Radiation protection in activities with natural radiation materials

General information

In some areas in which people are present for occupational reasons, naturally occurring radioactive substances can lead to increased radiation exposure.

With the radiation protection law that entered into force on 1 August 2020, the radiation protection regulations concerning artificial radioactive substances and natural radioactive substances have largely been harmonised. For this reason, the provisions for both areas are anchored in the Allgemeine Strahlenschutzverordnung (General Radiation Protection Ordinance – AllgStrSchV).

Companies that carry out activities involving naturally occurring radioactive materials are now also subject to the licensing or notification requirements of the Strahlenschutzgesetz (Radiation Protection Act – StrSchG), unless an exemption is granted by the AllgStrSchV.

The areas of activity in which increased radiation exposure of workers is possible through working with natural radioactive materials are listed in Annex 3 to the AllgStrSchV. These are the following areas:

  • Industry sectors, including research and relevant secondary processes
    • Extraction and industrial processing of rare earth elements
    • Production of thorium compounds and of thorium-containing products
    • Production of TiO2 pigments from minerals, for example ilmenite or rutile
    • Processing of raw phosphates, for example thermal phosphorus production and production of phosphate fertiliser and phosphoric acid
    • Cement production, including maintenance of clinker kilns
    • Zircon- and zircon oxide industry
    • Oil and natural gas industry
    • Deep geothermal energy
    • Primary iron production
    • Tin, lead and copper smelting
    • Mining of ores other than uranium ore
    • Processing of groundwater, provided no residues can arise in the process
  • Industrial or commercial activities
    • Welding of thoriated electrodes and AC welding using thoriated electrodes
    • Use of thorium-containing products other than those mentioned above, for example incandescent gas mantles
    • Use of material rich in natural uranium or thorium, for example as abrasive in high-pressure water jet cutting and sandblasting
    • Practices during which exposures from residues may occur, for example maintenance work, especially servicing and dismantling of heat-resistant lining made of material containing zircon, cleaning or reconstruction or dismantling of pipes and technical facilities with pumps and valves, servicing as well as reconstruction and dismantling of filter systems and flue gas scrubbers

If residues enriched with natural radioactive Materialsaccumulate during work processes, radiation protection measures must also be taken here.

If a company falls within the scope of one of the areas of activity mentioned before, its owner must commission a  certified monitoring service. The assignment includes a dose estimate for those workers who could be exposed to increased radiation exposure and, if necessary, the assessment of the activity concentration of residues and radioactive substances discharged with air or wastewater.

Please note

These estimates and assessments shall be repeated periodically (five or ten years), with cycles depending on whether the company is subject to a licensind or reporting requirement. In addition, they must be repeated in the event of changes relevant to radiation protection. Companies that are not subject to licensing or notification requirements but fall into one of the areas of activity also have to carry out a new inspection every ten years.

Depending on the results of the estimates and assessments, the companies are subject to either an authorisation requirement, a notification requirement or exemption from the notification requirement. The latter possibility exists if the results of the assessment and estimates suggest that radiation protection relevance is very low.

An enterprise is subject to licensing if workers are to be classified as "exposed workers" or if the discharges or residues exceed certain values specified in the AllgStrSchV. In this case, the provisions for practices requiring a licence will apply.

A company is obliged to notify if the activity concentrations of the residues are increased but do not exceed the limits for the obligation to obtain a licence and the expected radiation doses of the workers and the discharge values are not increased. The AllgStrSchV specifies values for activity concentrations above which they are to be considered relevant to radiation protection.

If the company is subject to licencing or notification requirements, it must take appropriate technical and/or organisational measures to ensure that radiation exposure of persons is kept as low as reasonably achievable. The company is best advised to clarify which measures are appropriate with the monitoring service.

Compliance with radiation protection is periodically monitored by the authority. In the case of companies subject to licencing at least every three years and in the case of companies subject to notification at least every five years.

During the residue check, the monitoring body determines whether these can be released without restrictions or restrictions. In the first case, there are no official restrictions on any future use of the released materials. In the second case, any future use of the released materials is subject to official restrictions (e.g. type of landfill, restrictions on types of recycling).

Enterprises affected

Companies in areas of activity listed in Annex 3 of the AllgStrSchV

Deadlines

Companies according to Annex 3 to the AllgStrSchV:

  • Immediate initiation of the dose estimation or, as may be the case, after modification of radiation protection relevant parameters (for example, extension/modification of the work process)
  • If radioactive material is discharged:
    • initiation of the assessment of the activity concentration of the effluent without undue delay
    • If the activity concentration exceeds the values in Table 3 of Section C of Annex 2: initiation of dose estimation for the population without undue delay
  • If there are any residues:
    • initiation of the assessment of the activity concentration of the residues without undue delay
    • If the activity concentration exceeds the values in Annex 1, Section D, Table 3, column 2: initiation of dose estimation for the population without undue delay
  • Repetition of the dose estimate every five years (if exposed workers are present), otherwise every ten years

Please note

Depending on the result of the dose estimation and the assessment of the activity concentrations, further deadlines may arise. This will be the case if the results of the activity assessment make the company's activities subject to licensing or notification requirements.

Competent authority

Procedure

  • Companies subject to authorisation:
    See chapter "Activities subject to authorisation".
  • Companies subject to notification obligations:
    The application to notify the activity must contain the documents specified in section 15 of the AllgStrSchV.

Further information

A list of the certified monitoring servicesGerman text and more detailed information as well as brochures are available on the website of the Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology.

Legal bases

Last update: 1 January 2024

Responsible for the content: Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology