Actions Completed by ARPANSA in Response to Independent Safety Review
Dear Australian Radiation Protection and Nuclear Safety Agency,
I am seeking access under the Freedom of Information Act 1982 (FOI Act) to actions completed by ARPANSA in response to R29 of last year's independent safety review.
In response to a number of recent safety incidents, an independent review was conducted at ANSTO in 2018. The results of this review were documented in "INDEPENDENT SAFETY REVIEW OF THE ANSTO HEALTH APPROACH TO OCCUPATIONAL RADIATION SAFETY AND OPERATIONAL PROCEDURES" dated October 2018. It resulted in the identification of 85 recommendations; a small number of which apply to the regulator ARPANSA.
One of the recommendations deals with the lack of clarity surrounding licence conditions. R29 states "Both ARPANSA and ANSTO should develop documentation that offers guidance on the interpretation and implementation of ARPANSA Licence Conditions and which take due cognisance of the suite of documents available through international bodies such as IAEA, WENRA and relevant good international regulatory practice e.g. UK, France, US, etc.".
Request information regarding actions that have been completed since October of 2018 to address this recommendation.
Yours faithfully,
Anonymous
Dear Sun Shine
I acknowledge receipt of your Freedom of Information Request below dated 31 July 2019 seeking access to:
"information regarding actions that have been completed since October 2018 to address recommendation 29 of ANSTO Independent Safety Review."
ARPANSA received your request on 31 July 2019 and the 30 day statutory period for processing your request commenced from the day after that date. You should therefore expect a decision from me by 30 August 2019. The period of 30 days may be extended if I need to consult third parties or for other reasons. I will advise you if this happens.
Kind regards
Gemma Larkins
Legal Officer
Office of the General Counsel
-----Original Message-----
From: Sun Shine <[FOI #5546 email]>
Sent: Wednesday, 31 July 2019 11:52 AM
To: $ARPANSA FOI <[ARPANSA request email]>
Subject: HPRM: Freedom of Information request - Actions Completed by ARPANSA in Response to Independent Safety Review
Dear Australian Radiation Protection and Nuclear Safety Agency,
I am seeking access under the Freedom of Information Act 1982 (FOI Act) to actions completed by ARPANSA in response to R29 of last year's independent safety review.
In response to a number of recent safety incidents, an independent review was conducted at ANSTO in 2018. The results of this review were documented in "INDEPENDENT SAFETY REVIEW OF THE ANSTO HEALTH APPROACH TO OCCUPATIONAL RADIATION SAFETY AND OPERATIONAL PROCEDURES" dated October 2018. It resulted in the identification of 85 recommendations; a small number of which apply to the regulator ARPANSA.
One of the recommendations deals with the lack of clarity surrounding licence conditions. R29 states "Both ARPANSA and ANSTO should develop documentation that offers guidance on the interpretation and implementation of ARPANSA Licence Conditions and which take due cognisance of the suite of documents available through international bodies such as IAEA, WENRA and relevant good international regulatory practice e.g. UK, France, US, etc.".
Request information regarding actions that have been completed since October of 2018 to address this recommendation.
Yours faithfully,
Anonymous
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Whilst ARPANSA has taken all reasonable steps to ensure this is email is virus free,
it accepts no responsibility and makes no warranty. The recipient should take its own
steps to ensure there is no virus and bears full responsibility for any use.
Australian Radiation Protection And Nuclear Safety Agency
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Dear $ARPANSA FOI,
I note you have ignored the 30-day deadline for my request. I respectfully ask that you comply with the FoI Act and respond by providing the requested information this week.
The recommendation was important because incidents at ANSTO continue to occur and ARPANSA does not appear to be improving safety or adding any regulatory value. The recommendation called for the development of documentation that offers guidance on the interpretation and implementation of ARPANSA Licence Conditions. It's impossible to regulate effectively without a common understanding of what a licence condition means.
If no action was taken by ARPANSA with respect to R29, a simple statement to that effect will suffice.
Yours sincerely,
Anonymous
Dear Sun Shine
Please find attached a decision dated 3 September 2019 in relation to your FOI Request dated 31 July 2019.
Kind regards
Gemma Larkins
Legal Officer
Office of the General Counsel
-----Original Message-----
From: Sun Shine <[FOI #5546 email]>
Sent: Tuesday, 3 September 2019 10:58 AM
To: $ARPANSA FOI <[ARPANSA request email]>
Subject: RE: HPRM: Freedom of Information request - Actions Completed by ARPANSA in Response to Independent Safety Review [SEC=UNCLASSIFIED]
Dear $ARPANSA FOI,
I note you have ignored the 30-day deadline for my request. I respectfully ask that you comply with the FoI Act and respond by providing the requested information this week.
The recommendation was important because incidents at ANSTO continue to occur and ARPANSA does not appear to be improving safety or adding any regulatory value. The recommendation called for the development of documentation that offers guidance on the interpretation and implementation of ARPANSA Licence Conditions. It's impossible to regulate effectively without a common understanding of what a licence condition means.
If no action was taken by ARPANSA with respect to R29, a simple statement to that effect will suffice.
Yours sincerely,
Anonymous
-----Original Message-----
Dear Sun Shine
I acknowledge receipt of your Freedom of Information Request below dated 31 July 2019 seeking access to:
"information regarding actions that have been completed since October 2018 to address recommendation 29 of ANSTO Independent Safety Review."
ARPANSA received your request on 31 July 2019 and the 30 day statutory period for processing your request commenced from the day after that date. You should therefore expect a decision from me by 30 August 2019. The period of 30 days may be extended if I need to consult third parties or for other reasons. I will advise you if this happens.
Kind regards
Gemma Larkins
Legal Officer
Office of the General Counsel
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #5546 email]
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
***********************************************************************************
Important: This email (including any attachments) is intended only for the use of the
addressee and may contain confidential and / or privileged information. If you are
not the intended addressee, you are prohibited from relaying on, distributing,
disclosing, copying or in any other way using any information in this email. If you have
received this email in error, please notify the sender immediately and erase all copies.
Any opinions expressed in this email are not necessarily held or authorised by Australian
Radiation Protection And Nuclear Safety Agency (ARPANSA).
Whilst ARPANSA has taken all reasonable steps to ensure this is email is virus free,
it accepts no responsibility and makes no warranty. The recipient should take its own
steps to ensure there is no virus and bears full responsibility for any use.
Australian Radiation Protection And Nuclear Safety Agency
***********************************************************************************
Dear $ARPANSA FOI,
Thank you. You stated that "ARPANSA has established its own project plan to deal with actions against ARPANSA. However ARPANSA has not developed any specific action in response to recommendation 29."
Can you please clarify? Is the action plan a justification for taking no action with respect to R29? Can you please provide the action plan in response to my FoI request?
Yours sincerely,
Anonymous
Dear Sun Shine
The project plan does not include actions for recommendation 29 and therefore does not fall within the scope of your request. As set out in the FOI Decision, recommendation 29 was based on interviews with ANSTO Health Staff and did not reflect the significant guidance already available on ARPANSA's website including:
(a) the Performance Objectives and Criteria which provide information on what ARPANSA looks for during an inspection https://www.arpansa.gov.au/regulation-an... ;
(b) extensive regulatory guidance https://www.arpansa.gov.au/regulation-an...
(c) Manuals https://www.arpansa.gov.au/regulation-an...
(d) international best practice for controlled facilities - https://www.arpansa.gov.au/regulation-an...
This guidance material is updated periodically to maintain currency.
Kind regards
Gemma Larkins
Legal Officer
Office of the General Counsel
-----Original Message-----
From: Sun Shine <[FOI #5546 email]>
Sent: Wednesday, 4 September 2019 1:21 PM
To: $ARPANSA FOI <[ARPANSA request email]>
Subject: HPRM: RE: HPRM: Freedom of Information request - Actions Completed by ARPANSA in Response to Independent Safety Review [SEC=UNCLASSIFIED]
Dear $ARPANSA FOI,
Thank you. You stated that "ARPANSA has established its own project plan to deal with actions against ARPANSA. However ARPANSA has not developed any specific action in response to recommendation 29."
Can you please clarify? Is the action plan a justification for taking no action with respect to R29? Can you please provide the action plan in response to my FoI request?
Yours sincerely,
Anonymous
-----Original Message-----
Dear Sun Shine
Please find attached a decision dated 3 September 2019 in relation to your FOI Request dated 31 July 2019.
Kind regards
Gemma Larkins
Legal Officer
Office of the General Counsel
-------------------------------------------------------------------
Please use this email address for all replies to this request:
[FOI #5546 email]
This request has been made by an individual using Right to Know. This message and any reply that you make will be published on the internet. More information on how Right to Know works can be found at:
https://www.righttoknow.org.au/help/offi...
If you find this service useful as an FOI officer, please ask your web manager to link to us from your organisation's FOI page.
-------------------------------------------------------------------
***********************************************************************************
Important: This email (including any attachments) is intended only for the use of the
addressee and may contain confidential and / or privileged information. If you are
not the intended addressee, you are prohibited from relaying on, distributing,
disclosing, copying or in any other way using any information in this email. If you have
received this email in error, please notify the sender immediately and erase all copies.
Any opinions expressed in this email are not necessarily held or authorised by Australian
Radiation Protection And Nuclear Safety Agency (ARPANSA).
Whilst ARPANSA has taken all reasonable steps to ensure this is email is virus free,
it accepts no responsibility and makes no warranty. The recipient should take its own
steps to ensure there is no virus and bears full responsibility for any use.
Australian Radiation Protection And Nuclear Safety Agency
***********************************************************************************