Germany's commentary on proposal for control of high activity sealed radioactive sources

Brussels, 9 July 2002

Proposal for a Council Directive on the control of high activity sealed radioactive sources

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Cover note. Brussels, 3 July 2002 (08.07) (document 10590/02 ATO 87).

Delegations will find attached the German delegation's comments on the above proposal.

German position on the proposal for a Council Directive on the control of high activity sealed radioactive sources (9935/02 of 14 June 2002) as at 2 July 2002

I. Need for regulation at European level

Germany in principle welcomes efforts to improve radiation protection in Europe. Euratom Directives 96/29 of 13 May 1996 and 97/43 of 30 June 1997 made available a wide range of control and regulation instruments which were implemented in the Member States. The draft Directive on the control of high activity radioactive sources deals specifically with problems that could arise when radioactive sources are no longer subject to control ("orphan sources"). Apart from the introduction of an authorisation requirement (Article 3(1)) and the rule on control of imports at Member States' borders (Article 9(3), first sentence) - which could also be brought in by means of a simple amendment to the basic Directive 96/29 Euratom or in a short Regulation - every provision should be carefully examined to determine whether its subject matter needs to be regulated in a Directive. Our comments on specific provisions of the draft Directive (9935/1/02 REV 1 of 28 June 2002) are set out below.

II. Relations with third countries

Generally speaking, the draft Directive should be clearer and more explicit about relations with third countries. Some of our proposed amendments, e.g. to the preamble and Article 1, concern that aspect...

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