With the ordinance on the further modernization of radiation protection law published at the beginning of December 2018, radiation protection law in Germany was comprehensively amended.
In view of the fact that naturally occurring radioactive material – i.e. natural radionuclides – can occur as a by-product in foundry chemical products, a collection of information has been compiled. It is intended to answer possible questions in this context and provide access to further sources of information.
Background to communication
On 5 December 2018, the “Ordinance on the Further Modernization of Radiation Protection Law” was published in the Federal Law Gazette Part I (No. 41, p. 2034), Article 1 of which is the new “Ordinance on Protection against Ionizing Radiation”(Radiation Protection Ordinance– StrlSchV). The StrlSchV specifies the requirements of the Radiation Protection Act (StrlSchG), which implements the requirements of European Directive 2013/59/Euratom. The StrlSchV came into force on December 31, 2018. This represents a comprehensive amendment to radiation protection law in Germany. One aspect of the Radiation Protection Act (StrlSchG) includes regulations on substances that exhibit natural radioactivity.
Foundry chemical products with natural radioactivity
Natural radioactivity is caused by radionuclides of natural origin. These radionuclides have been present in nature since the formation of earth matter (minerals). In principle, therefore, four classes of foundry chemical products, which may contain naturally occurring radionuclides, are affected as radiation sources by the amendment to the StrlSchG and the requirements of the new StrlSchV:
- Foundry sands
- Finishing
- Refractory materials
- Inorganic binder systems
Requirements from German radiation protection law
With regard to naturally occurring radioactivity, German radiation protection law only requires specific measures to protect occupationally exposed persons beyond the general precautionary principle under certain conditions.
1. restriction to certain areas of activity
- § Section 55 (1) and Annex 3 StrlSchG The “processing of substances containing zirconium in the manufacture of refractory materials” was newly included in the Radiation Protection Act as an area of activity in which radiation protection measures may be necessary. This change results in requirements for an assessment of radiation exposure in accordance with Section 55 StrlSchG, for which there are transitional provisions until December 31, 2020. If this assessment shows that the effective dose may exceed the value of 1 millisievert per calendar year (1 mSv/a), further measures are required in accordance with Section 56 StrlSchG.
2. product responsibility for goods
- § Section 153 (1) StrlSchG Manufacturers, suppliers, distributors or owners of goods that may cause “other existing exposure situations” as a result of their radioactivity are designated as responsible. In the supply chain of foundry chemical products, for example, indications of low-level radioactivity due to naturally occurring radionuclides have recently been communicated. Irrespective of this, the following applies: Waste resulting from the use of foundry chemical products with natural radioactivity is not radioactive residue according to § 5 paragraph 32 and Annex 1 StrlSchG.
Hazard and hazard minimization
Natural radiation exposure for humans is made up of external terrestrial and cosmic radiation exposure (“background radiation”) and internal radiation exposure through the intake of natural radionuclides via respiration or food. In principle, everyone is exposed to background radiation from natural sources, which can vary greatly depending on the region. In Germany, for example, the average natural radiation exposure is 2.1 millisieverts per year (mSv/a), but this can vary between 1 mSv/a and 10 mSv/a depending on where you live, your diet and lifestyle [see BfS website: “Radioactivity in the environment”]. DISCLAIMER: This compilation of specialist information for practitioners on the operational handling of foundry chemical products containing natural radionuclides in no way releases them from the obligation to observe the statutory regulations. This collection of information has been compiled with great care. Nevertheless, the authors and the Industrieverband Gießerei-Chemie e.V. accept no liability for the correctness of the information, notes, advice or for any printing errors. In addition to natural background radiation, people can be exposed to additional radiation doses through the use of radioactivity in medicine (X-ray diagnostics < 0.01 – 1 mSv) and technology. Medical applications account for almost half of the average annual radiation exposure, while everyday technical applications (e.g. hand luggage security checks) generally cause a significantly lower radiation exposure [see BfS websites: “Applications in medicine“; “Applications in everyday life and technology“].
The aim of radiation protection is to reduce additional radiation exposure as far as practically possible. An additional exposure of less than 1 millisievert per calendar year (mSv/a) does not require any special radiation protection measures. When using foundry chemical products that exhibit natural radioactivity, the following types of exposure may occur:
1. exposure to an external radiation source
- Influenced by quantity, distance, shielding and duration of exposure
2. incorporation by inhalation
- Inhalation of material dusts with natural radioactivity
The processing of foundry chemical products containing natural radioactivity must first be checked on the basis of the information in the manufacturer’s safety data sheet. Due to the precautionary principle, an exposure assessment must be carried out for the respective workplace and activity in accordance with § 55 StrlSchG. Further measures in accordance with radiation protection law are not required if an effective dose of 1 mSv per calendar year is not exceeded. Measures under occupational health and safety law, e.g. with regard to the inhalation of dusts, remain unaffected. Only above an effective dose of 1 mSv per calendar year are any requirements under radiation protection law to be met (e.g. notification to the authorities, appointment of radiation protection officers). The limit value for the effective dose for the protection of persons occupationally exposed to radiation is 20 mSv/a (Section 78 (1) StrlSchG), whereby lower limit values apply for groups of persons particularly worthy of protection. When working with foundry chemical products that exhibit natural radioactivity, this dose limit is not reached if work is carried out correctly and occupational safety is observed! The main recommendation for action to reduce the dose is therefore to minimize dust exposure and to regulate distance. For example, permanent workstations should not be located in the immediate vicinity of the mold storage area or supply warehouse. Furthermore, the following occupational safety measures are recommended in accordance with the hierarchy of measures (STOP):
- Storage separate from workstations, spatial separation
- Automation of process steps
- Shielding, enclosure, encapsulation
- Maximization of distances
- Local extraction, optimization of room air exchange
- Optimization of processes with regard to dust generation
- Reduction of the quantities stored at the workplace
- No unnecessary people at the workstations, access control
- Limitation of the duration of exposure (working time in the danger zone)
- Respiratory protection (subordinate to technical & organizational measures)
In addition, exposure must be monitored and possible release into the environment (exhaust air, waste water) must be controlled.
Overall assessment
German radiation protection law assumes that an additional exposure of 1 mSv/a due to occupational exposure can be tolerated without further measures. Beyond the general precautionary principle, no specific measures in accordance with StrlSchG and StrlSchV are therefore required in connection with occupational radiation protection (e.g. notification to the competent authority, appointment of radiation protection officers) if this additional exposure is complied with.
List of literature / information sources
Foundry Lexicon, Publisher & Editor: Foundry Technologies & Engineering GmbH; Link: https://www.giessereilexikon.com/
Act on Protection against the Harmful Effects of Ionizing Radiation (Radiation Protection Act – StrlSchG) of 27 June 2017 (Federal Law Gazette I p. 1966); Link: http://www.gesetze-im-internet.de/strlschg/index.html
Ordinance on Protection against the Harmful Effects of Ionizing Radiation (Radiation Protection Ordinance – StrlSchV) of 29 November 2018 (Federal Law Gazette I p. 2034, 2036); Link: http://www.gesetze-im-internet.de/strlschv_2018/index.html
EU Directive laying down basic safety standards for protection against the dangers arising from exposure to ionizing radiation (DIRECTIVE 2013/59/EURATOM) of 5 December 2013 (Official Journal of the European Union 2014, L 13, p. 1); Link: https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX:32013L0059
“Code of practice for handling zircon sand in iron and steel foundries, glassworks and refractory industry plants”; Staatliche Betriebsgesellschaft für Umwelt und Landwirtschaft, Sachsen 2011; Link: Zircon sand leaflet.pdf
Federal Office for Radiation Protection (BfS), Willy-Brandt-Straße 5, D-38226 Salzgitter – various websites, including “Radioactivity in the environment “: http://www.bfs.de/DE/themen/ion/umwelt/umwelt_node.html
“Applications in everyday life and technology”
“Radiation Protection and NORM Residue Management in the Zircon and Zirconia Industries”; Safety Reports Series No. 51, International Atomic Energy Agency (IAEA), Vienna 2007; Link: https://www.iaea.org/publications/7673/radiationprotection-and-norm-residue-management-in-the-zircon-and-zirconia-industries
“Determination and assessment of radiation exposure at workplaces with naturally occurring radioactive materials (NORM)” Federal Office for Radiation Protection, Project No. 3616S12343. Nuclear Control & Consulting GmbH, Braunschweig September 2017; Link: https://www.bmu.de/fileadmin/Daten_BMU/Pools/Forschungsdatenbank/fkz_361 6_S_12343_strahlenexposition_arbeitsplaetze.pdf
Best available techniques (BAT) in selected industrial sectors Sub-project 3: Foundries, Volume 3: Technician survey 2012, Federal Environment Agency research code 3710 44316 TV 3; Study conducted by: Institut für Gießereitechnik gGmbH, Dessau December 2014; Link: Innovative techniques Vol. 3
