Radiation Protection Convention, 1960 (No. 115) - Greece (Ratification: 1982)

Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

In order to provide a comprehensive view of the issues relating to the application of occupational safety and health (OSH) Conventions, the Committee considers it appropriate to examine Conventions Nos 115 (radiation protection) and 187 (promotional framework for OSH) together.

General provisions

Promotional Framework for Occupational Safety and Health Convention, 2006 (No.   187)

The Committee notes the observations of the Greek General Confederation of Labour (GSEE), received in 2023 and in 2024.

Article 2(1) of Convention No. 187. Promoting the continuous improvement of OSH by developing a national policy, national system and national programme. The Committee notes that Greece has a national policy on occupational safety and health (OSH) in the form of the National Strategy for OSH 2022–27 adopted in 2022 following consultations with the social partners, and a national OSH programme for 2024 as an annex to the Strategy. The Committee also notes that the Government has a national OSH system comprised of Act No. 3850/2010 on the ratification of the Code of laws on workers’ health and safety (Act No. 3850/2010) and a series of relevant Ministerial Decisions. The Committee notes that the National Strategy for OSH 2022–27 focuses on the continuous upgrading of working conditions and aims at meeting the new and interrelated challenges in the world of work. In its observations, the GSEE points to a lack of an integrated national OSH policy, functional infrastructure, and accountability within the national OSH policy and annual programmes. In this respect, it highlights a lack of prioritization of OSH issues by the Ministry of Labour and Social Security, inadequate functioning of the Ministry’s tripartite bodies, insufficient staffing and infrastructure of the Labour Inspectorate with regard to OSH, as well as a dysfunctional and ineffective OSH system that prioritizes formal compliance over effective implementation. It indicates that these factors have contributed to OSH deficits involving endangerment of human life, especially affecting migrant workers in Greece, and it refers to a dramatic rise in accidents, as indicated by data received by its member Federation of Associations of Employees of Technical Enterprises of Greece (OSETEE). The GSEE also indicates that the data underscores the need for stronger OSH policies, coordination, and preventive measures, including the prioritization of OSH in light of climate change and extreme weather conditions, to ensure the safety and well-being of workers in Greece. The Committee requests the Government to provide its comments in this respect. It requests the Government to provide information on the measures taken to address insufficient staffing of the Labour Inspectorate with regard to OSH. It requests the Government to continue to provide information on the measures taken to promote continuous improvement of OSH, in consultation with the most representative organizations of employers and workers.

Article 2(3). Measures that could be taken, in consultation with social partners, to ratify relevant OSH Conventions. The Committee notes the Government’s indication in its report that the Division on the Promotion of the Application of International Labour Standards of the Supreme Labour Council is responsible for discussing the possible ratification of ILO Conventions. The Committee requests the Government to indicate whether specific consideration has been given to measures that could be taken with respect to the OSH Conventions of the ILO and to provide information on the outcome of the consultations held with the social partners in this respect.

Article 4(1). Periodical review of a national OSH system in consultation with the social partners. The Committee notes the periodic amendments to Act No. 3850/2010, most recently in 2023. It also notes that the provisions of said Act have been codified under the new Code of Labour Law, which was given effect through the adoption of Presidential Decree No. 62/2025. The Government indicates that during the period covered by the previous National OSH Policy 2016–20, the legislative framework was strengthened both by transposing European Union directives and by establishing specific national legislation, for example on individual protection measures for employees of local self-government agencies, and safety and health in the distribution and transport of goods. The Committee requests the Government to continue to provide information on the measures taken to periodically review the national OSH system, including institutional arrangements for this review, and on the outcome of the consultations held with the social partners in this regard.

Article 4(2)(c). Mechanisms for ensuring compliance with national laws and regulations relating to OSH, including systems of inspections. The Government indicates that the monitoring of application of legislation on OSH and the investigation of occupational accidents lies within the remit of OSH Inspectors of the new independent administrative authority, the Labour Inspectorate, established under Law No. 4808/2021. In its observations, the GSEE indicates that the implementation of the Convention is closely linked to the effectiveness and accountability of the Labour Inspectorate. In this respect it reiterates its observations previously submitted under the Labour Inspection Convention, 1947 (No. 81), indicating that the creation of an independent Labour Inspectorate separated from the Ministry of Labour and Social Security has led to disconnection in coordinating OSH policies, and the non-functioning of the tripartite social dialogue body, the Social Control Council of Labour Inspectorate (SKEEE). According to the GSEE, this situation impacts the implementation of the National Strategy for OSH 2022–27, many of whose actions remain unimplemented. With regard to other mechanisms for ensuring compliance with national laws, the GSEE states that the Government should indicate whether the Register of Delinquent Companies Providing Cleaning and/or Security Services is operative and advocates for the publication of its methodology and data and its extension to all types of contractual assignments. The Committee requests the Government to provide its comments in this respect. With regard to the operation of the new Labour Inspectorate, the Committee refers to its comments that it adopted in 2025 concerning the application of Convention No. 81, specifically with respect to Articles 4 and 5(b) (organization and effective functioning of the system of labour inspection; supervision and control by a central authority; collaboration with representatives of employers and workers).

Article 4(3)(b), (c) and (e). Information and advisory services on OSH, provision of OSH training and OSH research. The Government indicates that, as provided in Act No. 3850/2010, the Ministry of Labour and Social Security and the Labour Inspectorate, individually or jointly, may conclude programme agreements with the Hellenic Institute for OSH (ELINYAE) for the preparation of studies, field research, training programmes in enterprises, consultancy services to employers or other actions and programmes for the promotion of OSH. According to Act No. 3850/2010, ELINYAE also provides training of safety technicians, occupational doctors and workers’ representatives. In its observations, the GSEE indicates that although ELINYAE has the primary responsibility for collecting and disseminating OSH knowledge in the country, it is underutilized, and its financial stability is affected by the absence of a signed programme agreement and the transformation of the Greek Employment Office (OAED) into the Public Employment Service (DYPA). The Committee requests the Government to provide its comments in this respect. It requests the Government to provide further information on the measures taken to ensure the provision of information and advisory services, OSH training and the undertaking of research on OSH.

Article 4(3)(f) and (g). Collection and analysis of data on occupational injuries and diseases. Collaboration with relevant insurance and social security schemes. The Government indicates that statistical data are collected by the Labour Inspectorate. The Committee recalls that under its comments on Convention No. 81, it noted that no information was available on the number of occupational diseases. In this respect, the Government indicates that in order to facilitate the collection and processing of reliable statistical data, it envisages the development of an integrated mechanism for the notification and registration of occupational accidents and diseases, the upgrading of the Labour Inspectorate’s Integrated Information System, and the creation of the new Integrated Information System for OSH (HERIDANOS). In this context, it also foresees the creation of an Occupational Risk Insurance Agency, following GSEE’s proposal. In its observations, the GSEE highlights the need for a comprehensive system to report and record occupational health issues, pointing to a lack of a central structure charged with this function, under-reporting, delays in accident reporting and investigations, and the exclusion of undeclared and migrant workers from official statistics. With regard to the Tempi train accident in February 2023, which resulted in at least 57 deaths and numerous injuries, the GSEE points to significant discrepancies between the official data from the Labour Inspectorate and the actual conditions observed. With regard to collaboration, the GSEE points to the absence of a coordinated data system connecting public authorities, indicating that labour and social security databases, the National Statistical Authority (ELSTAT) and the judiciary are not synchronized. The GSEE highlights the need to enhance the capacity of the Hellenic Statistical Authority to develop national statistics from a human rights perspective, including on incidents of sexual harassment and abuse. It also advocates for a National Research and Reporting Centre to identify harmful factors. The Committee requests the Government to provide its comments in this respect. In addition, referring to its comments under Convention No. 81, the Committee requests the Government to indicate the measures taken to enable the collection and analysis of data on occupational diseases, and to ensure the production and publication of relevant annual statistics. The Committee requests the Government to continue to provide information on the measures taken to reinforce the application of procedures for the notification of occupational accidents and diseases by employers. In this respect, it requests the Government to provide information on the progress achieved in the development of the new integrated mechanism for the notification and registration of occupational accidents and diseases, the upgrading of the Labour Inspectorate’s Integrated Information System, the creation of the new Integrated Information System for OSH (HERIDANOS), as well as the creation of an Occupational Risk Insurance Agency. It requests the Government to provide information on measures taken or envisaged to enhance collaboration between the Labour Inspectorate and relevant insurance and social security schemes.

Article 5(1) and (2)(e). National OSH Programme. Complementary national programmes. The Committee notes that the annual National Programme for OSH 2022–23 is annexed to the National OSH Strategy 2022–27 and forms an integral part of it. It also notes that a new National Programme for OSH 2024, was added in a new Annex in 2023 and it notes the information provided regarding tripartite consultations on the preparation of the National Programmes. The Committee requests the Government to provide information on the implementation of the National Programme for OSH 2022–23 and the National Programme for OSH 2024, including the activities carried out and the results achieved within their frameworks. It also requests the Government to provide information on the consultations undertaken with the most representative organizations of employers and workers in the programmes’ implementation, monitoring and evaluation.

Article 5(3). Publicizing the national programme. The National Programme for OSH 2022–23 and the National Programme for OSH 2024 are available online, as integral parts of the National Strategy for OSH 2022–27 on the website of the Ministry of Labour and Social Security and the website of ΕLΙΝΥΑΕ. The Committee requests the Government to provide information regarding the manner in which the Government ensures that its national programmes are widely publicized, in accordance with Article 5(3) of the Convention.

Protection against specific risks

Radiation Protection Convention, 1960 (No. 115)

Legislation. The Government indicates that the previous legislative framework related to radiation protection was thoroughly revised and repealed and a new regulatory framework for radiation protection was established, with the adoption of the new Regulations on Radiation Protection through Presidential Decree No. 101/2018. The Committee notes that the new Regulations aim to bring national legislation in line with the European Council Directive 2013/59/EURATOM. The Committee takes note of this information which addresses its previous request.

Article 14 of Convention n° 115. Discontinuation of assignment to work involving exposure to ionizing radiation pursuant to medical advice and alternative employment. In reply to Committee’s previous request, the Government reiterates that section 17(2)(e) of Act No. 3850/2010 on the ratification of the Code of laws on workers’ health and safety, which is now also codified under section 507(2)(e) of the new Code of Labour Law, provides that the occupational physician gives advice on alternative employment, for health reasons, on a temporary or permanent basis. In this respect, the Government indicates that according to the information received by the Labour Inspectorate, to date, no complaint has been received concerning employers’ non-compliance with the relevant advice of occupational physicians to move a worker to a different post because of their exposure to ionizing radiation. At the same time, the Government refers to section 80 of the new Regulations on Radiation Protection which provide that occupational health services perform medical surveillance of exposed workers regarding both workers’ exposure to ionizing radiation and their fitness for the tasks assigned to them relating to ionizing radiation. The Committee requests the Government to clarify whether the advice of the occupational physician on alternative employment due to health reasons, as stipulated under section 17(2)(e) of Act No. 3850/2010, entails an obligation on the employer to take corresponding measures.In this respect, the Committee also requests the Government to continue to provide information on the measures taken or envisaged to ensure that workers are not employed or engaged in work liable to expose them to ionizing radiations contrary to qualified medical advice.

Direct Request (CEACR) - adopted 2016, published 106th ILC session (2017)

General observation of 2015. The Committee would like to draw the Government’s attention to its general observation of 2015 under this Convention, and in particular to the request for information contained in paragraph 30 thereof.

The Committee notes the information provided by the Government in its report in response to its previous request concerning occupational exposure during or after an emergency (Articles 2 and 13(d) of the Convention).

Legislation. The Committee notes the Government’s indication in its report that the national legislation on the protection of workers from ionizing radiations is under review by a special committee (established by Decision No. P/204/028_04.02.2014 of the President of the Greek Atomic Energy Commission (EEAE)), with a view to implementing the Council of the European Union Directive 2013/59/EURATOM, which is in line with the 2007 recommendations of the International Commission of Radiation Protection and the Basic Safety Standards of the International Atomic Energy Organization. The Committee invites the Government to take into consideration its general observation of 2015 in the legislative review process. It also requests the Government to provide copies of any new or amended legislation adopted in this regard.

Article 14. Discontinuation of assignment to work involving exposure to ionizing radiation pursuant to medical advice and alternative employment. With reference to its previous comments, the Committee notes the Government’s indication that section 17.2(e) of Act No. 3850/2010 on the ratification of the Code of laws on workers’ health and safety provides that the labour physician gives advice on alternative employment, for health reasons, on a temporary or permanent basis. The Committee invites the Government to provide information on the effect given in practice to this provision of the legislation and the follow-up given by the employers to such advices as regards workers for whom work involving occupational exposure to ionizing radiation is medically inadvisable.

Application in practice. The Committee notes the information contained in the annual activity report of the EEAE for 2014 according to which 649 facilities were inspected and 11,584 workers were monitored for occupational exposure, of which 8,776 received doses under the reporting level. This report also indicates that the significant reduction in the number of cases exceeding 6 mSv per year (effective dose limit above which a radiation protection officer investigates the reasons, proposes suitable measures to be adopted and submits a report to the EEAE), from 62 in 2011 to 18 in 2014, is attributed to the intense training provided by the EEAE and to the continuous and direct communication for the investigation of those cases. The Committee requests the Government to continue to provide information on the application of the Convention in the country and to provide, where such statistics exist, information on the number of workers covered by the legislation, the number and nature of the contraventions reported and the number, nature and cause of occupational accidents and diseases reported.

Direct Request (CEACR) - adopted 2010, published 100th ILC session (2011)

The Committee notes that the Government has no legislative changes to report.

Article 13(d) of the Convention. Occupational exposure during or after an emergency. With reference to its previous comments, the Committee notes the information provided by the Government that the dose limits for workers refers to the activities of a usual practice and it is forbidden to exceed the dose limits, whilst the limited dose levels refer to the framework of the principle of optimization and are lower than the dose limits; it also refers to individual practices so that there is no excess of the dose limits by the total practice. The Committee further notes the conditions and limits laid down by the Radiation Protection Regulation, sections 1.9 and 1.13(b), in emergency situations. The Committee also notes that the duration of an emergency situation is defined on a case-by-case basis. The Committee requests the Government to provide further information on the practical application of this Article.

Article 14. Alternative employment or other measures offered for maintaining income where continued assignment to work involving exposure is medically inadvisable. The Committee notes the Government’s response that section 9(2)(e) of Act No. 1568/85 on the health and safety of workers, provides that the labour physician provides a written recommendation to the employer regarding the change of post for health reasons. With reference to paragraph 32 of the 1992 general observation, the Committee again requests the Government to indicate measures taken or envisaged to ensure that alternative employment or other measures are offered to workers to enable them to maintain their income where continued assignment to work involving exposure is medically inadvisable.

Part V of the report form. Application in practice. The Committee asks the Government to give a general appreciation of the manner in which the Convention is applied in the country and to provide, where such statistics exist, information on the number of workers covered by the legislation, the number and nature of the contraventions reported, and the number, nature and cause of accidents and occupational diseases reported.

Direct Request (CEACR) - adopted 2006, published 96th ILC session (2007)

1. The Committee notes the information contained in the Government’s report, in particular Ministerial Decision No. 1014/94 (Official Journal No. 216) of March 2001, which lays down basic standards for the protection of the health of the population and workers against the dangers arising from ionizing radiation. It also notes that Ministerial Decision No. 14632 of 1989 has been repealed.

2. Article 13(d) of the Convention. Occupational exposure during or after an emergency. The Committee notes in particular that section 1.2.4 of Ministerial Decision No. 1014/94 of 6 March 2001 on protection against radiation refers to “limited dose levels” during the emergency intervention of voluntary workers exposed to radiation and not to the dose limits set by the same Decision. The Committee also notes that the Decision does not permit the dose limits to be exceeded, but, on the other hand, permits the “limited dose levels” to be exceeded. In this regard, the Committee draws the Government’s attention to the issues addressed in paragraph 35(c)(iii) of the conclusions of its 1992 general observation on Convention No. 115, according to which the strict definition of circumstances in which exceptional exposure of workers, exceeding the normally tolerated dose limit, is to be allowed for “immediate and urgent remedial work”; that work must be strictly limited in scope and duration to what is required to meet an acute danger to life and health; exceptional exposure of workers is neither justified for the purpose of rescuing “items of high material value”, nor, more generally, because alternative techniques of intervention, which do not involve such exposure of workers, “would involve an excessive expense”. The Committee asks the Government to explain the difference between “the dose limits” and the “limited dose levels” mentioned in its report and to indicate the conditions which determine whether the situation is an emergency and to specify its duration.

3. Article 14. Offer of alternative employment. The Committee notes the Government’s indication that no measures exist for offering alternative suitable employment to workers who are required to stop carrying out radiation work for health reasons. In this regard, the Committee draws the Government’s attention to the explanations given in paragraph 32 of the 1992 general observation, according to which “every effort must be made to provide the workers concerned with suitable alternative employment or to maintain their income through social security measures or otherwise where continued assignment to work involving exposure is found to be medically inadvisable”. The Committee asks the Government to provide, in its next report, detailed information on the application of this Article in practice, as well as information on the way in which the general observation of 1992 relating to this Convention is taken into account.

Direct Request (CEACR) - adopted 2003, published 92nd ILC session (2004)

The Committee notes the Government’s last report. Further to its observation and with reference to its previous direct request, the Committee draws the Government’s attention to the following points.

1. The Committee notes with interest the provisions of section 1.2 and section 1.3 of Ministerial Decision No. 1014/94 (Official Gazette, No. 216) of 6 March 2001, issued by the Ministers of National Economy, Labour, Health, Welfare and Development, governing the regulations on radiation protection, which incorporate into national law the dose limits recommended in 1990 by the International Commission on Radiological Protection (ICRP), thus giving effect to Article 3, and Article 6, paragraph 2, of the Convention.

2. Article 13(d). Occupational exposure during and after an emergency situation. According to section 1.2.4 of Ministerial Decision No. 1014/94, the Greek Atomic Energy Commission (GAEC) specifies the dose limits for exposure of workers during an emergency, which however may not exceed twice the annual dose limits specified for radiation workers under this Ministerial Decision, and may not exceed five times this limit over a lifetime. The Committee observes that these dose limits reflect the recommendations made by the International Commission on Radiological Protection (ICRP) in 1990. In this respect, the Committee notes that, although the ICRP has largely abandoned the limitations previously established for planned special exposures, it nevertheless suggests that workers’ exposure should not exceed 0.5 Sv during the first stage of an intervention for the "control of an accident", that is 25 times the average annual occupational dose limit, with the exception of life-saving actions. However, in a second stage of remedial work, which is to begin "once the immediate emergency is under control", the normal occupational dose limits are applicable without any exception. The Committee, which referred to these recommendations in paragraphs 23 to 27 of its 1992 general observation under the Convention, understands that section 1.2.4 of the above Ministerial Decision makes no distinction between the two stages of an emergency intervention, which require the application of different dose limits for workers who undertake an intervention. In the light of these explanations and of the indications given in paragraphs 23-27 of the Committee’s 1992 general observation under the Convention to limit the occupational exposure of workers during and after an emergency intervention, the Committee requests the government to indicate how effect is given to the above mentioned recommendations.

3. Article 14. Alternative employment. The Committee notes section 1.7 of Ministerial Decision No. 1014/94, prohibiting the employment of a worker in a specific post where he is liable to become an exposed worker if the medical findings deem him unfit for such post, according to the opinion of the approved medical practitioner or the occupational health service. Pursuant to section 1.7 in conjunction with section 1.7.1(c) of the above Ministerial Decision, the approved medical practitioner or the occupational health service determines once a year whether the worker remains fit to perform radiation work. The Committee observes however that there does not seem to be a provision concerning the practical measures to be taken, i.e. the need to find alternative employment opportunities not involving exposure to ionizing radiation in the event that continued employment in a particular job involving exposure to ionizing radiations is contraindicated for health reasons. While Article 14 of the Convention does not directly address the issue of alternative employment to be offered to the workers concerned, the Committee would draw the Government’s attention to paragraph 32 of its 1992 general observation under the Convention where it underlined that the provision of alternative employment constitutes a general principle of occupational safety and health which appears in different instruments of the ILO. Beyond this, the offer of suitable alternative employment opportunities to these workers derives from the provision of Article 3, paragraph 1, of this Convention, according to which effective protection of workers must be ensured. The Government is therefore requested to indicate the measures taken or envisaged to provide suitable alternative employment to workers who are to discontinue radiation work for health reasons, or to enable them to maintain their income otherwise through social security measures.

Observation (CEACR) - adopted 2003, published 92nd ILC session (2004)

The Committee notes the information provided by the Government in its report. It notes with interest Ministerial Decision No. 1014/94 (Official Gazette, No. 216) of 6 March 2001, governing the regulations on radiation protection, which were issued by the Ministers of National Economy, Labour, Health, Welfare and Development, to transpose into national legislation European Directive 96/29/Euratom of 13 May 1996, laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionizing radiation, which reflects the dose limits set forth by the International Commission on Radiological Protection (ICRP) in its 1990 Recommendations and Directive 97/43/Euratom of 30 June 1997 on the health protection of individuals against the dangers of ionizing radiation in relation to medical exposure. It further notes that Ministerial Decision No. 1014/94 repeals Ministerial Decision No. 14632/(FOR)1416 of 1989.

In view of the new regulations, the Committee would draw the Government’s attention to the following point.

Article 8 of the Convention. The Committee notes the dose limits set forth by sections 1.3 and 1.3.1 of Ministerial Decision No. 1014/94 for exposure to ionizing radiations of the different categories of workers. Section 1.3.2 establishes a dose limit of 1 mSv for the general public. The Committee observes that its scope does not seem to include workers who are not directly engaged in radiation work. The Committee, while emphasizing that this provision of the Convention raises a particular concern for workers who, while not directly engaged in radiation work and thus not necessarily benefiting from monitoring programmes, special medical examination etc., may remain in, or pass through, areas where they may be exposed to ionizing radiations, recalls the Government’s obligation under Article 8 of the Convention to establish appropriate annual dose limits for exposure of workers who are not directly engaged in radiation work. With regard to the determination of the annual dose limits for non-radiation workers in the light of the knowledge available at the time, the Committee draws again the Government’s attention to section 5.4.5 of the ILO code of practice of 1986, according to which workers not directly involved in radiation work shall be protected as if they were members of the general public. For the general public, the ICRP, in its 1990 recommendations, spells out an annual effective dose limit of 1 mSv, averaged over five years. The Committee hopes that the Government will soon take the necessary measures, in the light of the above explanations, to establish appropriate dose limits for exposure to ionizing radiation of workers who are not directly engaged in radiation work, in order to fulfil its obligations under Article 8 of the Convention.

The Committee is raising other points in a request directly addressed to the Government.

Direct Request (CEACR) - adopted 2000, published 89th ILC session (2001)

The Committee notes that the Government’s report has not been received. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the matters raised in its previous direct request, which read as follows:

The Committee notes the information supplied by the Government in its report. Further to its previous observation, the Committee would like to draw the Government's attention to the following points.

1.  Article 3, in conjunction with Article 6.2, of the Convention.  The Committee notes section 1.2.1 of Ministerial Decision No. 14632/(FOR) 1416/1989, providing for the maximum permissible dose of ionizing radiation of 50 mSv per year (5 rem/year) for workers directly engaged in radiation work. The Committee further notes that section 1.3.4 of this Ministerial Decision provides for the immediate implementation of EU Directives setting up lower dose limits. In this respect, the Committee notes article 9 of the revised EURATOM Basic Safety Standards Directive (96/92/EURATOM) prescribing a dose limit of 100 Sv in a consecutive five-year period which constitutes an annual average of 20 mSv. This dose limit is also indicated in the 1990 recommendation of the International Commission on Radiological Protection (ICRP) to which the 1992 general observation of the Committee refers in order to define the term "knowledge available at the time …", included in Article 3 of the Convention. The Committee accordingly requests the Government to indicate the measures taken or contemplated with a view to revising the maximum permissible doses of ionizing radiation currently in force for workers directly engaged in radiation work.

2.  Article 13 of the Convention.  The Committee notes the provision 1.2.3 of Ministerial Decision No. 14632/(FOR) 1416/1989 concerning planned special exposure, which provides, inter alia, that the exposure to ionizing radiation should not exceed twice the average annual occupational dose limit. The Committee draws the Government’s attention to paragraphs 16 to 27 of its 1992 general observation under the Convention dealing with the limitation of occupational exposure during and after an emergency, where the Committee observed that the ICRP in its 1990 recommendations has largely abandoned the limitations previously established for planned special exposures. The relaxation of control during the first stage of emergency situations should nevertheless not lead to an exposure exceeding 0.5 Sv (that is, 25 times the average annual occupational dose limit), except for life-saving actions. The equivalent dose to the skin should not exceed 5 mSv. However, stringent criteria should define the exceptional circumstances in which normal exposure limits might be exceeded. In the second stage of an emergency intervention the normal dose limits are applicable. The Committee requests the Government to indicate the steps taken or envisaged in relation to the matters raised in its 1992 general observation under the Convention and, in particular, in the conclusions under paragraph 35(c), as well as on measures envisaged to ensure conformity with the above-described principles.

Observation (CEACR) - adopted 2000, published 89th ILC session (2001)

The Committee notes that the Government’s report has not been received. It must therefore repeat its previous observation which reads as follows:

The Committee notes the information supplied by the Government in its latest report.

1.  Article 8 of the Convention.  The Committee notes that section 1.3.4 of the Ministerial Decision No. 14632/(FOR) 1416/1989 requiring the immediate implementation of European Directives which set up lower dose limits. In this event, the Greek Nuclear Energy Committee is obliged to adopt new dose limits being the basis for a ministerial decision to be taken in order to translate the dose limits contained in the European Directives into national law. In this regard, the Committee notes the EU Council Directive96/29/EURATOM of 13 May 1996 laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionizing radiation. Article 9 of this Directive fixes dose limits for workers exposed to ionizing radiation and its article 13 sets dose limits for the general public which are both in line with the dose limits recommended by the ICRP in 1990. The Committee, however, notes that the Council Directive 96/29/EURATOM does not contain any provisions prescribing dose limits for non-radiation workers, and thus the national legislation is lacking provisions fixing the annual dose limit for workers not directly engaged in radiation work. The Committee recalls the provision of Article 8 of the Convention obliging the Government to fix appropriate levels of exposure in the light of knowledge available at the time for the group of workers not directly engaged in radiation work. In this respect, the Committee draws the Government’s attention to section 5.4.5 of the ILO Code of Practice of 1986, according to which the dose limit for workers not directly engaged in radiation work should be the same as the dose limit fixed for individual members of the public. For this category of persons, the 1990 ICRP recommendation set up a dose limit of 1 mSv/year, averaged over five years. The Committee accordingly hopes that the Government will take the necessary measures in the near future in order to fulfil its obligation under this Article of the Convention.

2.  The Committee is raising other points in a request addressed directly to the Government.

The Committee hopes that the Government will make every effort to take the necessary action in the very near future.

Direct Request (CEACR) - adopted 1999, published 88th ILC session (2000)

The Committee notes the information supplied by the Government in its report. Further to its previous observation, the Committee would like to draw the Government's attention to the following points.

1. Article 3, in conjunction with Article 6.2, of the Convention. The Committee notes section 1.2.1 of Ministerial Decision No. 14632/(FOR) 1416/1989, providing for the maximum permissible dose of ionizing radiation of 50 mSv per year (5 rem/year) for workers directly engaged in radiation work. The Committee further notes that section 1.3.4 of this Ministerial Decision provides for the immediate implementation of EU Directives setting up lower dose limits. In this respect, the Committee notes article 9 of the revised EURATOM Basic Safety Standards Directive (96/92/EURATOM) prescribing a dose limit of 100 Sv in a consecutive five-year period which constitutes an annual average of 20 mSv. This dose limit is also indicated in the 1990 recommendation of the International Commission on Radiological Protection (ICRP) to which the 1992 general observation of the Committee refers in order to define the term "knowledge available at the time ...", included in Article 3 of the Convention. The Committee accordingly requests the Government to indicate the measures taken or contemplated with a view to revising the maximum permissible doses of ionizing radiation currently in force for workers directly engaged in radiation work.

2. Article 13 of the Convention. The Committee notes the provision 1.2.3 of Ministerial Decision No. 14632/(FOR) 1416/1989 concerning planned special exposure, which provides, inter alia, that the exposure to ionizing radiation should not exceed twice the average annual occupational dose limit. The Committee draws the Government's attention to paragraphs 16 to 27 of its 1992 general observation under the Convention dealing with the limitation of occupational exposure during and after an emergency, where the Committee observed that the ICRP in its 1990 recommendations has largely abandoned the limitations previously established for planned special exposures. The relaxation of control during the first stage of emergency situations should nevertheless not lead to an exposure exceeding 0.5 Sv (that is, 25 times the average annual occupational dose limit), except for life-saving actions. The equivalent dose to the skin should not exceed 5 mSv. However, stringent criteria should define the exceptional circumstances in which normal exposure limits might be exceeded. In the second stage of an emergency intervention the normal dose limits are applicable. The Committee requests the Government to indicate the steps taken or envisaged in relation to the matters raised in its 1992 general observation under the Convention and, in particular, in the conclusions under paragraph 35(c), as well as on measures envisaged to ensure conformity with the above-described principles.

Observation (CEACR) - adopted 1999, published 88th ILC session (2000)

The Committee notes the information supplied by the Government in its latest report.

1. Article 8 of the Convention. The Committee notes that section 1.3.4 of the Ministerial Decision No. 14632/(FOR) 1416/1989 requiring the immediate implementation of European Directives which set up lower dose limits. In this event, the Greek Nuclear Energy Committee is obliged to adopt new dose limits being the basis for a ministerial decision to be taken in order to translate the dose limits contained in the European Directives into national law. In this regard, the Committee notes the EU Council Directive 96/92/EURATOM of 13 May 1996 laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionizing radiation. Article 9 of this Directive fixes dose limits for workers exposed to ionizing radiation and its article 13 sets dose limits for the general public which are both in line with the dose limits recommended by the ICRP in 1990. The Committee, however, notes that the Council Directive 96/92/EURATOM does not contain any provisions prescribing dose limits for non-radiation workers, and thus the national legislation is lacking provisions fixing the annual dose limit for workers not directly engaged in radiation work. The Committee recalls the provision of Article 8 of the Convention obliging the Government to fix appropriate levels of exposure in the light of knowledge available at the time for the group of workers not directly engaged in radiation work. In this respect, the Committee draws the Government's attention to section 5.4.5 of the ILO Code of Practice of 1986, according to which the dose limit for workers not directly engaged in radiation work should be the same as the dose limit fixed for individual members of the public. For this category of persons, the 1990 ICRP recommendation set up a dose limit of 1 mSv/year, averaged over five years. The Committee accordingly hopes that the Government will take the necessary measures in the near future in order to fulfil its obligation under this Article of the Convention.

2. The Committee is raising other points in a request addressed directly to the Government.

Direct Request (CEACR) - adopted 1995, published 82nd ILC session (1995)

The Committee notes that no report has been received from the Government. It hopes that a report will be supplied for examination by the Committee at its next session and that it will contain full information on the following matters raised in its previous direct request:

The Committee has noted the Government's indication in its report received in 1991 that the supplementary radiation regulations noted in the Committee's previous comments have taken the form of a Joint Ministerial Decision and are in the process of being published. The Government is requested to provide a copy of this Joint Ministerial Decision with its next report.

I. Article 8 of the Convention. In its previous comments, the Committee had noted that the maximum level of exposure to ionizing radiations for workers not directly engaged in radiation work is one-tenth of the limit of exposure for workers engaged in radiation work. As section 8 of the Joint Ministerial Decision No. A2/1539 on the fundamental safety standards for the health protection of the public and workers against ionizing radiations fixes a limit for whole body exposure to ionizing radiations at 50 mSv per year for workers engaged in radiation work, this would translate to a limit of 5 mSv for workers not directly engaged in radiation work. In its report received in 1991, the Government had confirmed this and added that this is in conformity with the maximum exposure limit permissible for the general public which is also 5 mSv.

While the Government has indicated that the limit of 5 mSv is consistent with the Euratom Directives Nos. 80/467 and 80/836, the Committee would recall that Article 3, paragraph 1 of the Convention provides that all appropriate steps shall be taken to ensure effective protection of workers, as regards their health and safety, against ionizing radiations, in the light of knowledge available at the time. In this regard, the Committee would draw the Government's attention its general observation under this Convention, in particular, paragraph 14 concerning dose limits for non-radiation workers. It notes that the International Commission on Radiological Protection in its 1990 Recommendations (ICRP Publication 60) maintains an annual limit on effective dose for the general public of 1 mSv, averaged over any five consecutive years. The Government is requested to indicate, in its next report, the measures taken to ensure that, in accordance with current knowledge, workers not directly engaged in radiation work are not exposed to dose limits exceeding 1 mSv per year, averaged over five years.

II. The Committee would more generally call the Government's attention to its 1992 general observation under this Convention which sets forth the revised exposure limits adopted by the International Commission on Radiological Protection on the basis of new physiological findings in its 1990 Recommendations (Publication No. 60). The Committee would recall that, under Article 3, paragraph 1 and Article 6, paragraph 2 of the Convention, all appropriate steps shall be taken to ensure effective protection of workers against ionizing radiations and to review maximum permissible doses of ionizing radiations in the light of current knowledge. The Government is requested to indicate the steps taken or being considered in relation to the matters raised in the conclusions to the 1992 general observation.

III. Exposures in emergency situations. The Committee noted the Government's reply to its general observation of 1987. It noted that sections 36 and 37 of Ministerial Decision No. 1539 of 1985 provide for special surveillance of workers exposed to excessive levels of ionizing radiation. In this regard, the Committee would refer the Government to paragraphs 16 to 27 of its general observation concerning the limitation of occupational exposure during and after an emergency. It requests the Government to indicate the steps taken or being considered in relation to the matters raised in paragraph 35(c) of the general observation.

Direct Request (CEACR) - adopted 1992, published 79th ILC session (1992)

The Committee has noted the Government's indication in its latest report that the supplementary radiation regulations noted in the Committee's previous comments have taken the form of a Joint Ministerial Decision and are in the process of being published. The Government is requested to provide a copy of this Joint Ministerial Decision with its next report.

I. Article 8 of the Convention. In its previous comments, the Committee had noted that the maximum level of exposure to ionising radiations for workers not directly engaged in radiation work is one-tenth of the limit of exposure for workers engaged in radiation work. As section 8 of the Joint Ministerial Decision No. A2/1539 on the fundamental safety standards for the health protection of the public and workers against ionising radiations fixes a limit for whole body exposure to ionising radiations at 50 mSv per year for workers engaged in radiation work, this would translate to a limit of 5 mSv for workers not directly engaged in radiation work. In its latest report, the Government has confirmed this and added that this is in conformity with the maximum exposure limit permissible for the general public which is also 5 mSv.

While the Government has indicated that the limit of 5 mSv is consistent with the Euratom Directives Nos. 80/467 and 80/836, the Committee would recall that Article 3, paragraph 1 of the Convention provides that all appropriate steps shall be taken to ensure effective protection of workers, as regards their health and safety, against ionising radiations, in the light of knowledge available at the time. In this regard, the Committee would draw the Government's attention its General Observation under this Convention, in particular, paragraph 14 concerning dose limits for non-radiation workers. It notes that the International Commission on Radiological Protection in its 1990 Recommendations (ICRP Publication 60) maintains an annual limit on effective dose for the general public of 1 mSv, averaged over any five consecutive years. The Government is requested to indicate, in its next report, the measures taken to ensure that, in accordance with current knowledge, workers not directly engaged in radiation work are not exposed to dose limits exceeding 1 mSv per year, averaged over five years.

II. The Committee would more generally call the Government's attention to its General Observation under this Convention which sets forth the revised exposure limits adopted by the International Commission on Radiological Protection on the basis of new physiological findings in its 1990 Recommendations (Publication No. 60). The Committee would recall that, under Article 3, paragraph 1 and Article 6, paragraph 2 of the Convention, all appropriate steps shall be taken to ensure effective protection of workers against ionising radiations and to review maximum permissible doses of ionising radiations in the light of current knowledge. The Government is requested to indicate the steps taken or being considered in relation to the matters raised in the conclusions to the General Observation.

III. Exposures in emergency situations

The Committee notes the Government's reply to its General Observation of 1987. It notes that sections 36 and 37 of Ministerial Decision No. 1539 of 1985 provide for special surveillance of workers exposed to excessive levels of ionising radiation. In this regard, the Committee would refer the Government to paragraphs 16 to 27 of its General Observation concerning the limitation of occupational exposure during and after an emergency. It requests the Government to indicate the steps taken or being considered in relation to the matters raised in paragraph 35(c) of the General Observation.

Direct Request (CEACR) - adopted 1990, published 77th ILC session (1990)

The Committee has noted the information supplied by the Government concerning draft regulations on radiation protection to supplement already existing regulations. It requires the Government to indicate whether these regulations have been adopted and, if so, to supply copies of them with the next report.

I. Article 8 of the Convention. The Committee notes the information supplied by the Government to the effect that the maximum level of exposure to ionising radiations for workers not directly engaged in radiation work is one-tenth of the limit of exposure for workers engaged in radiation work. It notes that section 8 of the Joint Ministerial Decision No. A2/1539 on the fundamental safety standards for the health protection of the public and workers against ionising radiations fixes a limit for whole body exposure to ionising radiations at 50 mSv per year for workers engaged in radiation work. Thus, the maximum exposure limit for workers not directly engaged in radiation work would be 5 mSv.

The Committee would call the Government's attention to paragraph 5.4.5 of the ILO Code of Practice for the Radiation Protection of Workers (ionising radiations). This paragraph provides that the dose limits for workers not directly engaged in radiation work should be the same as the dose limits applicable for members of the public. According to the 1985 statement of the International Commission on Radiological Protection (ICRP), the annual effective dose equivalent limit for members of the public should be 1 mSv. A subsidiary dose limit of 5 mSv in a year, for some years, is permissible, provided that the annual dose equivalent over a lifetime does not exceed the principal limit of 1 mSv in a year. The Committee requests the Government to indicate the measures taken or envisaged to ensure that the average annual dose equivalent over a lifetime for workers not directly engaged in radiation work does not exceed 1 mSv.

II. General observation

1. The Committee would also like to call the Government's attention to the general observation of 1987. This observation requested information concerning special measures to be taken in abnormal situations. The Committee would again request the Government to supply information concerning the limits of exposure which have been fixed for workers called to intervene in abnormal situations and the criteria used to set these limits in accordance with Article 6 of the Convention. Furthermore, the Committee requests the Government to indicate the measures taken to ensure that, once the initial event has been brought under control, the remaining remedial work is carried out within the dose equivalent limits.

2. The Committee notes that section 2 of Ministerial Decision No. A2/1539 excludes "natural background radiation" from the permissible dose equivalent. It requests the Government to indicate how this "natural background radiation" is determined and how the background radiation as a result of earlier incidents, not necessarily occurring at the workplace in question (such incidents may affect the total amount of radiation workers are exposed to even if they occur at a great distance from the workplace), is taken into account when determining the amount of radiation to which a worker is being exposed. It further requests the Government to indicate if measures have been taken to specify dangerously cumulating background radiation as one of the circumstances in which remedial action necessary to protect the worker from exposure to ionising radiations beyond fixed limits is taken by the employer, in accordance with Article 13(d).