achieving and maintaining a satisfactory control of radiation exposures rests squarely on the management bodies of the institutions conducting the operations’. All too often, we read in the newspapers that a worker in some organisation caused an accident because of poor training, poor performance, or something suchlike. But was it really the individual worker’s fault? Should not the top management have ensured that there was a quality system in place such that all workers have the necessary training and are capable and willing to perform adequately? And if an error is committed in spite of this, should there not have been redundant mechanisms to ensure that a single failure would not lead to disaster? The very top management may not be involved in day-to-day operation, but they can never evade the over-riding responsibility for providing a system and an organisation that are inherently safe.

Finally, a third type of reply brings us back to the medical arena where we started: in such establishments, those who are employed specifically to handle radiological protection issues may also have a particular responsibility for safety.

At installations in the nuclear fuel cycle, there are usually ‘safety experts’ and even ‘safety departments’ where engineering and behavioural aspects of safety are combined in a fruitful manner. Other large industries often have similar resources at hand. Such ‘safety departments’ are usually responsible for safety in the sense that they advise the top management and help management at all levels with their expertise.

However, at many hospitals and universities, there is no specific department or person with this particular experience. Thus, it often falls on the radiological protection experts in the organisation to provide advice in the area of safety as well as radiological protection. Publication 64 (ICRP, 1993) on potential exposures and, in particular, Publication 76 (ICRP, 1998b) with applied examples from outside the nuclear fuel cycle emphasise the importance of safety issues and the possible safety responsibility of those otherwise concerned with radiological protection. The Commission hopes that the present report will contribute to their successful handling of the complicated safety issues in connection with high-dose-rate brachytherapy units.

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References 

1. ICRP, 1989. Optimization and decision-making in radiological protection. ICRP Publication 55, Ann ICRP 20(1).
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2. ICRP, 1991. Recommendations of the International Commission on Radiological Protection. ICRP Publication 60, Ann ICRP 21 (1–3).
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3. ICRP, 1993. Protection from potential exposure: A conceptual framework. ICRP Publication 64. Ann ICRP 23(1).
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4. ICRP, 1998a. General principles for the radiation protection of workers. ICRP Publication 75. Ann ICRP 27 (1).
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5. ICRP, 1998b. Protection from potential exposure: Application to selected radiation sources. ICRP Publication 76. Ann ICRP 27 (2).
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6. ICRP, 2000. Radiation protection recommendations as applied to the disposal of long-lived solid radioactive waste. ICRP Publication 81. Ann ICRP 28 (4).
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7. ICRP, 2002a. Prevention of accidents to patients undergoing radiation therapy. ICRP Publication 86. Ann ICRP 30 (3).
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