Instruction IS-38, dated June 10, 2015, issued by the Nuclear Safety Council, regarding the training of individuals involved in the transport of radioactive material by road.
http://www.boe.es/boe/dias/2015/07/06/pdfs/BOE-A-2015-7562.pdf
For training related to radioactive materials, Chapter 1.3 of the ADR specifically refers to paragraph 1.7.2.5, which indicates that workers must be trained in radiation protection, in line with Article 21 of the RPSRI.
The provisions included in Chapter 1.3 of the ADR apply to the training of all persons involved in the activity of transporting dangerous goods in shipping companies, carriers, loaders, and consignees, except for members of the vehicle crew to whom the provisions of Chapter 8.2 of the ADR specifically apply. Chapter 8.2 defines initial training to obtain the training certificate issued by the corresponding Provincial Traffic Headquarters, as well as refresher training for certificate renewal every 5 years. Chapter 8.2 details how this training should be conducted; however, considering that for radioactive materials the ADR specifically refers to paragraph 1.7.2.5 and considering what is defined in the RPSRI regarding the periodic training that persons at risk of exposure to ionizing radiation should receive, the Nuclear Safety Council (CSN) considers it necessary to specify for drivers of radioactive material transports a periodic or refresher training to be provided by the companies themselves at intervals shorter than those for certificate renewal defined by the ADR, with the basic objective of taking into account changes in regulations and operational experience during that period.
Furthermore, special provision S12 of Chapter 8.5 of the ADR establishes an exemption for radioactive materials with UN numbers UN 2915 and UN 3332, allowing drivers to be exempt from the aforementioned training certificate if certain conditions are met. In this case, however, drivers must have appropriate training corresponding to their responsibility, which must be documented by a certificate issued by the employer. However, the ADR does not specify the content of this training.
In light of the above, the CSN considers that the ADR, in certain cases, does not sufficiently detail the content of initial and refresher training for the transport of radioactive material, nor does it specify the periodicity of the latter, or the content of the records to be kept of the training provided. Additionally, the CSN, in the exercise of its inspection and monitoring functions of radioactive material transport activities, has detected a wide variety in the training programs developed to comply with the requirements of Chapter 1.3 of the ADR and Article 21 of the RPSRI, both in content and in the frequency with which refresher training is provided, by different shipping facilities and companies transporting radioactive material by road. The CSN considers that this variety of approaches is precisely due to the lack of specificity in the regulations regarding the training points identified above.
In conclusion, this Instruction aims to specify in certain cases the content of initial and periodic training programs of Spanish companies involved in the transport of radioactive material by road, as well as the records of such training, in order to improve the nuclear safety and radiological protection conditions of their operations.