Changes to the Regulation of NORM in Western Australia, author Simon Booth

In Western Australia, ionising radiation is primarily regulated by the Radiological Council, with the exception of NORM in mining operations, which is regulated by the Department of Energy, Mines, Industrial Regulation and Safety (DEMIRS).

In 2020, the Work Health and Safety Act was adopted in WA as a part of national harmonisation. In WA, this Act (and subsidiary legislation) is administered by DEMIRS.

The Work Health and Safety (Mines) Regulations (WHSMR) and Work Health and Safety (General) Regulations (WHSGR), were legislated in 2022.

This information is focused on the WHSMR requirements; however it should be noted that the WHSGR align with radiation protection in terms of:

• General workplace health and safety requirements; and
• Lasers are specifically prescribed.

The WHSMR details the requirements relating to the appointment of NORM RSOs (in mining) which have only recently been implemented. The requirement for existing NORM RSOs (in mining) to comply with the new requirements have been extended until 30 March 2026.

For many years in WA, radiation protection relating to NORM in mining has been aligned with the “NORM Guidelines”, produced by DEMIRS (originally known by a different acronym) that offer a NORM management framework. Some of the original guidelines are now somewhat outdated, although DEMIRS is working methodically towards refreshing these documents, and they are then adopted by the WHSMR as being legislatively required.

NORM II (which replaced NORM 2) was ‘rolled out’ in early 2024 and is of particular importance as it offers:

• A five (5) tiered approach to radiological risks in mining;
• A framework towards RMP development;
• A framework towards the requirements for RSOs.

RSO classifications (and commensurate competency requirements) are grouped as:

• Exploration;
• Restricted; and
• Relevant Mine (essentially a moderate or elevated radiation exposure risk mining operation).

To be appointed to a Statutory RSO position (for NORM in mining), an applicant shall:

• have an undergraduate degree in STEM, although there are provisions for geology, geophysics or earth science degrees detailed for exploration operations, and occupational hygiene for restricted operations;
• hold a licence under the Radiation Safety Act (administered by the Radiological Council);
• have undertaken a NORM course approved for the tiered classification;
• have completed a Mine Air Quality Officer course (not required for exploration); and
• have completed a professional development program in radiation protection in mining supervised and authenticated by an RSO from a relevant mine (not required for exploration).

In addition to above, RSOs for a relevant mine shall have:

• successfully completed approved WHS risk management units for RSOs – namely:
  • RIIRIS501E or BSBWHS513 – Risk management core Unit of Competency (UOC);
  • BSBWHS411 – UOC to contextualise WHS risk for a statutory position holder; and
  • RIIRIS402E or BSBWHS414 – UOC to assist in risk communication.
• And passed an applicable legislation examination for RSOs.

The legislation exams are now on offer through DEMIRS in Perth, Bunbury and Kalgoorlie, and registration is through a DEMIRS online portal.

There are some example exam questions available to prepare for this exam.

In October 2024, there were only two (2) companies approved to run the NORM RSO courses – contact details for these training providers can be obtained from DEMIRS.

NORM that is not related to mining, such as within the Oil and Gas sector, remain primarily regulated by the Radiological Council.

Licensing and Training for non-NORM related practices

Details of radiation licensing courses other than NORM (such as Fixed Radiation Gauges, or X-ray Analysis) have not changed and are available at https://www.radiologicalcouncil.wa.gov.au/Licences/Recognised-Courses. Examination is typically invigilated by the training provider. Most licensing purposes involve passing a Radiological Council assessment, although some licensing purposes vary.