Experience in the implementation of NORM regulations in Germany

According to the Directive 96/29/EURATOM the EU Member States are obliged to identify work activities that might lead to a significant increase of exposure due to natural occurring radioactive materials (NORM). In Germany, investigations were carried out that resulted in lists of possibly relevant workplaces on the one hand and residues from industrial processes on the other. These lists are part of the German radiation protection ordinance and form a key element of the regulations on NORM. They reflect the concept of selectivity of radiation protection in this area. Another peculiarity is the fact that the NORM regulations rely to a large extent on self-control of the industries concerned. The responsible authorities play only a limited role, and authorization is generally not required. Since actions are currently in progress to update national and international recommendations and standards we have evaluated and summarized the experience gained from the implementation of the NORM regulations in Germany. Our inquiries allow the conclusion that overall, the concept has proven to work properly. Since most of the industries were confronted with problems of radioactivity and radiation protection for the first time, professional assistance was necessary in the beginning. However, in the long run the concept will help to optimize the efforts on both sides, industry and authorities. Some problems have appeared with regard to the concept of selectivity. For example, certain exposures had been considerably overestimated on the basis of conservative, generic dose assessments that formed the basis of the lists of regulated workplaces and residues. This may not only lead to undue regulatory efforts but also to an unnecessary stigmatization of industries and concerns among workers and the population. Therefore it is necessary to weigh up carefully the conservatism that is to some extent necessary in generic dose assessments and the realism required in on-site assessments. (author)