Observation (CEACR) - adopted 2015, published 105th ILC session (2016)

Radiation Protection Convention, 1960 (No. 115) - Japan (Ratification: 1973)

Other comments on C115

Observation

2017
2015
2005

Direct Request

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The Committee notes the observations made by the Japanese Trade Union Confederation (JTUC–RENGO), the Japan Business Federation (NIPPON KEIDANREN), communicated with the Government’s report, as well as the Government’s reply to both.

General observation of 2015. The Committee would like to draw the Government’s attention to its general observation of 2015 under this Convention, and in particular the request for information contained in paragraph 30.

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. The Committee notes the statement of the JTUC–RENGO that, due to the accident at the Fukushima power plant following the earthquake in 2011, an Ordinance on special measures was issued that raised the emergency radiation exposure dose limit to 250 mSv. Workers engaged in emergency work under that Ordinance, and accordingly mid- to long-term dose management must be implemented by the Government for workers whose exposure exceeded the normal exposure limit (100 mSv over a five-year period). The Committee notes the Government’s statement that the Ordinance on special measures was in force between March and December 2011, and that when the nuclear reactors were stabilized, the emergency radiation exposure dose limit was returned to 100 mSv. The Government also indicates that based on lessons learned from the 2011 earthquake, it has promulgated an amendment to the Ordinance on the prevention of ionizing radiation hazards and the Ministerial Guidelines for maintenance and improvement of the health of emergency workers at nuclear facilities, which will come into force on 1 April 2016. Based on the concept that a certain margin should be adopted regarding the application of dose limits for regular radiation workers, employers may assign workers whose cumulative dose exceeds 100 mSv over five years to normal radiation works where additional exposure is controlled within 5 mSv a year if the workers are essential to maintain the safety of nuclear facilities. The Committee also notes that the amended Ordinance on the prevention of ionizing radiation hazards provides that the Minister of Health, Labour and Welfare may set a special dose limit (exceptional emergency dose limit) not exceeding 250 mSv in situations in which it is difficult to observe the dose limit of 100 mSv during the emergency works. The Ordinance provides that employers shall select exceptional emergency workers from among the nuclear disaster prevention workers specified in the Act on special measures concerning nuclear emergency preparedness.

The Committee refers to paragraph 37 of its general observation of 2015, which states that, in emergency situations, reference levels should be selected to be within, or if possible below, the 20–100 mSv band. Measures should be taken to ensure that no emergency worker is subject to an exposure in an emergency in excess of 50 mSv. As indicated in paragraph 22 of the general observation, response organizations and employers should ensure that emergency workers who, in exceptional situations, undertake actions 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 that they may be required to take. The Committee requests the Government to take further measures to ensure that the protection provided in the Convention applies to emergency workers. In this regard, it requests the Government to indicate the measures taken or envisaged to ensure that workers who may be exposed to the exceptional emergency dose limits do so voluntarily and only after being informed of the associated health risks. The Committee also requests the Government to provide detailed information on the measures taken, including long-term measures, to monitor those workers exposed to higher doses of ionizing radiation following the 2011 earthquake.

The Committee is raising other matters in a request addressed directly to the Government.

[The Government is asked to reply in detail to the present comments in 2017.]