Observation (CEACR) - adoptée 1999, publiée 88ème session CIT (2000)

The Committee takes note of the information provided by the Government in its report. Further to its previous comments, the Committee again would draw the Government's attention to the following points:

1. Article 1 of the Convention. The Committee notes the Government's indication that no codes of practice nor controlling bodies have been set up in order to put into effect the provisions of the Convention. The Committee, however, notes that the Advisory Committee on Radiation Protection, first established in 1979, has resumed functioning. It also notes the numerous functions of this Committee which are to advise the Minister on an educational programme for designated and other workers and the general public; to keep records of designated radiation workers, their terms of employment, transfers and medical examinations, and of sources of radiation, their type and location, as well as to register and to license industrial sources; to devise an emergency plan in the case of accidents involving radioactive materials; etc. The Advisory Committee is also assigned to review the Radiation Protection Act 1971-11, to make recommendations applicable to the current national situation in Barbados, to prepare a detailed radiation protection programme for Barbados, and to develop a draft radiation policy for consideration by the Ministry. In view of the numerous functions of the Advisory Committee, the Government is requested to indicate the measures proposed or discussed in this Committee in order to take the necessary action to fulfil the obligations under the Convention. Moreover, the Committee asks the Government to indicate whether the Advisory Committee constitutes a tripartite body, composed of representatives of employers, workers and government and, if this is the case, to provide information on the manner consultations are held with the representatives of employers and workers regarding the measures to be taken in application of the Convention.

2. Article 2. The Committee notes the Government's indication that most of the work involving exposure to ionizing radiation was in the medical field, but that the number of industrial applications of radiation in Barbados is beyond its knowledge. In view of the activities of the Advisory Committee which are, inter alia, to keep records of designated radiation workers and to register and to license industrial sources of radiation, the Committee requests the Government to supply information on the activities of the Advisory Committee in this respect, in particular with regard to the assessment of main criteria to fix the threshold level above which the Convention is applied in the country.

3. Articles 3 and 6. The Committee recalls the comments it has been making for many years in relation to the provisions of these Articles of the Convention. It therefore wishes to recall once again that all appropriate steps shall be taken to ensure effective protection of workers against ionizing radiation and, to this effect, maximum permissible doses of ionizing radiation should be kept under constant review in the light of current knowledge relevant to implement effective protective measures. As regards the levels referred to in Article 6 of the Convention, the Committee recalls that they should be fixed with due regard to the relevant values recommended from time to time by the International Commission on Radiological Protection (ICRP). In this connection, the Committee refers again to its general observation of 1992 under the Convention, and would draw the Government's attention to the revised dose limits for exposure to ionizing radiation established on the latest physiological findings by the ICRP in its 1990 recommendations and contained also in the Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources, developed under the auspices of the IAEA, ILO and WHO, and three other international organizations, which are based on the ICRP recommendations. The Government is therefore requested to indicate the steps taken or being considered in relation to the matters raised in its general conclusion to the general observation of 1992 relevant to the implementation of measures ensuring an effective protection of workers exposed to ionizing radiation in the course of their work.

4. Article 4. The Committee notes that section 5, paragraph 1, of the Radiation Protection Act 1971-11 empowers the Minister of Health to give directives regarding protective measures to be taken against ionizing radiation as well as the time limits within which such measures shall be taken. The Committee requests the Government to indicate whether such directives have been issued and, if so, to provide a copy of these ministerial directives.

5. Article 5. The Committee notes with interest the Government's indication according to which a remote computerized brachytherapy afterloading system, type "Selectron HDR", has been installed in 1990 which reduces the number of workers dealing with the source of radiation to an extent that the probable exposure to radiation turns to zero. The Committee would ask the Government to indicate the fields in which this system is used and to supply information as regards experiences collected in applying this system.

6. Article 7. The Committee notes the Government's indication that no workers under the age of 16 are engaged in radiation work. The Committee accordingly would request the Government to indicate the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving ionizing radiations. The Committee, however, recalls Article 7, paragraph 1, providing for the fixation of appropriate levels of exposure for workers aged at least 18 and who are directly engaged in radiation work. The Government is therefore requested to indicate the measures taken or contemplated to fix the maximum permissible dose limit for those workers in order to ensure effective protection of their health and safety.

7. Article 8. The Committee notes the Government's indication according to which workers who are not directly engaged in radiation work are also monitored and that their exposure reports show very low values or no radiation value. The Committee recalls the provision of Article 8 obliging every ratifying State to fix appropriate levels of exposure in the light of knowledge available at the time for the group of workers not directly engaged in radiation work. It accordingly would ask the Government to indicate measures envisaged in order to fulfil its obligation under this Article of the Convention.

8. Article 9. The Committee notes the information supplied by the Government according to which an audible alarm system exists in the treatment room as well as a door interlock switch which, to the understanding of the Committee, interrupts the entry of radiation in the case of an inadvertent entry. As the Committee understands it, this security system only becomes effective in emergency situations. The Committee, however, recalls Article 9, paragraph 1, which provide for appropriate warnings at the workplace to indicate the presence of hazards from ionizing radiations as well as for the dissemination of information to the workers in this regard. The Government is therefore requested to indicate measures taken or contemplated in application of Article 9, paragraph 1, of the Convention. Regarding the application of Article 9, paragraph 2, of the Convention, the Committee notes the Government's explanations under Article 10 of the Convention according to which qualified workers employed in a hospital setting are presumably aware of the occupational hazard of radiation exposure. Nevertheless, written instructions are available for personnel dealing with patients treated with large doses of radioactive iodine-131. In view of this information, the Committee would point out that all workers have to be instructed in the precautions to be taken for their protection as regards their health and safety. In this regard, it would draw the Government's attention to section 2.4 of the ILO Code of practice for the radiation protection of workers (ionizing radiation) which contains general principles for informing, instructing and training of workers. The Government therefore is requested to indicate the measures taken or contemplated to ensure that workers are adequately instructed in the precautions to be taken for their protection. Nevertheless, the Committee wishes to know whether the security systems described above are installed in all areas where radiation work is performed.

9. Article 11. Noting the absence of information as to the application of this Article of the Convention, the Committee requests the Government to indicate the measures taken or envisaged providing for appropriate monitoring of workers in order to measure their exposure to ionizing radiations. The Committee ventures to call the attention of the Government to Paragraphs 17 to 19 of the Radiation Protection Recommendation, 1960 (No. 114), which proposes a number of measures to be taken in this connection.

10. Article 12. The Committee notes the Government's indication to the effect that all workers assuming duties at the hospital undergo a medical examination and are tested subsequently on a voluntary basis. It therefore wishes to point out that all workers directly engaged in radiation work shall undergo an appropriate medical examination prior to or shortly after taking up such work and subsequently undergo medical examinations at appropriate intervals. The Government accordingly is requested to indicate measures taken or envisaged ensuring that all workers directly engaged in radiation work profit from appropriate medical examination at the beginning of such an employment and at appropriate intervals. The Committee also requests the Government to provide information as to the nature and frequency of such medical examinations.

11. Article 13. In absence of information as well as provisions in application of this Article of the Convention, the Committee recalls that Article 13 of the Convention provides for certain action, as specified in its paragraphs (a) to (d), to be taken by the employer in emergency situations; in particular, the employer should take any necessary remedial action on the basis of technical findings and medical advice. In this regard, the Committee would call the Government's attention to its 1987 general observation under the Convention. The Committee would be grateful if the Government would indicate whether special provisions exist or are envisaged concerning the measures to be taken in abnormal situations in conformity with Article 13 of the Convention. With regard to emergency planning, the Committee would call the Government's attention once again to paragraphs 16 to 27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency and requests the Government to indicate the steps taken or contemplated in relation to the matters raised in its conclusions, particularly under paragraph 35 (c).

12. Article 14. The Committee notes the Government's indication that only pregnant women, particularly within the first 12 weeks of their pregnancy, are not assigned to duties where exposure to ionizing radiations is likely. The Government is requested to indicate the legal basis providing for such protection of pregnant women. However, the Committee wishes to point out that Article 14 of the Convention is applicable to all workers. It accordingly requests the Government to indicate whether and, if so, under which provision, it is ensured that a worker who is medically advised to avoid exposure to ionizing radiations is not assigned to work involving such exposure, or is transferred to another suitable employment if he or she has already been assigned.