High reliability – Safety at ANSTO

ANSTO provides a safe and healthy workplace for all workers and other persons under its control, through planned strategies to prevent death, work-related injury and ill health. We are each responsible for our own safety, that of our colleagues and of the public.

Through core values, ANSTO’s senior leadership is committed to delivering excellence in our Work, Health and Safety (WHS) performance. ANSTO remains committed to our overriding safety goal of ‘zero tolerance for harm to anybody, anywhere, anytime.’ Leadership is an important aspect in achieving continuous improvement in safety. The Executive Work, Health and Safety and Environment (WHSE) Committee includes all members of the ANSTO’s Group Executive as well as ANSTO’s Chief Nuclear Officer. The committee is responsible for providing oversight and setting direction on behalf of the ANSTO Executive for safety and environment strategies, initiatives, incident management processes targets and reporting. They provide continued leadership and oversight by monitoring site-wide risks and learning from incidents that had the potential of a major impact to people, plant/equipment and environment and by endorsing key safety-related projects and initiatives.

ANSTO continued to explore the integration of complementary functions and the sharing of key information during 2019-2020. The High Reliability team provides the safety expertise that supports ANSTO in delivering organisational excellence in safety, ensuring compliance to all regulatory safety requirements whilst promoting the use of best available techniques and practices to deliver a highly reliable organisation. The group provides best practice support of high quality work and services to its customers, by well-respected high calibre staff, enabling ANSTO to deliver outcomes in a safe and reliable manner. Functions within the group include Radiation Protection Services (RPS), Work Health and Safety (WHS), Emergency Management (EM), Health and Hygiene, Operational Sustainability and Continuous Improvement. The broad range of skills and expertise explicit in the group is in response to the varied portfolios of high hazard activities undertaken at ANSTO. ANSTO has eight distinct divisional activities, geographically located across three campuses, each with its prevailing circumstance requiring a tailored approach to safety due to the hazard profile and business outcomes required. ANSTO is also built upon a strong organisational governance and compliance foundation. The hierarchy of safety responsibility at ANSTO is shown in Figure 3.

Strategy

The ANSTO Work Health and Safety Strategy 2018-2022 (the strategy) establishes key objectives and actions for the continuous improvement of safety performance at ANSTO. The Strategy adopted four key objectives:

1. Our workers will be value driven, prepared, trained, aware and engaged;

2. Our workplaces will be managed on a risk informed basis, fit for purpose, reviewed, maintained, compliant and cover all areas where our people work;

3. Our systems, processes and initiatives will be integrated and of high integrity, enabling, informing, measurement based and validated;

4. Our stakeholders will be engaged to improve WHS performance.

To achieve these objectives a number of actions have been identified and are being monitored by the WHSE Committee.

Occupational hygiene

Occupational hygiene focuses on the risk management of health hazards in the workplace by measuring potential exposure to chemical, physical and biological hazards to assist in the design and implementation of control strategies to prevent ill health to workers.

ANSTO has implemented an occupational hygiene monitoring program that assesses exposure risks to current and legacy hazards in line with the legislative requirements. This function provides support across ANSTO operations and projects by characterising and assessing the risks of these hazards. During 2019-2020 this program has been expanded to include additional monitoring of other high risk chemicals according to the Globally Harmonised System of classification and labelling of chemicals (GHS).

The Health & Wellbeing Centre and Occupational Hygiene have been working closely to ensure ANSTO’s health assessment activities are risk based and fit for purpose. A part of this is ensuring that our people are equipped with equipment that is fit for purpose.

The hazards register continues to be a communication tool that lists known hazards, building information and corporate knowledge. ANSTO has an increasing need to record, trend and analyse health-related data. A software solution (Cority) will be implemented during 2020. This project has the objective to record, manage, track and trend this important information for occupational hygiene, medical/health and rehabilitation.

Key WHS achievements

The key WHS achievements for 2019-2020 for the Organisation are:

1. Ongoing Accreditation of all ANSTO campuses (NSW and Victoria) to ISO 45001 - Occupational Health and Safety Management Systems.
2. The implementation of Safety Conversations that aim to promote a positive safety culture and by engaging workers in two way communication about workplace safety.
3. Conservative approach in the preparation of the Lucas Heights Campus for the first ever Catastrophic Fire Danger days in NSW by closing the campus to all staff not required for essential operations.
4. Response to the evolving COVID-19 global pandemic with the implementations of alternate working arrangements and controls in a changing environment. This resulted in no positive COVID-19 cases recorded for ANSTO staff.
5. Capital projects, major shutdowns and maintenance tasks were delivered without significant injuries or requiring regulatory intervention.
6. The ANSTO influenza vaccination program was expanded this season in light of the COVID-19 pandemic to assist in protecting the health of our workers.

Safety awareness

All workers are continually engaged and informed through a risk-based WHS focus program combined with safety alerts. The ANSTO STAR (Stop Think Act Review) Safety Essentials were launched in January 2020 as the Safety Focus program for 2020. The program provides information on how staff can manage the safety risk of ten key areas. These ten key areas set out the minimum requirement for ANSTO staff to manage safety risks. In 2019-2020 the areas were electrical safety, confined space work, contractor management, mental health and wellbeing during COVID-19 and radiation protection.

Key WHS alerts during 2019-2020 included: welding fumes, lessons learnt from electrical near miss incident, lessons learnt from falling object near miss incident and working with hazardous chemicals.

In Australia, October is National Safe Work Month, a time for organisations to make their commitment to improving safety and health in their workplace. The theme of this year’s program was Mind, Body Role, a total employee health approach focusing on the overall health, safety and wellbeing of workers and their families. This approach provides a gateway to a range of benefits and initiatives designed to support workers in developing psychological, physical and emotional wellbeing.

Health and wellbeing of our people

The ANSTO Occupational Health and Wellbeing Centre provided advice, services and a comprehensive health program to workers throughout the 2019-2020 financial year. The Centre is staffed by one Occupational Health Nurse role and a Rehabilitation Case Advisor role supported by a contracted Physiotherapist and Occupational Physician. The health programs included men’s and women’s health, influenza vaccinations, travel and work immunization, workplace conditioning programs, ergonomic and work station assessments and mental health first aid. The Occupational Health and Wellbeing Centre is a central point of support for all aspects of workers' health.

The ANSTO Occupational Physician, Occupational Site Nurse and Radiation Protection Services Manager attended specialist training in emergency preparedness and medical management of radiation incidents at the Radiation Emergency Assistance Center/Training Site in the United States. This training provided industry best practice in response to radiation medical emergencies.

The quarterly ANSTO Health and Well Being Newsletter continued throughout 2019-2020 providing practical health guidance for workers and their families

The engagement of a health care provider closer to the Clayton Campus has been well received by workers. The Valewood medical clinic has engaged with Clayton workers providing an effective and convenient service.

The early intervention strategies implemented by the ANSTO Health Centre continue to support the timely return of workers to pre-injury duties and keep workers engaged with ANSTO during the treatment and rehabilitation processes. The program focuses on providing early assessment and treatment to reduce the consequences of all injuries regardless of an accepted worker’s compensation claim. This has proved successful in meeting ANSTO’s goal of returning workers to normal duties as productive team members as soon as possible. The ANSTO rehabilitation program continues to be compliant with the requirements of the SRA Act demonstrating effective procedures and programs are in place.

Workers' compensation

The ANSTO premium is dependent on the aggregate premium pool (the total premium to be charged across all Commonwealth agencies) and ANSTO’s claim performance. ANSTO premiums are summarised in Table 6.

Regulator engagement - Comcare

The main Safety Regulator that ANSTO engages with for WHS oversight is Comcare.

ANSTO continued to work closely with Comcare during 2019-2020, with Comcare representatives visiting ANSTO campuses, gaining additional insights into ANSTO. These visits gave ANSTO insight into best practice activities and allowed us to gain a better understanding of the role of the regulator. This resulted in improved work health and safety outcomes for the business and key projects. Comcare continued to provide support, information and guidance regarding WHS legislative requirements to ANSTO.

ANSTO is required to report incidents to Comcare under the section 35 of the WHS Act. This section defines a notifiable incident as:

• the death of a person, or
• the serious injury or illness of a person, or
• a dangerous incident.

During 2019-2020 eight incidents were notified by ANSTO to Comcare outlined in Table 7.

An ANSTO Contractor also notified Comcare and SafeWork NSW when asbestos air monitoring being performed during non-friable (bonded) asbestos removal work detected fibres above the action limit for respirable fibres. The monitoring results confirmed that the fibres were not indicative of asbestos above the action limit. The How to safely remove asbestos Code of Practice, SafeWork Australia (view code at https://bit.ly/2S2PjOJ), requires licensed asbestos removalists to take certain action depending on the respirable fibre levels measured. The action level dictates what controls and actions need to be implemented.

Comcare also received an anonymous complaint of bullying and psychological hazard in an ANSTO workplace. Comcare found that ANSTO complied with their duties under the WHS Act and Regulations.

Training

ANSTO offers training in a range of work, health and safety related subjects to all workers. WHS training courses aim to provide the necessary information, instruction and skills to workers to assist them in meeting their legislative responsibility and to undertake work without risk to themselves, others and the workplace.

Incidents

The ANSTO Incident Management System consolidates operational, environmental and safety incidents and any associated actions into one location. The system has allowed for improved trending and data analysis for safety-related incidents which has supported evidence-based decision making. The primary focus of the ANSTO investigation process is to determine what caused the incident and ensure the appropriate response and controls have been adopted in each case to prevent a reoccurrence.

Workers are encouraged to report all incidents following ANSTO’s ‘No Blame – Full disclosure’ principle. ANSTO continues to promote the reporting of all incident types. Refer to Table 8. The upward trend in reports indicates a strong reporting culture.

The ANSTO Incident Management System continues to provide enhanced analysis and trending of incidents including both leading and lagging incident types. Leading incidents are those where there has been no impact to people, facilities or equipment this includes Near Misses/Hits, Hazards and Observations. Lagging incident types have had an impact to people, facilities or equipment and they include injuries, and exposure to chemicals, biological agents and radiological materials. ANSTO continues to measure Opportunities for Improvement (OFI) as a leading safety measure of ANSTO’s incident reporting culture.

In 2019-2020 the majority of incidents reported were leading incident types which is reflected in the OFI of 68 per cent. This is compared to OFIs of 73 per cent (2018-2019), 71 per cent (2017-2018), 80 per cent (2016-2017) and 82.5 per cent (2015-2016).

ANSTO staff are encouraged to report all types of incidents, with 44 per cent of incidents being near hits/misses or hazards/observations. All safety incidents are allocated an actual and potential impact rating. The potential impact rating identifies the 'worst case scenario' of the incident. The majority (72 per cent) of reported safety incidents had a potential impact rating of low significance or minor.

The high reporting rate, especially of OFI and low significant/minor incidents highlights an ongoing positive reporting culture.

Lost shift and lost time injuries

Lost Shift Injury Frequency Rate (LSIFR) and Lost Time Injury Frequency Rate (LTIFR) are a safety performance measure at ANSTO that are used to separate serious injuries (LTI) from less serious injuries (LSI). These measures relate to injuries that required time taken off work and do not reflect the impact the injury has had on the worker (Refer Table 9).

In 2019-2020 there were 13 Lost Shift Injuries and no Lost Time Injuries. Staff who exceeded the annual dose limit mentioned above were re-allocated alternate responsibilities on site.

Lost Shift injuries are injuries where workers required less than five days off work; Lost Time injuries are injuries that required five or more days off work. This definition was adopted for benchmarking purposes to be in line with the Safe Work Australia definition of a serious compensation claim of an injury that requires in one working week or more off work.

The early intervention program managed by the ANSTO Health and Wellbeing Centre aims to minimise the time taken off for work related injuries and allows workers to return to work as early as possible.

Lost Shift Injury Frequency Rate (LSIFR) and Lost Time Injury Frequency Rate (LTIFR) are a safety performance measure at ANSTO that are used to separate serious injuries (LTI) from less serious injuries (LSI). A LTIFR or LSIR is a frequency rate and refers to the number of lost time or lost shift injuries occurring per one million hours worked. These measures relate to injuries that required time taken off work and do not reflect the impact the injury has had on the worker (Refer Table 9).

The average time taken off for each of the Lost Shift injuries was two days. The data in Table 9, indicates a downward trend in LTIFR’s that require a longer period off work, primarily due to early intervention

The LSIFR/LTIFR is tracked over a 13 month period. In 2019-2020 there were 13 lost shift injuries recorded; eight of these were related to muscular stress. All these injuries were managed by the ANSTO Health and Wellbeing Centre through the early intervention program that allowed most of these workers to return to work within two days. Refer to Figure 5.

Figure 5: Rolling annual lost shift/time injury frequency rate

Independent Safety Review of the ANSTO Health Approach to Occupational Radiation Safety and Operational Procedures

In June 2018 a review was conducted by a globally recognised panel of experts, following a directive issued to ANSTO by the regulator, ARPANSA.

The final report by the independent expert review team contains 85 recommendations in respect to ANSTO, to ARPANSA and to the Australian Government. ARPANSA approved ANSTO’s Response to the Independent Review of the ANSTO Health Approach to Occupational Radiation Safety and Operational Procedures (Implementation Plan) in December 2019.

The ARPANSA Facility Licence for ANSTO Health was amended to require ANSTO to report to ARPANSA on the process of the Implementation Plan starting with a report for the last quarter of 2019 and then at six monthly intervals until all actions are completed to the satisfaction of the ARPANSA CEO. The reports will be submitted in January and July of each year. The first progress report, since the approval of the Implementation Plan in December 2019, was submitted in January 2020 outlining the governance model that would be followed. As at 30 June 2020, 32 recommendations had been closed by ANSTO.

Emergency management

Emergency management is part of the business resilience framework that allows ANSTO to respond to disruptive incidents in a cohesive manner that is consistent with organisational objectives. ANSTO has adopted the Australasian Inter-Service Incident Management System (AIIMS) as part of an integrated approach to business resilience including emergency management. ANSTO’s Emergency Operations are responsible for the management, coordination, preparation, resourcing and overall operational response for all ANSTO incidents and emergencies.

ANSTO is working to align and implement the requirements of the International Atomic Energy Agency (IAEA) Safety Standards Series No. GSR Part 7, Preparedness and Response for a Nuclear or Radiological Emergency (2015) and other related international guidance. The implementation of this plan has been monitored by ARPANSA as part of routine regulatory oversight.

ANSTO supports Nuclear Powered Warship visits to Australian ports under the Commonwealth Plan for Nuclear Powered Warship visits (OPSMAN 1) by acting as the Leader Radiation Monitoring Group and are the Commonwealth operational representative during a visit. ANSTO also advises the State or Territory on emergency responses during a radiological or nuclear emergency associated with the visit.

Radiation safety

(Australian Radiation Protection and Nuclear Safety Act 1998 and Regulations 2018)

Everyone in the world is exposed to ionising radiation from natural sources. People may also be exposed to radiation from non-natural sources, including nuclear medicine procedures for diagnosis and treatment of certain illnesses. Personal radiation exposure (‘dose’) is measured in sieverts (Sv), however, typical annual exposures are so small that they are usually expressed in units of one thousandth of a sievert, known as a millisievert (mSv). Equivalent dose and effective dose are specific units used for radiological protection purposes.

ANSTO has a demonstrated capacity to safely manage its diverse set of nuclear activities. During routine operations, ANSTO workers and members of the public are exposed to very low levels of radiation. This low level of exposure is achieved through good management practices, which also allows the delivery of the significant societal benefit associated with ANSTO’s nuclear activities.

The safety improvement focus remains on modifications to processes for identifying, assessing, managing and eliminating high hazard consequences from low probability incidents.

Strategy

The ANSTO Radiation Protection Strategic Plan is used to strengthen ANSTO’s high-performance culture. The four objectives of the plan are:

1. Improve radiation safety culture
2. Reduce radiological safety risks
3. Ensure continued regulatory compliance
4. Generate continuous improvement in radiological protection.

Continuous improvement

ANSTO's safety culture is underpinned by a strong regulatory framework, which includes oversight by ARPANSA, the Therapeutic Goods Administration, Comcare and the ASNO. ANSTO will continue to engage with its Commonwealth and State regulators and other Commonwealth agencies to ensure regulatory requirements are met. The Organisation will also continue to identify opportunities for continuous improvement that not only make a positive contribution to ANSTO’s safety culture, but also to its commercial operations and research endeavours.

ANSTO plans to deliver a continuous improvement program that will focus on holistic improvement across all areas of the Organisation through the facilitation of strategic programs in partnership with local management. The target area will be radiological condition awareness that will enhance workers’ skills in radiological monitoring and assessing its significance and understanding of local hazards through ownership of enhanced reporting and investigation.

ANSTO is implementing strategies to more strongly align with national and international organisations, such as the International Atomic Energy Agency (IAEA), the UK Safety Directors Forum, the National Physical Laboratory (NPL), the Nuclear Energy Agency; and the International Commission for Radiological Protection (ICRP). One focus is developing ANSTO’s nuclear baseline. These strategies will further improve ANSTO’s radiological safety culture over the next two to four years and beyond. These international guides often exceed the requirements of the Australian legislation and will align ANSTO with international best practice

Occupational exposures

According to the most recent data from ARPANSA, the average effective dose an Australian receives from natural background radiation (excluding medical sources) is 1.5 mSv per year. Federal, state and territory regulations require that a member of the public should receive no more than 1 mSv effective dose per year from radiation sources in addition to background radiation and medical procedures.

Effective dose in particular is a central feature of radiological protection. It sums up any number of different exposures into a single number that reflects, in a general way, the overall risk. The concept may be complex, but it makes radiological protection practical to implement.

The regulatory annual limits for radiation workers (Occupationally Exposed Persons) are:

• 20 mSv effective whole body dose (averaged over five years, with no more than 50 mSv in any one year);
• 20 mSv equivalent lens of the eye dose (averaged over five years, with no more than 50 mSv in any one year);
• 500 mSv equivalent dose to the skin;
• 500 mSv equivalent dose to the (hands and feet).

This is derived from recommendations made by the International Commission on Radiological Protection (ICRP 103) that have specified three basic principles for radiation protection, which are applied at ANSTO.

These principles are:

1. Justification of a Practice – All exposures to ionising radiation shall have a positive net benefit.

2. Optimisation of Protection – All exposures shall be as low as reasonably achievable (ALARA), taking into account economic and societal factors.

3. Dose Limitation – All exposures from planned exposure situations shall be less than the relevant statutory limit.

Limits are insufficient in themselves to ensure the best achievable protection under the prevailing circumstances, and both the optimisation of protection and the limitation of doses and risks to individuals are necessary to achieve the highest standards of safety.

The radiation exposure of ANSTO’s workers, who are routinely engaged in working with ionising radiation, is monitored by our specialist dosimetry service, with records of exposures maintained. The monitoring results for the last five calendar years 2015-2019 (Table 10) show that radiation doses received by ANSTO workers remain significantly below regulatory limits. The graph in Figure 6 compares maximum effective dose to a single worker and the average effective dose across all relevant ANSTO workers. Table 11 shows the distribution of individual effective doses over the same five year period.

In 2019 the average effective dose across all ANSTO workers was 0.4 mSv. This is equivalent to receiving two chest x-rays¹ or flying from Melbourne to London and back three times.² It is also about 20 per cent of the average background radiation exposure received just from living in Australia.

1. https://www.iaea.org/Publications/Factsheets/English/radlife
2. https://www.arpansa.gov.au/understanding-radiation/radiation-sources/more-radiation-sources/flying-and-health

Figure 6: Comparison of maximum and average effective doses.

Extremity exposure

The exposure to the hands of ANSTO workers is routinely measured for those operations that require workers to have their hands closer to sources of radiation, such as during radiopharmaceutical product testing. This is called equivalent dose, which is different to effective dose presented above. It focuses on specific organs or parts of the body.

Generally, the radiation exposures to the hands are very low compared to the applicable dose limit of 500 mSv to the skin / extremities. The maximum planned extremity dose to ANSTO operators in 2019 was 72 mSv (with the exception of the three workers indicated below), which is very much less than the legal limit. More than 99 per cent of workers' extremity exposures were below 50 mSv.

Three workers received exceptional doses to the skin caused by an accidental exposure due to Mo-99 contamination. Significant radioactive contamination was transferred to the surface of a shielding pot and operators were exposed locally to the hands when they wiped the pot surfaces. The best estimated dose to the skin from this exposure indicated that two operators exceeded the annual equivalent dose limit of 500 mSv, but received less than the threshold for tissue reactions, such as reddening of the skin; and the third operator received less than the annual equivalent dose limit (~400 mSv).

Regulator engagement - ARPANSA

The main regulator ANSTO engages with for radiation and nuclear safety is ARPANSA.

ANSTO is required to report accidents under section 58 of the Australian Radiation Protection and Nuclear Safety Regulations 2018. An accident is any occurrence, associated with controlled apparatus, controlled materials or a controlled facility, which results in, or has the potential to result in, exposure to radiation, such as to cause injury, damage or harm to any person or the environment. During 2019-2020 there were no accidents reported to ARPANSA. ANSTO was found in breach of its licences on three occasions. Refer to Table 12.