Radiation Protection Convention, 1960 (No. 115) - Barbados (RATIFICATION: 1967)

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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 to the request for information contained in paragraph 30 thereof.

Articles 1, 3, 5–9 and 11–15 of the Convention. Legislation. Consultations. Activities covered and effective protection of workers. The Committee notes with concern that, despite its reiterated comments, there has been no progress in the application of the Convention. The Government recognizes in its report that there are shortcomings in the Radiation Protection Act (Cap. 353A) of 1971, which only gives effect to Article 10 of the Convention (notification of work involving exposure to ionizing radiations). In addition, the Committee notes the Government’s indication that, with the exception of the systems put in place in the main public hospital, workers who are exposed to ionizing radiations are not protected. The Government expresses its intention to revise the Radiation Protection Act (Cap. 353A), in order to bring it into conformity with the Convention. In this regard, the Government indicates that a regulation on radiation protection could be established under the Safety and Health at Work Act (Cap. 356), proclaimed in January 2013.

In response to the previous observations of the Barbados Workers’ Union (BWU) concerning the reactivation of the Advisory Committee on Radiation Protection, the Government indicates that a similar tripartite committee would be established to review and propose the necessary revision of the legislation in order to comply with the requirements of the Convention. In this respect, the Committee draws the attention of the Government to the guidance contained in its 2015 general observation. While noting the intent of the Government to revise the Radiation Protection Act (Cap. 353A) of 1971, the Committee requests the Government to take the necessary steps, without delay and in consultation with representatives of employers and workers, to give full effect to the abovementioned provisions of the Convention, in light of its 2015 general observation, and to submit a detailed report in this regard.

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The Committee notes with regret that the brief report submitted by the Government does not reply to its previous comments. It must therefore repeat its previous observation which read as follows:

Repetition

Comments by the Barbados Workers Union (BWU). The Committee notes the comments transmitted by the BWU on 1 September 2011 which were communicated to the Government on 19 September 2011 and that no response thereto has been received from the Government. The Committee notes that the BWU reiterates its call to institute its previously suggested measures so as to mitigate the probability and severity of any incidents relative to radiation exposure, that the BWU on several occasions has requested that the Advisory Committee be reactivated, maximum admissible radiation exposure doses be fixed and a compulsory annual examination be instituted, among other measures and that according to the BWU workers in a number of establishments have, of late, made calls for the aforementioned measures relating to radiation protection to be implemented without delay. In the light of these comments, the Committee requests the Government to take all appropriate measures to ensure full application of the Convention. It also reiterates its request to the Government to respond to its previous observations which read as follows:

The Committee notes the information contained in the Government’s report and the reply to its direct request. It notes that, despite comments it has reiterated for several years, the Government’s report contains no new information and that, according to the Government’s replies, no follow-up has been given to the Committee’s comments. The Committee also notes that the Government’s report refers to observations submitted by the “Barbados Workers’ Union” which requests the Government to reactivate the Advisory Committee on Radiation Protection (ACRP); to establish legislative measures to afford protection to workers exposed to ionizing radiation, particularly by fixing the maximum admissible radiation exposure doses; to take appropriate measures to prescribe a compulsory medical examination – not merely optional – for workers exposed to radiation; and to provide alternative employment allowing them to maintain their income for persons who can no longer work in zones exposed to radiation. In view of the above, the Committee is bound to reiterate its observations on the following matters.

Articles 2 and 4 of the Convention. The Committee noted the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of “knowledge available at the time” and in the light of “current knowledge”, the Committee noted from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type “Selectron HDR”, in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee noted the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the “Selectron HDR” system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee noted the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7(2) of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7(1)(a) of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicated that the reports on radiation received by these workers show either negligible or zero doses. While the Committee noted this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3(1) of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention, as well as to section 5.4.5 of the ILO Code of Practice on the Radiation Protection of Workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee noted the information supplied with the Government’s report on the functions of the alarm systems used in those units at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO Code of Practice on the Radiation Protection of Workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9(2) of the Convention.

Article 11. The Committee noted the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicated that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicated that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection – Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16–27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

The Committee hopes that the Government will make every effort to take the necessary action in the near future.

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The Committee notes with regret that the Government’s report has not been received. It must therefore repeat its previous observation which read as follows:

Repetition

Comments by the Barbados Workers Union (BWU). The Committee notes the comments transmitted by the BWU on 1 September 2011 which were communicated to the Government on 19 September 2011 and that no response thereto has been received from the Government. The Committee notes that the BWU reiterates its call to institute its previously suggested measures so as to mitigate the probability and severity of any incidents relative to radiation exposure, that the BWU on several occasions has requested that the Advisory Committee be reactivated, maximum admissible radiation exposure doses be fixed and a compulsory annual examination be instituted, among other measures and that according to the BWU workers in a number of establishments have, of late, made calls for the aforementioned measures relating to radiation protection to be implemented without delay. In the light of these comments, the Committee requests the Government to take all appropriate measures to ensure full application of the Convention. It also reiterates its request to the Government to respond to its previous observations which read as follows:

The Committee notes the information contained in the Government’s report and the reply to its direct request. It notes that, despite comments it has reiterated for several years, the Government’s report contains no new information and that, according to the Government’s replies, no follow-up has been given to the Committee’s comments. The Committee also notes that the Government’s report refers to observations submitted by the “Barbados Workers’ Union” which requests the Government to reactivate the Advisory Committee on Radiation Protection (ACRP); to establish legislative measures to afford protection to workers exposed to ionizing radiation, particularly by fixing the maximum admissible radiation exposure doses; to take appropriate measures to prescribe a compulsory medical examination – not merely optional – for workers exposed to radiation; and to provide alternative employment allowing them to maintain their income for persons who can no longer work in zones exposed to radiation. In view of the above, the Committee is bound to reiterate its observations on the following matters.

Articles 2 and 4 of the Convention. The Committee noted the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of “knowledge available at the time” and in the light of “current knowledge”, the Committee noted from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type “Selectron HDR”, in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee noted the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the “Selectron HDR” system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee noted the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7(2) of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7(1)(a) of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicated that the reports on radiation received by these workers show either negligible or zero doses. While the Committee noted this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3(1) of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention, as well as to section 5.4.5 of the ILO Code of Practice on the Radiation Protection of Workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee noted the information supplied with the Government’s report on the functions of the alarm systems used in those units at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO Code of Practice on the Radiation Protection of Workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9(2) of the Convention.

Article 11. The Committee noted the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicated that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicated that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection – Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16–27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

The Committee hopes that the Government will make every effort to take the necessary action in the near future.

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Comments by the Barbados Workers Union (BWU). The Committee notes the comments transmitted by the BWU on 1 September 2011 which were communicated to the Government on 19 September 2011 and that no response thereto has been received from the Government. The Committee notes that the BWU reiterates its call to institute its previously suggested measures so as to mitigate the probability and severity of any incidents relative to radiation exposure, that the BWU on several occasions has requested that the Advisory Committee be reactivated, maximum admissible radiation exposure doses be fixed and a compulsory annual examination be instituted, among other measures and that according to the BWU workers in a number of establishments have, of late, made calls for the aforementioned measures relating to radiation protection to be implemented without delay. In the light of these comments, the Committee requests the Government to take all appropriate measures to ensure full application of the Convention. It also reiterates its request to the Government to respond to its previous observations which read as follows:

Repetition

The Committee notes the information contained in the Government’s report and the reply to its direct request. It notes that, despite comments it has reiterated for several years, the Government’s report contains no new information and that, according to the Government’s replies, no follow-up has been given to the Committee’s comments. The Committee also notes that the Government’s report refers to observations submitted by the “Barbados Workers’ Union” which requests the Government to reactivate the Advisory Committee on Radiation Protection (ACRP); to establish legislative measures to afford protection to workers exposed to ionizing radiation, particularly by fixing the maximum admissible radiation exposure doses; to take appropriate measures to prescribe a compulsory medical examination – not merely optional – for workers exposed to radiation; and to provide alternative employment allowing them to maintain their income for persons who can no longer work in zones exposed to radiation. In view of the above, the Committee is bound to reiterate its observations on the following matters.

Articles 2 and 4 of the Convention. The Committee noted the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of “knowledge available at the time” and in the light of “current knowledge”, the Committee noted from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type “Selectron HDR”, in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee noted the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the “Selectron HDR” system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee noted the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7(2) of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7(1)(a) of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicated that the reports on radiation received by these workers show either negligible or zero doses. While the Committee noted this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3(1) of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention, as well as to section 5.4.5 of the ILO Code of Practice on the Radiation Protection of Workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee noted the information supplied with the Government’s report on the functions of the alarm systems used in those units at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO Code of Practice on the Radiation Protection of Workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9(2) of the Convention.

Article 11. The Committee noted the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicated that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicated that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection – Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16 27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

The Committee hopes that the Government will make every effort to take the necessary action in the near future.

[The Government is asked to reply in detail to the present comments in 2012.]

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The Committee notes with regret that the Government’s report has not been received. It must therefore repeat its previous observation which read as follows:

The Committee notes the information contained in the Government’s report and the reply to its direct request. It notes that, despite comments it has reiterated for several years, the Government’s report contains no new information and that, according to the Government’s replies, no follow-up has been given to the Committee’s comments. The Committee also notes that the Government’s report refers to observations submitted by the “Barbados Workers’ Union” which requests the Government to reactivate the Advisory Committee on Radiation Protection; to establish legislative measures to afford protection to workers exposed to ionizing radiation, particularly by fixing the maximum admissible radiation exposure doses; to take appropriate measures to prescribe a compulsory medical examination – not merely optional – for workers exposed to radiation; and to provide alternative employment allowing them to maintain their income for persons who can no longer work in zones exposed to radiation. In view of the above, the Committee is bound to reiterate its observations on the following matters.

Articles 2 and 4 of the Convention. The Committee noted the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of “knowledge available at the time” and in the light of “current knowledge”, the Committee noted from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type “Selectron HDR”, in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee noted the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the “Selectron HDR” system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee noted the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7(2) of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7(1)(a) of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicated that the reports on radiation received by these workers show either negligible or zero doses. While the Committee noted this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3(1) of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention, as well as to section 5.4.5 of the ILO code of practice on the radiation protection of workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee noted the information supplied with the Government’s report on the functions of the alarm systems used in those unites at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO code of practice on the radiation protection of workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9(2) of the Convention.

Article 11. The Committee noted the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicated that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicated that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection – Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16–27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

The Committee hopes that the Government will make every effort to take the necessary action in the very near future.

CMNT_TITLE

1. The Committee notes the information contained in the Government’s report and the reply to its direct request. It notes that, despite comments it has reiterated for several years, the Government’s report contains no new information and that, according to the Government’s replies, no follow-up has been given to the Committee’s comments. The Committee also notes that the Government’s report refers to observations submitted by the “Barbados Workers’ Union” which requests the Government to reactivate the Advisory Committee on Radiation Protection; to establish legislative measures to afford protection to workers exposed to ionizing radiation, particularly by fixing the maximum admissible radiation exposure doses; to take appropriate measures to prescribe a compulsory medical examination – not merely optional – for workers exposed to radiation; and to provide alternative employment allowing them to maintain their income for persons who can no longer work in zones exposed to radiation. In view of the above, the Committee is bound to reiterate its observations on the following matters:

Articles 2 and 4 of the Convention. The Committee noted the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of “knowledge available at the time” and in the light of “current knowledge”, the Committee noted from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type “Selectron HDR”, in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee noted the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the “Selectron HDR” system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee noted the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7, paragraph 2, of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7, paragraph 1(a), of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicated that the reports on radiation received by these workers show either negligible or zero doses. While the Committee noted this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3, paragraph 1, of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention as well as to section 5.4.5 of the ILO code of practice on the radiation protection of workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee noted the information supplied with the Government’s report on the functions of the alarm systems used in those unites at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO code of practice on the radiation protection of workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9, paragraph 2, of the Convention.

Article 11. The Committee noted the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicated that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicated that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection – Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16 to 27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

2. The Committee hopes that the Government will make every effort to take the necessary action in the very near future.

CMNT_TITLE

The Committee notes that the Government’s report has not been received. It must therefore repeat its previous observation, which read as follows:

1. The Committee noted in its previous comment that the Advisory Committee on Radiation Protection (ACRP), first established in 1979, was being reactivated. In this respect, it notes the Government’s indication that a number of persons have been invited to sit on the ACRP, namely representatives from the University of the West Indies, the Ministry of the Environment, the Barbados Dental Association, medical and nursing personnel working in hospitals, as well as two representatives from the industry sector of which, however, one has refused to join this Committee because of the rather limited use of radiation. To the Committee’s understanding, the above advisory committee has not resumed functioning yet. With regard to the numerous tasks of the ACRP, which are enumerated in the "Advisory Committee on Radiation Protection - Terms of reference", the Committee recalls that the functioning of the ACRP is instrumental in the preparation and implementation of legislative or other measures in order to provide an effective protection to workers exposed to ionizing radiation in the course of their work and thus in the application of the Convention. The Committee therefore urges the Government to take appropriate action to make the ACRP operational. It requests the Government to keep the Committee informed on any progress achieved in this regard.

2. With reference to its previous comments, the Committee draws the Government’s attention to the following points.

Articles 2 and 4 of the Convention. The Committee noted the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that, the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of "knowledge available at the time" and in the light of "current knowledge", the Committee noted from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type "Selectron HDR", in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee noted the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the "Selectron HDR" system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee noted the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7, paragraph 2, of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7, paragraph 1(a), of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicated that the reports on radiation received by these workers show either negligible or zero doses. While the Committee noted this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3, paragraph 1, of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention as well as to section 5.4.5 of the ILO code of practice on the radiation protection of workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee noted the information supplied with the Government’s report on the functions of the alarm systems used in those unites at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO code of practice on the radiation protection of workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9, paragraph 2, of the Convention.

Article 11. The Committee noted the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicated that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicated that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection - Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16 to 27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

The Committee hopes that the Government will make every effort to take the necessary action in the very near future.

CMNT_TITLE

The Committee notes the information provided by the Government in its report in response to its comments.

1. The Committee noted in its previous comment that the Advisory Committee on Radiation Protection (ACRP), first established in 1979, was being reactivated. In this respect, it notes the Government’s indication that a number of persons have been invited to sit on the ACRP, namely representatives from the University of the West Indies, the Ministry of the Environment, the Barbados Dental Association, medical and nursing personnel working in hospitals, as well as two representatives from the industry sector of which, however, one has refused to join this Committee because of the rather limited use of radiation. To the Committee’s understanding, the above advisory committee has not resumed functioning yet. With regard to the numerous tasks of the ACRP, which are enumerated in the "Advisory Committee on Radiation Protection - Terms of reference", the Committee recalls that the functioning of the ACRP is instrumental in the preparation and implementation of legislative or other measures in order to provide an effective protection to workers exposed to ionizing radiation in the course of their work and thus in the application of the Convention. The Committee therefore urges the Government to take appropriate action to make the ACRP operational. It requests the Government to keep the Committee informed on any progress achieved in this regard.

2. With reference to its previous comments, the Committee draws the Government’s attention to the following points.

Articles 2 and 4 of the Convention. The Committee notes the Government’s indication that the regulatory body to monitor the exposure of workers to ionizing radiation has not been established yet. It further notes that, the ACRP has not yet given directives regarding protective measures to be taken against ionizing radiation, or time limits for the application of such measures. Referring to its introductory comments, the Committee urges the Government to take the appropriate steps to make the ACRP operational and thus creating the framework for the monitoring of workers’ exposure to ionizing radiation and the issuing of directives regarding protective measures, which falls, according to the Committee’s understanding, in the area of competence of the ACRP.

Articles 3 and 6. With regard to the fixing of maximum permissible doses of ionizing radiation, necessary in order to comply with the requirement to ensure effective protection of workers in the light of "knowledge available at the time" and in the light of "current knowledge", the Committee notes from the Government’s report that the radiation protection officer, being a hospital physician and the chairperson of the ACRP, is well aware of the recent revised dose limits of the International Commission on Radiological Protection (ICRP). In this regard, the Government indicates that reports on the doses of ionizing radiation received by workers show that the limits recommended by the ICRP were not exceeded. However, in particular cases recorded for cardiac catheterization doctors and one radiologist, the dose of radiation absorbed was beyond this limitation, which subsequently has been brought to their attention. The Committee, noting that the observance of the dose limits for ionizing radiation, as recommended by the ICRP in 1990, do not seem to set a problem to the Government in practice, requests therefore the Government to reconsider the possibility to fix maximum permissible dose levels of ionizing radiations with legally binding effect in order to guarantee by means of enforceable provisions an effective protection of workers exposed to ionizing radiations, in accordance with Articles 3 and 6 of the Convention.

Article 5. With regard to the installation of a computerized system, type "Selectron HDR", in 1990 which reduces the number of workers dealing with radiation sources to an extent that the probable exposure to radiation would turn to zero, the Committee notes the Government’s indication that this system is used in the treatment of cancer of the uterine cervix and related problems. However, its use in other medical disciplines has to be planned since logistical problems regarding the necessary equipment and the movement of staff working in related disciplines need to be resolved. The Committee hopes that the Government will take the necessary action to enable the use of the "Selectron HDR" system in all medical disciplines where appropriate in order to restrict the exposure of workers to the lowest practicable level and to avoid any unnecessary exposure of workers. The Committee requests the Government to supply information on experiences already collected in applying the system in the field of the treatment of cancer of the uterine cervix.

Article 7. The Committee notes the Government’s indication that no legislation is in place to set a lower limit on the age of radiation workers. However, since it is a very fundamental issue, it is hoped that it will appear in the amended Radiation Act. In the meantime it belongs to the radiation protection officer’s tasks to ensure that adequate structural shielding in place is provided, such as area monitoring, warning lights or alarm where appropriate and that only qualified workers are employed to operate machines producing radiation. In this respect, the Committee notes again the Government’s indication provided with its 1998 report to the effect that the minimum age for engagement in radiation work was 16. Recalling the provision of Article 7, paragraph 2, of the Convention which provides for a minimum age of 16 to become engaged in work involving ionizing radiation, the Committee requests again the Government to specify the legal basis providing for the prohibition to engage young persons under 16 years of age in work involving exposure to ionizing radiations. Moreover, the Committee recalls the provision of Article 7, paragraph 1(a), of the Convention, providing for the fixation of appropriate levels of exposure to ionizing radiations for workers who are directly engaged in radiation work and are aged 18 and over. The Committee therefore asks the Government once again to indicate the measures taken or contemplated in order to fix appropriate levels for this group of workers. Since the Committee understands from the Government’s indication that an amendment of the Radiation Act is intended, it would invite the Government to consider the possibility to incorporate such appropriate levels in the amendment of the above Act.

Article 8. With regard to dose limits to be set for workers not directly engaged in radiation work, the Government indicates that the reports on radiation received by these workers show either negligible or zero doses. While the Committee notes this information with interest, it nevertheless wishes to point out that Article 8 of the Convention obliges every ratifying State to fix appropriate levels of exposure to ionizing radiations for this category of workers, in accordance with Article 6, read together with Article 3, paragraph 1, of the Convention, that is in the light of knowledge available at the time. In this respect, the Committee would draw the Government’s attention to paragraph 14 of its 1992 general observation under the Convention as well as to section 5.4.5 of the ILO code of practice on the radiation protection of workers (ionizing radiations) of 1986, explaining that the employer has the same obligations towards workers not engaged in radiation work, as far as restricting their radiation exposure is concerned, as if they were members of the public with respect to sources of practices under the employer’s control. The annual dose limits should be those applied to individual members of the public. According to the 1990 ICRP Recommendations, the annual dose limit for members of the public is 1 mSv. The Committee therefore asks the Government to indicate the measures envisaged to fulfil its obligation under this Article of the Convention.

Article 9. The Committee notes with interest the information supplied with the Government’s report on the functions of the alarm systems used in those unites at hospitals where radiation treatment is carried out. It also notes the existence of appropriate warning signs fixed on the doors to indicate the presence of hazards arising from ionizing radiations. However, with regard to adequate instructions of workers directly engaged in radiation work, the Committee calls again the Government’s attention to section 2.4 of the 1986 ILO code of practice on the radiation protection of workers (ionizing radiations) which contains general principles for informing, instructing and training of workers. The Government is requested to indicate the measures taken or envisaged to ensure that workers are adequately instructed in the precautions to be taken for their protection in conformity with Article 9, paragraph 2, of the Convention.

Article 11. The Committee notes the Government’s indication to the effect that the workers designated to perform radiation work are presently monitored by TLD radiation monitoring badges supplied by the universities of the West Indies. The Committee requests the Government to explain more in detail the characteristics of this specific monitoring and the manner in which it is carried out.

Article 12. With regard to appropriate medical examination of workers directly engaged in radiation work, the Government indicates that a medical examination is still a prerequisite for an appointment to the public service. In addition, all workers assuming duties at the hospital are tested subsequently after they have taken up their work on a voluntary basis. In this respect, the Committee wishes to underline that subsequent medical examinations of workers directly engaged in radiation work have to be carried out on a mandatory basis and thus cannot be left to the discretion of the workers concerned whether or not they want to undergo a medical examination once they have been employed. The Government is accordingly requested to indicate the measures taken or envisaged ensuring that all workers engaged in radiation work are obliged to undergo appropriate medical examinations, not only prior to their employment, but also subsequently at appropriate intervals.

Article 13. With regard to the measures to be taken in emergency situations, the Government indicates that no such measures are in place yet, but that it is hoped that the development of emergency plans will be one of the tasks of the proposed regulatory body. In this respect, the Committee states that the ACRP is responsible, inter alia, to prepare a detailed radiation protection programme for Barbados (point (3) of the Advisory Committee on Radiation Protection - Terms of reference). The Committee thinks that the preparation of measures to be taken in emergency situations would form an integral part of its task. The Committee therefore hopes that the ACRP will resume its functions in the near future and that it will, within the framework of its duties, elaborate plans for emergency situations. To this effect, the Committee invites the Government again to refer to its 1987 general observation under the Convention as well as to paragraphs 16 to 27 of its 1992 general observation under the Convention concerning occupational exposure during and after an emergency which intend to give guidance regarding the measures to be taken in emergency situations. The Committee hopes that the Government will report on any progress made in this respect.

Article 14. In absence of any additional information regarding alternative employment of workers with premature accumulation of their lifetime dose, the Committee requests once again the Government to indicate whether and, if so, under which provisions, 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.

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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.

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The Committee recalls that in a communication of December 1995 the Government has indicated that a comprehensive report was being compiled and would be forwarded shortly. The Committee notes that no report was since received. The Committee hopes that the Government will provide a report for examination by the Committee at its next session containing full information on the following points raised in its previous direct request.

1. The Committee noted the Government's indication that information concerning the measures to be taken in abnormal circumstances would be supplied in the Government's next report. The Committee also recalls from an earlier report that devising an emergency plan in case of accidents involving radioactive material is one of the functions of the Advisory Committee established since June 1978, which is also to keep records of designated radiation workers, their terms of employment, medical examinations, etc., and of sources of radiation, their type and location, as well as to register and license industrial sources. With regard to emergency planning, the Committee would call the Government's attention 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).

2. Under Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention, all appropriate steps shall be taken to ensure effective protection of workers against ionizing radiation and to review maximum permissible doses of ionizing radiation in the light of current knowledge. Referring to its general observation under the Convention, the Committee would draw the Government's attention to the revised dose limits for exposure to ionizing radiation established on the basis of new physiological findings by the International Commission on Radiological Protection (ICRP) in its 1990 Recommendations and contained also in the 1994 Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources of 1994, developed under the auspices of the IAEA, ILO and WHO, and three other international organizations, which are based on the ICRP recommendations. In its report for the period ending 30 June 1992, the Government had indicated that the revisions made in 1972 to the United Kingdom Code of Practice for the Protection of Persons against Ionizing Radiation arising from Medical and Dental Use were being followed in Barbados. The United Kingdom has indicated in its latest reports that it was revising its Code of Practice concerning the exposure of persons to ionizing radiation in light of the new ICRP recommendations. The Government is requested to indicate the steps taken or being considered in relation to the matters raised in the conclusions to the general observation.

3. In earlier reports, the Government had indicated that the only work involving exposure to ionizing radiation in Barbados was in the medical field. The Government has indicated in its latest report that no progress has been made in licensing and registering industrial sources of radiation. The Committee requests the Government to supply information on the activities of the Advisory Committee referred to in point 1 above, including details of the records kept by that Committee concerning radiation workers and sources of radiation, within and outside the medical field.

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The Committee notes the information provided in the Government's latest report in reply to its previous direct request and the General Observation of 1987.

1. The Committee notes the Government's indication that information concerning the measures to be taken in abnormal circumstances will be supplied in the Government's next report. The Committee also recalls from an earlier report that devising an emergency plan in case of accidents involving radioactive material is one of the functions of the Advisory Committee established since June 1978, which is also to keep records of designated radiation workers, their terms of employment, medical examinations, etc., and of sources of radiation, their type and location, as well as to register and license industrial sources. With regard to emergency planning, the Committee would call the Government's attention to paragraphs 16 to 27 of its General Observation under this 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).

2. Under Article 3, paragraph 1 and Article 6, paragraph 2 of the Convention, all appropriate steps shall be taken to ensure effective protection of workers against ionising radiations and to review maximum permissible doses of ionising radiations in the light of current knowledge. Referring to its General Observation under the Convention, the Committee would draw the Government's attention to the revised dose limits for exposure to ionising radiations established on the basis of new physiological findings by the International Commission on Radiological Protection (ICRP) in its 1990 Recommendations. In its report for the period ending 30 June 1982, the Government had indicated that the revisions made in 1972 to the United Kingdom Code of Practice for the Protection of Persons against Ionising Radiation arising from Medical and Dental Use were being followed in Barbados. The United Kingdom has indicated in its latest report that it would revise its Code of Practice concerning the exposure of persons to ionising radiations in light of the new ICRP recommendations. The Government is requested to indicate, in its next report, the steps taken or being considered in relation to the matters raised in the conclusions to the General Observation.

3. In earlier reports, the Government had indicated that the only work involving exposure to ionising radiations in Barbados was in the medical field. The Government has indicated in its latest report that no progress has been made in licensing and registering industrial sources of radiation. The Committee requests the Government to supply in its next report information on the activities of the Advisory Committee referred to in point 1 above, including details of the records kept by that Committee concerning radiation workers and sources of radiation, within and outside the medical field.

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1. The Committee notes the information supplied by the Government in response to points 1 and 3 of its 1987 direct request.

2. The Committee further notes that the procedure for registering and licensing industrial sources of radiation has not yet been finalised. It reiterates the hope that prior to the licensing of any industrial source, the Government will introduce national provisions ensuring the application of the Convention to such sources (in consultation with representatives of employers and workers as required by Article 1 of the Convention). The Committee would be grateful if the Government would continue providing in its reports information on the progress made in this field.

3. The Committee also draws the Government's attention to its general observation of 1987 concerning the protection of workers against ionising radiations in abnormal situations. It would be grateful if the Government would supply in its next report the information requested in the last paragraph of that observation on whether special provisions have been taken or are envisaged concerning the measures to be taken in abnormal situations.