The Canadian Industrial Radiation Safety Association (CIRSA) has been striving to establish a good working relationship with CNSC on behalf of many licensees within the industrial radiography industry. Our membership consists of licensees who have a genuine vested interest in radiation safety and compliance to the regulatory requirements.
CIRSA is of the opinion that CNSC would like to improve communications and its relationship with all licensees, including the industrial radiography industry. Our association believes that improving communications provides an opportunity to strategically work together and develop a mutually beneficial working relationship with the CNSC.
In our review of the CNSC annual report, it is obvious that we both have the same interests in protection of Canadians and the environment. Our association believes that licensees are a key stakeholder and should have a legitimate voice as related to both social and economic factors related to our industry.
The CIRSA organization has considerable influence on industrial radiography safety through our membership. Our industry has been steadily progressing and improving radiation safety culture amongst industrial radiography licensees over the past several years. Overall our industry is passionate about the work they do and are a hardworking, very safe and reasonably compliant industry. Our association desires and supports having licensees play an active role in the development and implementation of solutions to industrial radiography problems, rather than be continually talked at by the regulator.
This industry is well educated and is concerned that as stakeholders we are often poorly consulted by the CNSC. Some examples of areas where we see a need for improved consultation and increased involvement:
- Industry best practises required to ensure the safety of our workers and the public.
- Communications between CNSC staff and the licensees regarding the expectations for regulatory initiatives.
- The process for development and implementation of regulations and licence conditions.
- An improved forum for consultation meetings. We feel we have been in more of a “talked at”, than a “talked with” platform.
- CNSC does not understand that our members are in a service industry that plays a key role in the inspection of equipment to ensure the safety of the public and the protection of the environment.
- Sharing of safety sensitive information such as industry related incidents. These would likely prove to be a very preventive measure for stakeholders to have this knowledge and then establish common goals and objectives to correct.
- Consultation for regulatory amendments or interpretation has not been very transparent.
- Develop a culture between the CNSC and Licensees that will favour fair business practices and improved understanding.
- Stakeholder participation in EDO certification program.
Regularly scheduled meeting to present information on our association’s progress, influence on the industry, and opportunities to improve radiation safety within Canada. We would also like to discuss how we could improve our working relationship together with a commitment to establishing a clear, transparent and practical regulatory program for the radiography industry.