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Radiation Protection Convention, 1960 (No. 115) - Egypt (RATIFICATION: 1964)

Other comments on C115

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General observation of 2015. The Committee wishes to draw the Government’s attention to its general observation of 2015 under this Convention, and in particular to the request for information contained in paragraph 30 thereof.
Article 2 of the Convention. Application of the Convention to all activities involving exposure of workers to ionizing radiations in the course of their work. Emergency workers. In its previous comment, the Committee requested the Government to provide additional information on measures taken to optimize protection during accidents and emergency work. The Committee notes that in its report, the Government refers to, in addition to the Labour Code, the Ministerial Order No. 211 of 2003 which relates to the safety thresholds, necessary conditions and requirements to fend off biological, chemical, mechanical and physical hazards, and to safeguard the working environment. The Government indicates that section 10(6) of Ministerial Order No. 211 of 2003 specifies that the management of an undertaking shall be required to prepare an emergency plan to address radiation accidents during the operation usage, handling and storage of ionising sources which may expose workers and the environment to high levels of ionising pollution. A group of employees should be trained to implement the plan and carry out tests on its different elements. Under section 10(6), any person who is licensed to use or to keep ionizing substances shall notify the competent authority, as soon as an accident occurs, which may expose any person to a set of radiation beyond the permissible threshold, as soon as the accident occurs while indicating the details of the accident, and the causes which led to its occurrence.
In this respect, the Committee would like to draw the attention of the Government to paragraphs 17–23 and 36–37 of its 2015 general observation, where it indicates that individual exposure in emergency situations should be optimized, with appropriate boundaries of reference levels. Such reference levels should be selected to be within, or if possible below, the 20–100 mSv band. Measures are to be taken to ensure that no emergency worker is subject to an exposure in an emergency in excess of 50 mSv, except in certain specific and exceptional situations (described in paragraph 37 of the general observation). Response organizations (as defined in note No. 19 of the general observation, “a response organization is an organization designated or otherwise recognized by a State as being responsible for managing or implementing any aspect of an emergency response”) and employers should ensure that emergency workers who undertake actions in exceptional circumstances in which the doses received might exceed 50 mSv do so voluntarily, have been clearly and comprehensively informed in advance of the associated health risks, as well as of available measures for protection and safety and that they are, to the extent possible, trained in the actions they may be required to take. In light of the indications contained in the abovementioned paragraphs of its 2015 general observation, the Committee requests the Government to provide information on the boundaries of reference levels for the exposure of workers in emergency situations, as well as the exceptional circumstances and the conditions in which emergency workers might be subject to an exposure in excess of 50 mSv.
Article 14. Discontinuation of assignment to work involving exposure to ionizing radiation pursuant to medical advice and alternative employment. With reference to its previous comments, the Committee notes the indication of the Government that pursuant to section 2 of the Social Security Act No. 135 of 2010, which entered into force on 1 January 2012, the provisions of the Social Insurance Act No. 79 of 1975 related to medical treatment and care have not been repealed and remain valid. In this regard, the Committee had previously noted that pursuant to Act No. 79, workers are entitled to alternative employment or maintenance of income in the event they have been diagnosed with an occupational disease. The Committee recalls that, in accordance with this Article of the Convention, the Government must take all the necessary measures to ensure that workers are not employed or do not continue to be employed in work that may expose them to ionizing radiation contrary to qualified medical advice, including before any occupational disease is diagnosed. In addition, paragraph 27 of the Radiation Protection Recommendation, 1960 (No. 114), provides that if, as the result of such medical advice, it is inadvisable to subject a worker to further exposure to ionising radiations in that worker's normal employment, every reasonable effort should be made to provide such a worker with suitable alternative employment. The Committee also draws the attention of the Government in this respect to paragraphs 27, 28 and 40 of its 2015 general observation. The Committee requests the Government to provide information on the measures taken or envisaged to ensure that workers shall not be employed or continue to be employed in work liable to expose them to ionizing radiations, contrary to medical advice, even before any occupational disease is diagnosed. The Committee also invites the Government to supply information with regard to the efforts that should be made to provide such workers with suitable alternative employment.
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