The accidental presence of radioactive sources in metals (e.g., scraps, semi-finished products, finished products) can expose workers and citizens to serious health risks and contaminate the environment. For this reason, European and Italian regulations impose specific radiometric controls on these materials. In particular, EU Directive 2013/59/Euratom (Basic Safety Standards) was transposed in Italy by Legislative Decree no. 101/2020. Article 72 of Legislative Decree 101/2020 establishes the obligation for those who import, collect, deposit, or melt scraps and metals to carry out radiometric surveillance on loads to detect anomalous radioactivity and protect health and the environment. This same obligation extends—according to specific procedures—also to importers of semi-finished metal products and finished metal products.
Italian and European regulatory framework for semi-finished metal products
Legislative Decree July 31, 2020, no. 101, implementing Directive 2013/59/Euratom, establishes the general rules for protection against ionizing radiation. Art. 72 of the decree lists the activities subject to radiometric surveillance: primarily industrial or commercial enterprises that import, collect, deposit, or melt scrap or other waste metal materials. Furthermore, those operating in large import centers or transit hubs who import semi-finished products or finished metal products are subject to the obligation, although application to finished products generally occurs only at the request of the competent authorities.
These provisions are dictated:
“In order to detect the presence of anomalous levels of radioactivity or any disused sources, to guarantee the health protection of workers and the population … and to avoid environmental contamination”.
In addition to Legislative Decree 101/2020 (which updated the previous Legislative Decree 230/1995), the regulatory framework includes implementing decrees and technical guidelines. Recently, the National Environmental Protection System (SNPA) published Guideline 51/2024, which updates operational indications on radiometric surveillance and confirms which companies are legally obligated.
Based on Legislative Decree 101/2020 and SNPA guidelines, companies that “treat metal scrap and waste metal materials, as well as imported semi-finished metal products and finished products” are required to conduct surveillance. Furthermore, companies with environmental authorizations (AIA or waste) and those treating WEEE (Waste Electrical and Electronic Equipment) or producing “End of Waste” scrap from metals are also required to perform radiometric controls if stipulated in their authorization titles. Finally, it should be remembered that while the requirements are Italian, they derive from EU principles: every member state has transposed the Euratom 2013/59 directive into its own legal system, thereby coordinating procedures.
Summary: who are the obligated subjects for the radiometric monitoring of semi-finished metal products?
According to the law, the following must organize radiometric monitoring:
- Scrap dealers and foundries: those who import or collect scrap and waste metal materials, or melt them.
- Metal import centers: those who import semi-finished metal products (specified in the regulatory annex) in large warehouses or main transit hubs.
- Metal importers: those who import semi-finished products and, upon request from authorities, finished metal products.
Operators who only perform metal transport without customs operations are not subject to the obligation. In other words, the obligation falls on the producer/metal processing company or the recipient of foreign loads, not on the pure carrier.
SNPA guidelines and environmental agency documents reiterate that Legislative Decree 101/2020 imposes radiometric surveillance on those who “treat metal scrap, waste metal materials, semi-finished metal products, and imported finished products”.
In practice, this includes steel companies, car breakers, metal recycling workshops, foundries, scrap collection stations, recovery consortia, etc. If the issuance of environmental authorizations specifically provides for radiometric monitoring, waste and WEEE management companies must also comply.
Operational procedures for the radiometric monitoring of semi-finished metal products
The surveillance methods are defined by the Technical Annex of Legislative Decree 101/2020 (now Annex A of Legislative Decree 17/2022), which provides clear operational phases. Generally, all planned activities must be carried out according to good technical standards, with measurements recorded and official certificates issued. Specifically:
- External radiometric monitoring upon arrival: every incoming load of metal (scrap or semi-finished products) must be monitored using fixed or mobile radiometric instrumentation before unloading. This involves measuring ambient dose equivalent rates (H*(10)) around the load, using sensors around a container, wagon, or truck. If the load exceeds certain preset thresholds, an alarm is triggered, allowing for the detection of “hotspots” that may not be visible.
- Visual inspection at the time of unloading: simultaneously, personnel perform a visual check of the materials during unloading/handling, looking for apparent anomalies such as suspicious objects, different packaging, or signs of irradiation. If material with suspicious characteristics is identified, further localized radiometric assessments are conducted.
- Internal material control: if doubts emerge from the external monitoring or visual inspection, direct measurements are performed on the unloaded material. For example, parts of the loads are measured for external dose rates, or a portable detector is used near suspicious blocks. In foundries or recycling plants, internal controls are also applied to melting furnaces, analyzing casting samples for specific activity (Bq/kg) and inspecting slag and flue gas filtering waste for anomalous radiation.
These activities generate mandatory documentation. Every external check must correspond to a recording (often a “radiometric surveillance register”) kept at the company for at least five years. For imports, the result of the completed check is certified via an attestation issued by the appointed Radiation Protection Expert. The surveillance certificate, citing the date, time, instrument, measurement results, and the device’s last calibration, must be attached to the customs import declaration. In practice, no load can be cleared through customs without this official certification.
The instrumentation used (probes, fixed or mobile radiometric portals, scintillation or semiconductor detectors) must be calibrated and verified periodically. The appointed radiation protection expert (2nd or 3rd level) is technically responsible for the validity of the controls. Indeed, the legislator (Art. 72, paragraph 2) establishes that only these professionals registered in ministerial lists can sign the monitoring attestation.
In summary, the operational procedure requires:
- External detection of the load.
- Visual inspection of every material.
- Potential direct point measurement.
- Completion of the register.
- Issuance of technical certification by the expert.
Anomalies during radiometric measurements: what to do
If radiometric measurements detect abnormal levels of radioactivity higher than the natural background, or the presence of abandoned sources, the law mandates immediate action. Specifically, Legislative Decree 101/2020 establishes that the person discovering the anomaly must adopt security measures (such as moving the material, evacuating risk areas, or using shielding) and inform the competent authorities without delay. Communications must be sent to the Provincial Prefect, local health services (ASL), the Provincial Fire Brigade Command, the Region/Autonomous Province, and the local ARPA/APPA.
Even a carrier who accidentally discovers anomalous levels during transport is subject to this same information obligation. These rules aim to secure the population and allow authorities to activate emergency plans.
It must be emphasized that abuse is prohibited: if contamination of products or waste is found following processing (for example, melted sources in a steel mill), the contaminated material cannot be used, sold, or disposed of without special authorization from the Prefect. Ultimately, the regulation increases responsibility in the event of a radiological accident, providing for administrative and criminal procedures for non-compliance.
Role of the radiation protection expert
A key point of the regulation is the involvement of the Radiation Protection Expert (RPE). This professional (2nd or 3rd level) is qualified to perform or supervise radiometric monitoring and sign the certificate of conformity. The expert collaborates with the company to define the surveillance plan:
- Selects the instruments.
- Prepares operational instructions.
- Trains personnel on recognizing radioactive sources and regularly verifies measurement quality.
Specifically, the attestation issued by the RPE, which must be attached to the customs import declaration, includes the suitability of the instrument used. In practice, a radiometric monitoring certification is not valid without the signature of an RPE registered on the ministerial list.
Atlas Services S.r.l. – Our experience in radiation protection
Atlas Services S.r.l. is a company specialized in environmental and industrial radiation protection. Thanks to an internal team of Radiation Protection Experts and certified instrumentation, Atlas Services offers companies complete services for the radiometric monitoring of metal materials. Specifically, we can provide:
- Regulatory evaluation and technical consultancy to identify the company’s legal obligations according to Legislative Decree 101/2020 and the Energy Decree (D.L. 17/2022).
- Execution of incoming radiometric measurements: installation or use of fixed and mobile portal detectors at access points, with electronic data recording.
- Inspection and direct measurement on suspicious scrap or semi-finished products, with the issuance of detailed analytical reports.
- Issuance of radiometric monitoring attestations valid for customs purposes, signed by our Radiation Protection Experts, useful for importers.
- Staff training: specific courses on recognizing radioactive sources and managing radiological emergencies.
- Emergency procedure management: assistance in case of detecting anomalous radioactivity, communication with authorities, and support in remediation activities.
Atlas Services operates with accredited technicians. A tailored Radiometric Surveillance Plan is prepared for every client company, including operational protocols and personalized forms. For more information or to request a quote, you can contact our sales office or visit the company website.
