The instruction and its scope
Instruction IS-38, issued by Spain's Nuclear Safety Council (CSN) in June 2015, remains listed in the CSN's current instruction catalogue, checked on 12 October 2026. CSN instructions are binding technical standards, rather than optional training guidance.
IS-38, section 1.2, covers staff of entities with a registered office in Spain acting there as consignor, loader, unloader, receiver or registered road carrier of radioactive material. The company holders are responsible for providing the training.
Start with the work people actually perform
The CSN's transport requirements overview explains that safe transport depends on package design, preparation of consignments and the responsibilities of the participating organisations. Carriers have specific responsibilities concerning personnel training, vehicles and stowage.
For a training review, identify who prepares consignments, loads or unloads, drives, or checks received packages. A useful staff list should describe these functions, including occasional duties, rather than relying only on job titles.
Distinguish the three training components
ADR 2025, chapter 1.3, distinguishes general awareness, function-specific training and safety training. General awareness introduces the applicable framework. Function-specific training addresses the requirements relevant to the person's responsibilities, including other modes where the operation is multimodal. Safety training concerns the hazards and appropriate safety and emergency procedures.
For class 7, ADR 1.7.2.5 additionally requires appropriate radiation-protection training. Use IS-38's section 3 and annex to map its detailed content to the relevant roles. The initial programme also needs to address the company's operating procedures. Training materials should explain the approved arrangements used at that workplace, rather than offer a generic course with no connection to the operation.
Company training and the ADR driver certificate
IS-38 does not replace ADR driver certification under chapter 8.2. It covers driver radiation-protection training and employer-certified training for drivers meeting the conditional S12 exemption.
Assess the certificate requirement against the actual consignment and current ADR provisions. Course attendance alone does not demonstrate eligibility for an exemption. Keep the assessment of transport requirements separate from the evidence showing which training a driver has received, so that one document is not mistaken for the other.
Refresher intervals and training records
Under IS-38 sections 3.2.2 and 4.2, consecutive refresher courses must be no more than 24 months apart, and training records must be retained for at least 36 months after course completion.
The required record includes the worker's name and task, course date, trainer or training organisation, duration and description, and signatures of the worker and company representative. Records must be available to the worker on request and to the CSN.
A practical review should compare completed course dates with planned refresher dates and check that the file contains the required evidence, not merely a booking confirmation.
Read the 2015 instruction with today's framework
IS-38 refers to the former radiation-protection regulation, Royal Decree 783/2001. Royal Decree 1029/2022 repealed that regulation and directs references in other provisions to the corresponding provisions of the new regulation. Its Article 23 requires relevant information before work starts and radiation-protection training appropriate to responsibilities and exposure risks.
Physical security may bring additional requirements: IS-46, sections 8 and 9, includes security training within its own scope and expressly preserves IS-38. Radiation protection, physical security and ADR driver certification therefore need separate consideration when reviewing a company's training arrangements.
Prepare a training review for your operation
Gather the types of material and packages handled, the company's transport roles, the staff functions, existing course programmes and completed training records. Describe the transport modes and any proposed driver exemption. This helps a reviewer identify missing information and target the content to the work involved.
DGSA advisory services can help connect transport obligations with the company's training documentation. For training enquiries, explain whether the need concerns company personnel, radiation protection, physical security or an ADR driver certificate. Contact DGSA with these details so that the applicable training can be assessed.