Start with the source and the authorised activity
CSN Instruction IS-41 of 26 July 2016 establishes requirements for sources in categories 1, 2 and 3, and prudent management practices for sources below those categories but above exemption limits. It addresses holders of radioactive installations and other activities authorised to handle sources. Its exclusions include certain sources identified in Royal Decree 1308/2011 and sources within protected areas of specified nuclear facilities.
CSN’s current instruction register continues to list IS-41. CSN instructions are binding for the parties within their scope after publication in the BOE. The original adaptation period is a historical transition, not a new period available to an operator today.
Responsibility and the protection plan
The holder is responsible for categorising sources and for establishing, maintaining and updating their protection arrangements. For category 1, 2 and 3 sources, IS-41 requires a physical protection plan. Its requirements include documented responsibilities, source accounting, staff training and procedures for relevant notifications.
The underlying framework is Royal Decree 1308/2011. Article 24 links the installation’s protection system and plan with its operating authorisation, while Article 9 identifies the responsible holder. Sources below category 3 but above exemption limits still require prudent management; they should not be described simply as exempt from protection duties.
A mobile-source transfer is a specific case
IS-41 excludes transport generally, but expressly covers the defined traslado: moving source-containing mobile equipment, devices or containers from the installation to the place of use and back. This distinction matters when identifying the applicable physical protection framework.
Instruction IS-46 of 14 May 2024 establishes transport security requirements for specified nuclear materials and radioactive sources. It excludes defined transfers of category 1, 2 and 3 sources for the authorised activities of their installation, whose physical protection remains covered by IS-41. Its definition requires origin and destination at the same installation, without a change of ownership. A source delivery to another holder should not automatically be treated as this case.
These security provisions do not replace the applicable modal dangerous goods requirements. A movement meeting the security definition of traslado does not, by that fact alone, establish an ADR exemption.
Review arrangements through an appropriate channel
As a practical starting point, identify the authorised activity, holder, source categories, current authorisation and applicable instruction. Review the responsibilities and document revisions with the people competent for the installation and the operation. Use the official texts to resolve scope questions before assuming that one plan covers every movement.
Protection plans and related information require appropriate confidentiality. Article 5 of Royal Decree 1308/2011 and IS-41’s information-protection requirements should guide how documents are shared. Avoid including detailed protection arrangements in an ordinary public enquiry.
DGSA advisory services can help review the interface with dangerous goods transport responsibilities. Contact DGSA with a general description of the activity so that the appropriate review and document-sharing arrangements can be agreed.