Radiation Protection Convention, 1960 (No. 115) - Slovakia (Ratification: 1993)

Replies received to the issues raised in a direct request which do not give rise to further comments (CEACR) - adopted 2024, published 113rd ILC session (2025)

The Committee notes the information provided by the Government, which answers the points raised in its previous direct request and has no further matters to raise in this regard.

Direct Request (CEACR) - adopted 2015, published 105th ILC session (2016)

The Committee notes the information provided by the Government in its report in reply to its previous comments concerning Article 7(2) of the Convention on the prohibition against employing young persons under 16 in work involving exposure to radiation.

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.

Article 6(2) of the Convention. Maximum permissible doses. The Committee previously noted that section 9(2) of Regulation No. 345/2006, on basic safety requirements for protection of the health of workers and the general public against the effects of ionizing radiation, prescribes that the permissible dose to the lens of the eye is 50 mSv per year. With reference to paragraphs 11 and 32 of its general observation of 2015, the Committee would like to draw the Government’s attention to the most recent recommendations of the International Commission of Radiological Protection that recommend, for radiation workers, an equivalent dose to the lens of the eye of 20 mSv per year, averaged over defined periods of five years, with no single year exceeding 50 mSv per year. The Committee requests the Government to provide information on measures taken to review the permissible doses established with respect to the lens of the eye, in light of current knowledge.

Article 14. Discontinuation of assignment to work involving exposure to ionizing radiation pursuant to medical advice and alternative employment. The Committee previously noted that pursuant to section 125 of the Labour Code, workers transferred to other work due to a risk of contracting an occupational disease are entitled to supplementary pay, for a maximum period of 12 consecutive months from the day of the transfer, if the transfer would cause the workers to receive a lower salary. In this respect, the Committee notes the Government’s indication that if the worker is unable to return to their original post, section 54 of the Labour Code provides that they are to come to an agreement with their employer on a change of working conditions. The Committee requests the Government to provide information on the application in practice of sections 54 and 125 of the Labour Code to workers who, for medical reasons, can no longer perform work involving exposure to ionizing radiations.

Direct Request (CEACR) - adopted 2010, published 100th ILC session (2011)

Further to its observation the Committee requests the Government to provide additional information on the following points.

Article 7(2) of the Convention. Prohibition against employing young persons under 16 in work involving exposure to radiation. With reference to its previous comment the Committee notes the information provided by the Government in its report that section 13 of Regulation No. 345/2006, Coll. provides that the dose limits for apprentices and students “until the calendar year in which they reach the age of sixteen years” shall be the same as the limits set for members of the public in section 15. In the view of the Committee, this provision appears to fall short of a prohibition against employing young persons under 16 in work involving exposure to radiation as required by this provision of the Convention. The Committee once again requests the Government to provide further information on how full effect is given, in law and in practice, to this provision of the Convention.

Article 14. Alternative employment or other measures offered for maintaining income where continued assignment to work involving exposure is medically inadvisable. With reference to its previous comment, the Committee notes with interest that section 125 of the Labour Code regarding wages for performance of other work provides, inter alia, that workers transferred to other work due to a risk of contracting an occupational disease are entitled to supplementary pay at least to the level of the average earnings they received before the transfer if such transfer would cause the workers to receive a lower salary. Such supplementary pay is payable up to a maximum period of 12 consecutive months from the day of the transfer. The Committee requests the Government to indicate what measures are offered to transferred workers after the expiry of the 12-month period referred to in section 125 of the Labour Code.

Exceptional exposure of workers in emergency situations. The Committee notes the information provided in response to its previous comments that section 14 of Regulation No. 345/2006 regulates the exceptional circumstances in which the exposure to radiation in excess of the dose limits for workers set in section 11 of the same Regulation shall be authorized. It is provided that: (a) such exposure must be for a limited period and undertaken only by volunteer workers; (b) activities must be carried out in certain working areas; and (c) the exposure limits authorized may not exceed double the dose limits for workers set in section 11 of the Regulation. With reference thereto the Committee wishes to draw the Government’s attention to paragraphs 17, and 21–22 of its 1992 general observation under this Convention and the notion of “planned special exposure” as a means of protection for emergency work was largely abandoned by the International Commission on Radiological Protection (ICRP) in 1990. With reference to its previous comment, the Committee reiterates its request to the Government to indicate measures taken or envisaged in order to ensure compliance with the ICRP recommendation referred to in its 1992 general observation under the Convention in this respect.

Observation (CEACR) - adopted 2010, published 100th ILC session (2011)

Legislation. The Committee notes the information regarding newly adopted legislation including Act No. 355/2007, Coll. on Protection, Support and Development of Public Health and Regulation No. 345/2006, Coll. on basic safety requirements for protection of the health of workers and the general public against the effects of ionizing radiation, which give effect, inter alia, to Article 12 of the Convention.

Articles 3 and 6 of the Convention. Permitted dose limits. Pregnant workers. Article 7(1)(b). Exposure limits for young persons between 16 and 18 years of age. With reference to its previous comments, the Committee notes with satisfaction the information that Regulation No. 345/2006, Coll., referred to above, provides, inter alia,  that the exposure limit for pregnant women working in a workplace with sources of ionizing radiation shall be such that from the time when the woman informs the operator until the end of her pregnancy the sum of the effective doses from external exposure and the committed effective doses from internal irradiation of the foetus does not exceed 1 mSv, and that the prescribed dose limits for exposure to radiation of young persons between 16 and 18 years of age are in conformity with the relevant exposure limits recommended by the International Commission on Radiological Protection (ICRP), that is: (a) an effective dose of 6 mSv in a year; (b) an equivalent dose to the lens of the eye of 50 mSv in a year; and (c) an equivalent dose to the extremities or the skin of 150 mSv in a year.

The Committee is raising other points in a request addressed directly to the Government.

Direct Request (CEACR) - adopted 2009, published 99th ILC session (2010)

The Committee notes that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

The Committee notes the information contained in the Government’s report, including reference to relevant provisions in the Labour Code and Decree No. 12/2001 of the Ministry of Health concerning radiation protection requirements.

Articles 3 and 6 of the Convention. Permitted dose limits. Pregnant workers. The Committee notes that with respect to dose limits for exposure to radiation for pregnant women, section 5 of Decree No. 12/2001, provides that “the effective dose limit from the interior exposure of the foetus shall not exceed 1 mSv counting from the day in which the pregnant woman informs the employer of her pregnancy to the end of the pregnancy”. The Committee notes with interest that this limit is half of the limit of 2 mSv recommended by the International Commission on Radiological Protection (ICRP) referred to in the 1992 general observation under the Convention (paragraph 13). The Committee requests the Government to provide additional information on the application in practice of this provision.

Article 7, paragraph 1(b). Exposure limits for young persons between 16 and 18 years of age. The Committee notes that the dose limits recommended by the ICRP as regards young workers are intended to protect apprentices who are training for employment involving exposure to radiation and for students aged 16 to 18 who are required to use sources in the course of their studies. However, the Committee notes that the scope of section 7 of Decree No. 12/2001 “Limits of radiation exposure for school children and students” is not limited to these categories of persons. Furthermore, while an effective dose limit of 6 mSv in a year corresponds to the limits recommended by the ICRP for this category of persons, section 7 of Decree No. 12/2001 provides for an equivalent dose limit of 150 mSv per year for the eye which is three times more than the limit recommended by the ICRP and an equivalent dose to the extremities of the skin of 500 mSv in a year which is more than three times the limit of 150 mSv recommended by the ICRP. The Committee requests the Government to indicate measures taken or envisaged in order to ensure a full application of the Convention in these respects.

Article 7, paragraph 2. Prohibition against employing young persons under 16 in work involving exposure to radiation. With reference to subparagraph 2 of section 7 of Decree No. 12/2001, which is slightly ambiguous on this point, the Committee requests the Government to clarify whether it is clearly prohibited, in law as well as in practice, to engage young persons under the age of 16 in work which involves exposure to radiation.

Exceptional exposure of workers in emergency situations. The Committee notes that subparagraphs 2 and 3, section 8, of Decree No. 12/2001 set certain exceptionally permitted increased dose limits applicable in emergency situations and that subparagraph 4 of the same section provides that the limits set in these aforementioned subparagraphs 2 and 3 “shall not apply to cases where human life is rescued or the development of a radiation accident with possibly serious social and economic consequences is prevented”. In this regard, the Committee wishes to draw the Government’s attention to item 35(c)(iii) of the conclusions of the Committee’s 1992 general observation under this Convention call for a strict definition of circumstances in which exceptional exposure of workers, exceeding the normally tolerated dose limit, is to be allowed for immediate and urgent remedial work; that work must be strictly limited in scope and duration to what is required to meet an acute danger to life and health; exceptional exposure of workers is neither justified for the purpose of rescuing items of high material value nor, more generally, because alternative techniques of intervention, which do not involve such exposure of workers, would involve excessive expenses. In light of the foregoing, the Committee requests the Government to indicate measures taken or envisaged in order to ensure a full application of the Convention in these respects.

Article 12. Medical examinations. The Committee notes that current legislation which gives effect to this provision is Act No. 277/1994 on health care (as amended), and that the Government indicates that an executive decree to this Act is under preparation. The Committee hopes that such a decree will soon be adopted and asks the Government to provide a copy of the text once it is adopted.

Article 14. Alternative employment or other measures offered for maintaining income where continued assignment to work involving exposure is medically inadvisable. The Committee notes that section 55, paragraph 2, of the Labour Code includes an obligation for the employer to transfer an employee to other work if, according to medical opinion, the employee should not perform its work due to occupational disease or the threat of such disease. Against this background, the Committee wishes to draw the attention of the Government to paragraph 32 of the 1992 general observation under the Convention where it is indicated that every effort must be made to provide the workers concerned with suitable alternative employment, or to maintain their income through social security measures or otherwise where continued assignment to work involving exposure to ionizing radiations is found to be medically inadvisable. The Committee requests the Government to provide, with its next report, the information concerning the practical application of section 55, paragraph 2, of the Labour Code and the efforts made to provide workers concerned with suitable alternative employment or to offer them other means to maintain their income.

Direct Request (CEACR) - adopted 2006, published 96th ILC session (2007)

1. The Committee notes the information contained in the Government’s report, including reference to relevant provisions in the Labour Code and Decree No. 12/2001 of the Ministry of Health concerning radiation protection requirements.

2. Articles 3 and 6 of the Convention. Permitted dose limits. Pregnant workers. The Committee notes that with respect to dose limits for exposure to radiation for pregnant women, section 5 of Decree No. 12/2001, provides that “the effective dose limit from the interior exposure of the foetus shall not exceed 1 mSv counting from the day in which the pregnant woman informs the employer of her pregnancy to the end of the pregnancy”. The Committee notes with interest that this limit is half of the limit of 2 mSv recommended by the International Commission on Radiological Protection (ICRP) referred to in the 1992 general observation under the Convention (paragraph 13). The Committee requests the Government to provide additional information on the application in practice of this provision. 

3. Article 7, paragraph 1(b). Exposure limits for young persons between 16 and 18 years of age. The Committee notes that the dose limits recommended by the ICRP as regards young workers are intended to protect apprentices who are training for employment involving exposure to radiation and for students aged 16 to 18 who are required to use sources in the course of their studies. However, the Committee notes that the scope of section 7 of Decree No. 12/2001 “Limits of radiation exposure for school children and students” is not limited to these categories of persons. Furthermore, while an effective dose limit of 6 mSv in a year corresponds to the limits recommended by the ICRP for this category of persons, section 7 of Decree No. 12/2001 provides for an equivalent dose limit of 150 mSv per year for the eye which is three times more than the limit recommended by the ICRP and an equivalent dose to the extremities of the skin of 500 mSv in a year which is more than three times the limit of 150 mSv recommended by the ICRP. The Committee requests the Government to indicate measures taken or envisaged in order to ensure a full application of the Convention in these respects.

4. Article 7, paragraph 2. Prohibition against employing young persons under 16 in work involving exposure to radiation. With reference to subparagraph 2 of section 7 of Decree No. 12/2001, which is slightly ambiguous on this point, the Committee requests the Government to clarify whether it is clearly prohibited, in law as well as in practice, to engage young persons under the age of 16 in work which involves exposure to radiation.

5. Exceptional exposure of workers in emergency situations. The Committee notes that subparagraphs 2 and 3, section 8, of Decree No. 12/2001 set certain exceptionally permitted increased dose limits applicable in emergency situations and that subparagraph 4 of the same section provides that the limits set in these aforementioned subparagraphs 2 and 3 “shall not apply to cases where human life is rescued or the development of a radiation accident with possibly serious social and economic consequences is prevented”. In this regard, the Committee wishes to draw the Government’s attention to item 35(c)(iii) of the conclusions of the Committee’s 1992 general observation under this Convention call for a strict definition of circumstances in which exceptional exposure of workers, exceeding the normally tolerated dose limit, is to be allowed for immediate and urgent remedial work; that work must be strictly limited in scope and duration to what is required to meet an acute danger to life and health; exceptional exposure of workers is neither justified for the purpose of rescuing items of high material value nor, more generally, because alternative techniques of intervention, which do not involve such exposure of workers, would involve excessive expenses. In light of the foregoing, the Committee requests the Government to indicate measures taken or envisaged in order to ensure a full application of the Convention in these respects.

6. Article 12. Medical examinations. The Committee notes that current legislation which gives effect to this provision is Act No. 277/1994 on health care (as amended), and that the Government indicates that an executive decree to this Act is under preparation. The Committee hopes that such a decree will soon be adopted and asks the Government to provide a copy of the text once it is adopted.

7.  Article 14. Alternative employment or other measures offered for maintaining income where continued assignment to work involving exposure is medically inadvisable. The Committee notes that section 55, paragraph 2, of the Labour Code includes an obligation for the employer to transfer an employee to other work if, according to medical opinion, the employee should not perform its work due to occupational disease or the threat of such disease. Against this background, the Committee wishes to draw the attention of the Government to paragraph 32 of the 1992 general observation under the Convention where it is indicated that every effort must be made to provide the workers concerned with suitable alternative employment, or to maintain their income through social security measures or otherwise where continued assignment to work involving exposure to ionizing radiations is found to be medically inadvisable. The Committee requests the Government to provide, with its next report, the information concerning the practical application of section 55, paragraph 2, of the Labour Code and the efforts made to provide workers concerned with suitable alternative employment or to offer them other means to maintain their income.

Direct Request (CEACR) - adopted 2003, published 92nd ILC session (2004)

The Committee notes with regret that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

1. Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention. The Committee notes with interest the information provided by the Government in its report, that new legislation is being prepared on health protection against unfavourable effects of ionizing radiation, based on Act No. 272/1994, Coll. of Acts on health protection against ionizing radiation. Referring also to its 1992 general observation on the Convention, the Committee hopes that the Government will soon be in a position to supply information on the provisions adopted that fully apply the Convention and are consistent with the dose limits set out in the 1990 International Commission on Radiation Protection Recommendations, and the 1994 Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources.

2. Emergency exposure situations. Referring to the explanations given in paragraphs 16 to 27 and 35(c) of its 1992 general observation under the Convention, and in the light of paragraphs 233 and 236 of the 1994 International Basic Safety Standards, the Committee hopes that the Government will provide information on the measures taken or contemplated in relation to emergency situations.

3. The provision of alternative employment. With reference to paragraphs 28 to 34 and 35(d) of its 1992 general observation under the Convention, and the principles reflected in paragraphs 96 and 238 of the 1994 International Basic Safety Standards, the Committee requests the Government to provide information on measures taken or contemplated to ensure effective protection of workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur and who may thus be faced with the dilemma that protecting their health means losing their employment.

Direct Request (CEACR) - adopted 2002, published 91st ILC session (2003)

The Committee notes with regret that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

1. Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention. The Committee notes with interest the information provided by the Government in its report, that new legislation is being prepared on health protection against unfavourable effects of ionizing radiation, based on Act No. 272/1994, Coll. of Acts on health protection against ionizing radiation. Referring also to its 1992 general observation on the Convention, the Committee hopes that the Government will soon be in a position to supply information on the provisions adopted that fully apply the Convention and are consistent with the dose limits set out in the 1990 International Commission on Radiation Protection Recommendations, and the 1994 Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources.

2. Emergency exposure situations. Referring to the explanations given in paragraphs 16 to 27 and 35(c) of its 1992 general observation under the Convention, and in the light of paragraphs 233 and 236 of the 1994 International Basic Safety Standards, the Committee hopes that the Government will provide information on the measures taken or contemplated in relation to emergency situations.

3. The provision of alternative employment. With reference to paragraphs 28 to 34 and 35(d) of its 1992 general observation under the Convention, and the principles reflected in paragraphs 96 and 238 of the 1994 International Basic Safety Standards, the Committee requests the Government to provide information on measures taken or contemplated to ensure effective protection of workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur and who may thus be faced with the dilemma that protecting their health means losing their employment.

Direct Request (CEACR) - adopted 2001, published 90th ILC session (2002)

The Committee notes with regret that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

1. Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention. The Committee notes with interest the information provided by the Government in its report, that new legislation is being prepared on health protection against unfavourable effects of ionizing radiation, based on Act No. 272/1994, Coll. of Acts on health protection against ionizing radiation. Referring also to its 1992 general observation on the Convention, the Committee hopes that the Government will soon be in a position to supply information on the provisions adopted that fully apply the Convention and are consistent with the dose limits set out in the 1990 International Commission on Radiation Protection Recommendations, and the 1994 Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources.

2. Emergency exposure situations. Referring to the explanations given in paragraphs 16 to 27 and 35(c) of its 1992 general observation under the Convention, and in the light of paragraphs 233 and 236 of the 1994 International Basic Safety Standards, the Committee hopes that the Government will provide information on the measures taken or contemplated in relation to emergency situations.

3. The provision of alternative employment. With reference to paragraphs 28 to 34 and 35(d) of its 1992 general observation under the Convention, and the principles reflected in paragraphs 96 and 238 of the 1994 International Basic Safety Standards, the Committee requests the Government to provide information on measures taken or contemplated to ensure effective protection of workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur and who may thus be faced with the dilemma that protecting their health means losing their employment.

Direct Request (CEACR) - adopted 2000, published 89th ILC session (2001)

The Committee notes that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

1.  Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention.  The Committee notes with interest the information provided by the Government in its report, that new legislation is being prepared on health protection against unfavourable effects of ionizing radiation, based on Act No. 272/1994, Coll. of Acts on health protection against ionizing radiation. Referring also to its 1992 general observation on the Convention, the Committee hopes that the Government will soon be in a position to supply information on the provisions adopted that fully apply the Convention and are consistent with the dose limits set out in the 1990 International Commission on Radiation Protection Recommendations, and the 1994 Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources.

2.  Emergency exposure situations.  Referring to the explanations given in paragraphs 16 to 27 and 35(c) of its 1992 general observation under the Convention, and in the light of paragraphs 233 and 236 of the 1994 International Basic Safety Standards, the Committee hopes that the Government will provide information on the measures taken or contemplated in relation to emergency situations.

3.  The provision of alternative employment. With reference to paragraphs 28 to 34 and 35(d) of its 1992 general observation under the Convention, and the principles reflected in paragraphs 96 and 238 of the 1994 International Basic Safety Standards, the Committee requests the Government to provide information on measures taken or contemplated to ensure effective protection of workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur and who may thus be faced with the dilemma that protecting their health means losing their employment.

Direct Request (CEACR) - adopted 1995, published 83rd ILC session (1996)

1. Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention. The Committee notes with interest the information provided by the Government in its report, that new legislation is being prepared on health protection against unfavourable effects of ionizing radiation, based on Act No. 272/1994, Coll. of Acts on health protection against ionizing radiation. Referring also to its 1992 General Observation on the Convention, the Committee hopes that the Government will soon be in a position to supply information on the provisions adopted that fully apply the Convention and are consistent with the dose limits set out in the 1990 International Commission on Radiation Protection Recommendations, and the 1994 Basic Safety Standards for Protection against Ionizing Radiation and for the Safety of Radiation Sources.

2. Emergency exposure situations. Referring to the explanations given in paragraphs 16 to 27 and 35(c) of its 1992 General Observation under the Convention, and in the light of paragraphs 233 and 236 of the 1994 International Basic Safety Standards, the Committee hopes that the Government will provide information on the measures taken or contemplated in relation to emergency situations.

3. The provision of alternative employment. With reference to paragraphs 28 to 34 and 35(d) of its 1992 General Observation under the Convention, and the principles reflected in paragraphs 96 and 238 of the 1994 International Basic Safety Standards, the Committee requests the Government to provide information on measures taken or contemplated to ensure effective protection of workers who have accumulated exposure beyond which an unacceptable risk of detriment is to occur and who may thus be faced with the dilemma that protecting their health means losing their employment.

Direct Request (CEACR) - adopted 1995, published 82nd ILC session (1995)

The Committee would draw the Government's attention to the matters raised in its General Observation of 1992 on the basis of the new findings set out in the 1990 Recommendations of the International Commission on Radiological Protection. It requests the Government to indicate the measures taken to ensure the effective protection of workers in the light of current knowledge, in conformity with Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention, and to indicate the steps taken or being considered in relation to the various points raised in the conclusions to the 1992 general observation on the Convention.

[The Government is requested to supply a detailed report on the Convention in 1995.]

Direct Request (CEACR) - adopted 1994, published 81st ILC session (1994)

The Committee notes from the Government's report that there has been no change in the application of the Convention.

The Committee would draw the Government's attention to the matters raised in its General Observation of 1992 on the basis of the new findings set out in the 1990 Recommendations of the International Commission on Radiological Protection. It requests the Government to indicate the measures taken to ensure the effective protection of workers in the light of current knowledge, in conformity with Article 3, paragraph 1, and Article 6, paragraph 2, of the Convention, and to indicate the steps taken or being considered in relation to the various points raised in the conclusions to the General Observation.