Brussels, 5 June 2002
Proposal for a Council Directive on the control of high activity sealed radioactive sources. Comments on the above proposal from the German delegation. Cover note. Brussels, 28 May 2002 (29.05) (document 9297/02 ATO 64). Full text
1. The draft Directive is currently under discussion with the relevant national institutions (Länder authorities, federal departments, industry and users). It is therefore unlikely that Germany will be able to give its full opinion on the details of the draft before summer 2002.
2. Germany would like the Commission to explain how the proposal for a Directive fits in with existing Community legislation, with particular reference to Directive 96/29/EURATOM (reporting requirements: Art. 3(1) and (2)(a) to (c); exemption values: Annex I) and Directive 92/3/Euratom and Regulation 1493/93/Euratom, which, according to paragraph 6.5 of the Commission proposal, are to be extended to cover the shipment of sources not covered by existing provisions.
Germany would be grateful if the Commission could explain the reasons for its choice of the values in Annex I to the draft (1/100 of the A1 values) as opposed to, for example, a fraction of the A2 values or a multiple of the exemption values in Annex I to Directive 96/29/EURATOM.
Germany would also be grateful if the Commission could state how far the rules contained in the proposal for a Directive on the control of high activity radioactive sources are necessary to bring the problem of lost radioactive sources under control, bearing in mind rules which already exist or are in the planning stage.