Accreditation of third-party service providers – radiation competency assessment

Two sessions were held on 7 and 15 December 2021.

• Presentation slides
• Application form

Draft accreditation of third-party service providers - radiation competency assessment

Accreditation is formal recognition that a product or service meets specified quality assurance requirements. For the purposes of this project, accreditation refers to recognition that a person has appropriate skills, qualifications, knowledge or experience to issue certificates of competency in relation to applicants for a licence under the Radiation Protection and Control Act 1982.

The draft accreditation policy specifies the requirements necessary to ensure that persons operating certification schemes does so in a consistent, comparable and reliable manner. By setting and maintaining standards that are reliable and valid, accreditation provides assurance that applicants for an authorisation have appropriate knowledge of the principles and practices of radiation protection.

Certification is one of several measures aimed at ensuring safe radiation practice, and in the final instance responsibility for meeting safety standards remain with those undertaking and supervising the activity.

Accreditation promotes separation between those responsible for providing and delivering qualifications, training, assessments and tests, and the regulator who ensured there is a fair and accurate measure of competence to meet mandatory regulatory requirements. Accreditation of certifiers with high levels of expertise and experience would bring a new professional status to assessment of radiation knowledge and skills that are valued and trusted by the community.

The accreditation scheme will apply to organisations and persons who are qualified to issue certificates of competency in relation to persons seeking authorisation to undertake activities regulated under the RPC Act. For a person to be accredited, they must have appropriate skills, qualifications, knowledge or experience to properly carry out the activities authorised by the accreditation. They must also satisfy any other requirements for accreditation prescribed by the regulations.

The Minister may establish various classes of accreditation, and an accreditation may be limited to the matters covered by the accreditation.

Accrediting third-party service providers allows for more effective sharing of expertise between operators to train staff, develop systems and undertake assessments. This will enable a greater degree of assurance that controls are implemented and any new situations or exposure pathways are identified.

Third-party certification will be for persons applying for an authorisation under the RPC Act, excluding those who are registered with the Medical Radiation Practice Board of Australia under the National Registration and Accreditation Scheme.

Such persons would have been adequately assessed to undertake the activities for which they are registered and would have completed an approved program of study through an accredited training provider or passed the Medical Radiation Practice Board’s national exam.

Guiding principles

The overarching guiding principle for the accreditation scheme will be the safe and competent use of radiation. For this, the EPA will rely on demonstrated compliance with nationally and internationally accepted standards and practices in line with the radiation protection principle in the National Directory for Radiation Protection (NDRP).

The purpose of the radiation protection principle is to provide for the:

... justification of practices to ensure that benefits outweigh the detriment, limitation of radiation doses to individuals from all practices, and optimisation of protection and safety so that individual doses, the number of people exposed and the likelihood of exposure are all kept as low as reasonably achievable, economic and social factors being taken into account.

This radiation protection principle is applied through the processes of justification, limitation, and optimisation.

We will also rely on certification by the accredited training provider that an applicant for an EPA licence is competent to carry out the authorised activities in a safe manner.

A second guiding principle is progressing nationally harmonised regulation of radiation. This is reflected in the strong similarity of the draft EPA accreditation standards with those issued by the Accreditation Committee of the Medical Radiation Practice Board. Harmonisation of radiation protection in Australia is a priority of the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) and all the States and Territories. In line with the recommendation of the International Atomic Energy Agency (IAEA) 2018 Integrated Regulatory Review Service Mission, the aim is common competency requirements and their consistent application across jurisdictions.

A graded approach

In a graded approach the stringency of the control measures and conditions to be applied is commensurate, to the extent practicable, with the likelihood and possible consequences of, and the level of risk associated with, a loss of control. In the context of this accreditation policy, this would mean that the requirements to be met should be proportionate to the level of risk and complexity of the activity to which the competency certification relates.

For example, the stringency of requirements to be accredited to issue certificates of competency in relation to the operation of radiation apparatus of similar dose capacity will differ depending on whether it is applied for industrial, veterinary or human purposes. It is also proposed to reflect a graded approach in the implementation of the accreditation policy by introducing it in a phased manner, starting with accreditation in relation to certification of lower risk activities.

The process

It is proposed that applications for accreditation will be lodged online, reviewed for completeness and assigned to an authorised officer who will evaluate the application against the accreditation policy and submit the results of the assessment to the Radiation Protection Committee or a subcommittee established for this purpose.

The Committee will assess the application against specified criteria including the authorised officer’s assessment and make a recommendation to the Minister or his delegate for a decision. If approved, the decision will include the conditions of accreditation and the matters to be covered by the accreditation. This will include specification of the activities for which certificates of competency may be issued, and the information to be provided as part of the certification.

The EPA will institute an audit program to monitor compliance with the accreditation and the need to adjust the conditions of accreditation due to factors such as changes in knowledge and technology.

Standards and criteria

Applications for accreditation will be assessed against the requirements of the Third-Party Certification of Radiation Competency Policy which are based on the Australia/New Zealand Standard AS/NZS ISO/IEC 17024:2013 Conformity assessment – General requirements for bodies operating certification of persons.

By meeting the standard, the objectives are to ensure that the accredited assessment:

• gives a reliable indication of knowledge, skills and understanding
• gives a reliable indication of achievement
• promotes public confidence in regulated qualifications and related assessment
• is valued and promoted by learners, workers, employers and organisations within the radiation sector.

At the conclusion of this consultation process, the EPA will prepare a summary of submissions and other forms of feedback and submit a final draft policy to the Radiation Protection Committee for advice and to the Minister for approval.

This will be followed by finalising the online application process and conducting information sessions before inviting the first round of applications for accreditation.