Strengthening Radiation Safety for Gauging Equipment under BAPETEN Regulation Number 2 of 2025
Summary
Regulation of the Nuclear Energy Regulatory Agency [Peraturan Badan Pengawas Tenaga Nuklir (BAPETEN)] Number 2 of 2025 on Radiation Safety in the Use of Ionizing Radiation Sources for Gauging Equipment (“BAPETEN Regulation 2/2025”) was issued and took effect on its date of promulgation on October 10, 2025.
The main objective of this regulation is to establish a comprehensive supervisory framework and radiation safety requirements for any party utilizing ionizing radiation sources in gauging equipment.
This regulation serves as an implementing measure of Government Regulation [Peraturan Pemerintah] Number 45 of 2023, to ensure that the utilization of nuclear technology in this industrial sector is protected from the harmful effects of ionizing radiation, under both normal and emergency operating conditions.
Background and Context
The issuance of this BAPETEN Regulation is based on the need to create safety standards in the supervision of nuclear energy utilization, specifically for the application of measurement or gauging equipment in industry. As stated in the preamble (considerations) section, this regulation specifically aims to implement the mandate of Article 33 and Article 66 paragraph (5) of Government Regulation Number 45 of 2023 on Ionizing Radiation Safety and Radioactive Substance Security.
This reflects the need to update and clarify existing safety norms to align with the development of higher-level legislation, as well as to address the challenges and risks that may arise from the use of ionizing radiation sources in a dynamic industrial work environment.
Comparison with the Previous Regulation
BAPETEN Regulation 2/2025 revokes and declares invalid the Regulation of the Head of BAPETEN [Peraturan Kepala BAPETEN] Number 6 of 2009 on Radiation Safety in the Use of Radioactive Substances and X-Ray Equipment for Gauging Equipment (“Head of BAPETEN Regulation 6/2009”).
A comparative analysis between the two regulations shows a significant strengthening, delegation, and addition of norms in the new regulation to enhance overall safety standards. The new regulation shifts from a category-based approach (high/low activity) to a more integrated and modern safety management framework.
| Aspect | Head of BAPETEN Regulation 6/2009 | BAPETEN Regulation 2/2025 |
| Safety Management Structure | Requires a person-in-charge and personnel (Radiation Protection Officer/RPO, Operator, Maintenance Officer). | Mandates the establishment of a "Radiation Safety Organizer" with a clear organizational structure (Chairperson, RPO, Members) and mandates the implementation of an integrated "Management System." |
| Radiation Protection and Safety Program (PPKR) Document | The document format consists of 5 chapters. The regulation's appendix states this program "does not need to be approved by the Head of BAPETEN" and is flexible for updates. | The document format is highly detailed and structured into 11 chapters. This document becomes the core of the safety system that must be comprehensively prepared, implemented, and updated by the License Holder. |
| Establishment of Worker Dose Constraint | Dose constraints are established by the License Holder after obtaining approval from the Head of BAPETEN and are reviewed periodically. | The License Holder must establish and review the Dose Constraint independently. This regulation provides clear technical guidance on its establishment based on the facility's operational period (0-2 years, 2-4 years, >4 years). |
| Leak Test Frequency | Conducted at least once every 2 years only for high-activity radioactive substances. | Conducted at least 1 (one) time every 2 (two) years for all relevant radioactive sources, regardless of activity category. |
| Emergency Reporting | Written reports regarding radiation accidents are submitted to the Head of BAPETEN no later than 5 (five) working days after the incident. | Reporting procedures are significantly strengthened: initial notification (phone/online system) no later than 1 (one) hour, followed by a written report no later than 2 (two) days after the incident. |
| Routine Reporting | Reporting frequency is differentiated by category: once a year for low-activity radioactive substances and every 6 (six) months for high-activity. | Standardized into one annual safety verification report that must be submitted by all License Holders via the online system. |
Key Provisions
| Regulatory Aspect | Provisions | Article(s) |
| Licensing Requirements | Any party intending to use ionizing radiation sources for gauging must have a license from BAPETEN. | Article 3 |
| Radiation Protection Principles | The License Holder must apply three basic principles of radiation protection: justification, optimization, and limitation. | Articles 7 - 12 |
| Radiation Protection for Workers | The License Holder must implement a protection program for workers, including work area zoning, provision of protection equipment, and periodic dose and health monitoring. | Articles 13 - 25 |
| Safety Assessment | Required to create a safety assessment report analyzing potential failures and risks. This assessment must be reviewed if there are modifications to the facility or procedures. | Articles 29 - 31 |
| Radiation Protection and Safety Program (PPKR) | The License Holder must prepare, implement, and update a comprehensive PPKR document according to the format in Annex II. | Articles 32 - 33 |
| Annual Verification and Reporting | The License Holder must conduct an internal verification of the PPKR implementation and report the results to the Head of BAPETEN at least 1 (one) time per 1 (one) year online. | Articles 35 - 36 |
| Equipment and Facility Requirements | Gauging equipment and radioactive source storage must meet strict design, standards, and maintenance requirements to contain radiation. | Articles 38 - 51 |
| Emergency Response | The License Holder must have a written emergency response plan and report any radiation accident immediately (max 1 hour verbally) followed by a written report (max 2 days). | Articles 52 - 55 |
| Management and HR | The License Holder is fully responsible for safety, must establish a radiation safety organizer, and ensure personnel (RPO, Operator, Maintenance Officer) have qualifications and competence. | Articles 61 - 72 |
| Leak Test Sanctions | Radioactive sources with leak test results exceeding 185 Bq are prohibited from use and must be designated as radioactive waste. | Article 45 |
| Closing Provision | This regulation immediately revokes and replaces Regulation of the Head of BAPETEN Number 6 of 2009 from its effective date. | Article 73 |
| Technical Annexes | The regulation is supplemented by five technical annexes as implementation guides, including the PPKR Document format and Emergency Forms. | Annexes I - V |
Annex I: Radiation Signage
This annex establishes the visual and technical standards for the radiation hazard sign (trefoil symbol) that must be installed on all gauging equipment and radioactive source storage areas. Its provisions include:
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Shape and Color: The symbol shall resemble a three-bladed propeller, colored black or red, with a yellow background.
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Wording: Must include the words "AWAS BAHAYA RADIASI" (CAUTION RADIATION HAZARD) in black or red block letters below the symbol.
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Visibility: The sign must be clearly visible and identifiable from a distance of at least 1 meter.
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Placement: The sign must be permanently affixed to the relevant equipment or location.
Annex II: Format and Content of the Radiation Protection and Safety Program (PPKR)
This annex specifies the structure and content of the PPKR document that the License Holder must possess. This document shall consist of 11 chapters, namely:
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Introduction: Contains company profile, background, objectives, scope, and legal basis.
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Radiation Safety Management: Outlines the safety organizer's organizational structure, personnel duties and responsibilities, training programs, quality assurance, list of procedures, and recording and reporting systems.
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Safety Assessment Report: Contains an in-depth analysis and evaluation of potential risks and system failures.
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Establishment of Dose Constraints: Explains the methods for establishing and reviewing dose constraints for workers, with technical guidance based on the facility's operational period.
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Facilities and Ionizing Radiation Sources: Describes the type, quantity, and specifications of the radiation sources used and the design of storage and operational facilities.
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Work Area Zoning: Explains the design of area division into controlled areas and supervised areas, complete with exposure rates and signage placement.
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Monitoring of Radiation Exposure in Work Areas: Details the plan, procedures, and equipment used to monitor radiation levels in the work environment.
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Worker Monitoring: Outlines the personal dose monitoring program and periodic health monitoring program for radiation workers.
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Public Exposure Monitoring: Explains the plan for monitoring radiation outside the work area and radioactive waste management procedures.
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Radiation Protection Equipment and Calibration Program: Lists all protection equipment used (dosimeters, survey meters, PPE) and the calibration schedule for measuring instruments.
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Radiation Emergency Program: Outlines potential types of emergencies, response plans, reporting procedures, and emergency training programs.
Annex III: Calculation of Radiation Shielding for Neutron Radiation Sources
This annex provides technical guidance for facilities using neutron radiation sources. It provides two mathematical formulas for calculating adequate shielding (radiation barrier) thickness:
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For AmBe-241 Sources: Uses the removal cross-section concept.
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For Neutron Generators: Uses a formula involving variables such as neutron flux, distance, and dose factors.
This annex also includes a table containing constant values (relaxation length, correction factors, and dose factors) for various shielding materials such as concrete, paraffin, and water, which are required for the calculations.
Annex IV: Nuclear Emergency Response Reporting Form
This annex provides the standard form format that must be completed and submitted by the License Holder to BAPETEN as a written report after a radiation accident occurs. This form is designed to collect crucial information quickly and in a structured manner, covering:
- Identity of the reporter and institution.
- Time and location of the incident.
- Brief description of the incident.
- Data of the radiation source involved (isotope type, activity).
- Data on radiation exposure and measured contamination levels.
- Number of victims (if any).
- Response actions that have been taken.
- Assistance expected from BAPETEN.
Annex V: Declaration of the End of the Emergency Condition
This annex contains the official letter format that must be created by the License Holder to declare that an emergency condition has been successfully handled and is declared over. This letter is addressed to the Head of BAPETEN and must contain:
- Reference to the initial emergency report.
- A brief explanation of the response actions taken.
- Justification for why the emergency condition is declared to have ended.
- A formal statement that "the emergency incident condition as described above is declared COMPLETE".
Conclusion
BAPETEN Regulation 2/2025 governs the supervision of nuclear energy utilization in Indonesia, particularly for the industrial sector using gauging equipment.
The approach used is the implementation of a radiation safety management system that is more structured, documented, and routinely verified. Three key points to note:
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The obligation to prepare and update the Radiation Protection and Safety Program Document according to a more detailed standard format;
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The requirement to proactively establish, monitor, and review Dose Constraints for workers with clear guidance; and
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The affirmation of the License Holder's legal responsibility, which cannot be delegated, even if operational tasks can be assigned.
This regulation encourages the creation of a stronger safety culture, where risk identification, prevention, and emergency preparedness become an integral part of all operational activities.
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