377 12 Regulations F. J. Bradley and R. M. Pratt CONTENTS 12.1 Introduction 378 12.1.1 Background 378 12.1.2 Overview 380 12.2 Derivation of Radioactivity Concentration Limits in Food and Drinking Water 381 12.3 International Regulations for Radioactivity in Food and Commodities 381 12.3.1 Codex Alimentarius Commission 381 12.3.1.1 Background 381 12.3.1.2 Implementation 382 12.3.2 Food and Agriculture Organization 383 12.3.2.1 Background 383 12.3.2.2 Implementation 383 12.3.3 European Union 385 12.3.3.1 Background 385 12.3.3.2 Inspection and Enforcement 387 12.3.4 International Atomic Energy Agency 387 12.3.4.1 Background 387 12.3.4.2 Implementation 388 12.4 National Regulations for Radioactivity in Food and Commodities 389 12.4.1 Australia 389 12.4.1.1 Background and Implementation 389 12.4.2 Lithuania 389 12.4.2.1 Background 389 12.4.2.2 Enactment 390 12.4.2.3 Inspection and Enforcement 391 12.4.3 Ukraine 391 12.4.3.1 Background 391 12.4.3.2 Implementation 392 12.4.3.3 Inspection and Enforcement 392 12.4.4 U.S. Food and Drug Administration 393 12.4.4.1 Background 393 12.4.4.2 Promulgation 394 12.4.4.3 Derived Intervention Levels 394 12.4.4.4 Surveillance and Enforcement 395 DK594X_book.fm Page 377 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC 378 Radionuclide Concentrations in Food and the Environment 12.4.5 U.S. Nuclear Regulatory Commission 395 12.4.5.1 Background 395 12.4.5.2 Inspection and Enforcement 399 12.4.6 Japan 399 12.4.6.1 Background 399 12.4.6.2 Implementation 400 12.4.7 Canada 400 12.4.7.1 Background 400 12.4.7.2 Implementation 401 12.4.7.3 Comparison of Standards for Radioactivity in Food 401 12.5 International Regulations for Radioactivity in Drinking Water 403 12.5.1 World Health Organization 403 12.5.1.1 Background 403 12.5.1.2 Implementation 403 12.5.1.3 Inspection and Enforcement 405 12.6 National Regulations for Radioactivity in Drinking Water 405 12.6.1 U.S. Environmental Protection Agency Drinking Water Standards 405 12.6.1.1 Background and Implementation 405 12.6.2 New Zealand 407 12.6.2.1 Background and Implementation 407 References 407 Acronyms 409 Glossary 410 12.1 INTRODUCTION 12.1.1 B ACKGROUND Regulations for control of radioactivity in food and the environment are myriad and complex. International and national bodies have formulated maximum per- missible contamination limits in response to the 1986 Chernobyl accident and, more recently, in preparation for future radiological emergencies, either accidental or by malevolent intent. Individual countries have promulgated sets of regulatory limits, some based on international standards, some generated internally. To list control values for all countries would be impractical; therefore, this chapter will present a limited selection of regulations and recommendations from international agencies and some individual nations. Since radioactivity in food, the environment, and drinking water involves public exposure, tables in this chapter present concentration limits based on the concept of dose limitations to the public. For comparison and completeness, occupational dose limits for regulated industries, issued by the International Atomic Energy Agency (IAEA) and the U.S. Nuclear Regulatory Commission (NRC), are presented in Section 12.3.4 and Section 12.4.5, respectively. DK594X_book.fm Page 378 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC Regulations 379 Methodologies for derivation of concentration limits in food and water are discussed, with examples provided. An area of concern is radionuclides in soil, especially following decommissioning of formerly licensed or regulated facilities. Generic soil limits are not provided since they are site specific, but a decision-making statistical methodology to demonstrate compliance with limits, the Multiagency Radiation Survey and Site Investigation Manual (MARSSIM), is briefly covered in Section 12.4.5. While most regulatory limits are based on doses above natural background radiation, some values include background, such as drinking water standards, which are discussed in Section 12.5 and Section 12.6. All foods have some radioactivity arising from naturally occurring radionu- clides, and some people have declared that this is beneficial. Natural radioactivity in matter arises mainly from 3 H, 14 C, 40 K, 226 Ra, natural thorium (Th-nat), natural uranium (U-nat), and their decay products. Thoron and radon ( 220 Rn and 222 Rn) are ubiquitous noble gases and can cause especially high inhalation doses aver- aging 1.2 mSv/yr with a range of 0.2 to 10 mSv/yr. The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) [1] has provided an estimate of worldwide average public radiation exposures, as presented in Table 12.1. This table provides a perspective for the public exposure limits rec- ommended by various agencies in this chapter and indicates that naturally occur- ring radionuclides impose an internal ingestion dose of 0.3 mSv/yr or 30 mrem/yr. According to the Department for Environment, Food and Rural Affairs, United Kingdom (DEFRA) [2], approximately 60% of the annual internal ingestion background dose arises from 40 K; the remaining 40% is from the other naturally occurring radionuclides. Potassium is regulated by the body so that adults have TABLE 12.1 Average Radiation Dose from Natural Sources Source Worldwide Average Annual Effective Dose (mSv/yr) Typical Range (mSv/yr) External exposure Cosmic rays Terrestrial gamma rays a 0.4 0.5 0.3–1.0 0.3–0.6 Internal exposure Inhalation (mainly radon) Ingestion (food and drinking water) 1.2 0.3 0.2–10 b 0.2–0.8 Total 2.4 1–10 a Terrestrial exposure is due to radionuclides in the soil and building materials. b Dose from inhalation of radon may exceed 10 mSv/yr in certain residential areas. Source: UNSCEAR, 2000 [1]. See http://www.who.int/water_sanitation_health/dwq/gdwq3/en. DK594X_book.fm Page 379 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC 380 Radionuclide Concentrations in Food and the Environment a fairly constant potassium content. The other naturally occurring radionuclides vary greatly among individuals, depending on their culture, diet, and food sources. Individuals in Kerala, India, and Pocos del Cobdas, Brazil have evolved in a total background average dose level of about 24 mSv/yr (10 times the norm) with apparently no detectable ill effects. There is a long history of regulating toxic chemicals, such as lead and arsenic, in food and commodities, and in the 1950s the concept of regulating radioactivity in the environment, especially in air and water, was formalized. New York State Industrial Code, Rule 38 [3] listed maximum permissible concentrations (MPC) in units of microCuries per milliliter (µCi/ml) in air and water based on the then- current doses recommended by the National Committee on Radiological Protec- tion (NCRP) [4]. At about the same time, the U.S. Atomic Energy Commission (AEC) — later the regulatory side became the NRC — issued “Part 20, Standards for Protection Against Radiation” (see Section 12.4.5). These recommendations differentiated between occupationally exposed workers and the public, with the public MPC set at about 3% of the worker MPC. Two events, worldwide fallout from atmospheric testing of nuclear weapons and the Chernobyl nuclear reactor meltdown, galvanized many regulatory agen- cies to determine what impact such events had on foodstuffs and to issue regu- lations governing their transnational transport. 12.1.2 O VERVIEW This chapter presents two classes of regulations. The first class embodies recom- mendations issued by international organizations that, in most cases, are not legally binding and the second class of regulations represents those issued by national governments that, in most cases, have some legal status. Most guidelines specify limits on radioactivity in food and drinking water. The IAEA has issued a set of recommendations covering the broad topic of contamination of commodities. The limits presently in force and characterized in this chapter are as follows: Chernobyl contamination related limits: Food and Agriculture Organization (FAO), Section 12.3.2 European Union (EU), Section 12.3.3 Australia, Section 12.4.1 Lithuania, Section 12.4.2 Ukraine, Section 12.4.3 Other limits that address future radiological contaminating events: Codex Alimentarius Commission, Section 12.3.1 EU, Section 12.3.3 Lithuania, Section 12.4.2 U.S. Food and Drug Administration (FDA), Section 12.4.4 Japan, Section 12.4.6 Canada, Section 12.4.7 Then there are limits covering on-going licensed or regulated operations handling radioactivity: DK594X_book.fm Page 380 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC Regulations 381 International Atomic Energy Agency (IAEA), Section 12.3.4 U.S. Nuclear Regulatory Commission (NRC), Section 12.4.5 Finally, agencies that address the sensitive topic of radioactivity in drinking water: World Health Organization (WHO), Section 12.5.1 U.S. Environmental Protection Agency (EPA), Section 12.6.1 New Zealand Ministry of Health, Section 12.6.2 12.2 DERIVATION OF RADIOACTIVITY CONCENTRATION LIMITS IN FOOD AND DRINKING WATER The methodology for estimating the MPC of radionuclides in food and drinking water is well established and goes back to the earliest regulations in radiation protection. Mathematically, for the i th radionuclide, the equation is (12.1) where MPC = maximum permissible concentration (in Bq/kg for solid or liquid and Bq/l for water), D = maximum recommended dose per unit time per critical organ (in mSv/yr), f = fraction of food intake that is contaminated (dimensionless), FI = food intake per unit time (in kg/yr or l/yr), DC = dose conversion factor (in mSv/Bq). Equation 12.1 is used to illustrate the derivation of the various concentration limits throughout the chapter. Terms used for radioactivity concentration limits by various agencies include MPC, guideline level (GL), action level (AL), maximum acceptable value (MAV), international radionuclide action level for foods (IRALF), intervention level (IL), derived intervention level (DIL), level of concern (LOC), and other similar terms. The annual dose unit is in millisieverts per year (mSv/yr) and usually indicates the committed effective dose equivalent (CEDE). In some cases, the unit repre- sents the committed dose equivalent (CDE), when only the individual tissue or organ is the target. The f factor given in Equation 12.1 may vary from 0.01 to 1.0; the assumed value will be given in the various subsections. 12.3 INTERNATIONAL REGULATIONS FOR RADIOACTIVITY IN FOOD AND COMMODITIES 12.3.1 C ODEX A LIMENTARIUS C OMMISSION 12.3.1.1 Background The Codex Alimentarius Commission (CAC) is a joint endeavor of the Food and Agriculture Organization (FAO) and the World Health Organization (WHO) of MPC D fFIDC i i i = ()( ) DK594X_book.fm Page 381 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC 382 Radionuclide Concentrations in Food and the Environment the United Nations (UN). The Codex Alimentarius, or Food Code, is the global reference of good practice for consumers, food producers and processors, and national food control agencies in the international food trade. It provides recommen- dations for GLs for radioactivity in foods to assist UN agencies. The GLs may become the basis for national action levels [5]. They are reproduced in Table 12.2. The proposed recommendations of the CAC are at step five of the overall acceptance procedure. The GLs are intended to apply to radionuclide contami- nation in food destined for human consumption and traded internationally. It is suggested that the GLs apply to food after reconstitution (not dried foods) and ready for consumption in the first year after a nuclear accident or malevolent incident. The nuclides in Table 12.2 are those most likely present after such an event. Naturally occurring radionuclides are excluded except for 235 U, 3 H, and 14 C. The nuclides are segregated into four groups with the GLs logarithmically rounded by orders of magnitude (i.e., 1, 10 2 , 10 3 , and 10 4 Bq/kg). 12.3.1.2 Implementation Each radionuclide group in Table 12.2 can be treated independently, but for multiple radionuclides within each group, the sum of the concentrations must be less than the GL for that group. If the concentration in food is less than the GL, the food is considered safe for human consumption. When contamination exceeds the GL, the national government must decide whether, and under what circum- stances, the food will be distributed. National governments may want to adopt different GLs if the underlying assumptions do not apply. The GLs are determined using Equation 12.1. The example for the case of 90 Sr uses the following assumptions: TABLE 12.2 Codex Alimentarius Commission, United Nations: Emergency Food Guideline Levels Group Radionuclides Guideline Level (Bq/kg) I 238 Pu, 239 Pu, 240 Pu, 241 Am 1 II 90 Sr, 106 Ru, 129 I, 131 I, 235 U 100 III 35 S, 60 Co, 89 Sr, 103 Ru, 134 Cs, 137 Cs, 144 Ce, 192 Ir 1,000 IV 3 H, 14 C, 99 Tc 10,000 Source: CAC, 2004 [5]. See http://www.criirad.com/criirad/actualites/Dossiers2005/ MenacesRadioactivesAliments/Extrait%20Codex%20Anglais.doc. DK594X_book.fm Page 382 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC Regulations 383 D = 1 mSv/yr, committed effective dose, DC = 2.3 × 10 –4 mSv/Bq, from the ICRP [6,7], FI = 550 kg/yr, for adults, FI = 200 kg/yr, for infants, f = 0.1, imported food in the first year following a nuclear accident or malevolent incident, f = 0.01, minor foods (garlic, truffles, etc.). for infants GL Sr– 90 = 217, rounded to 100 Bq/kg. In a similar manner, the GLs for other radionuclides can be determined. 12.3.2 F OOD AND A GRICULTURE O RGANIZATION 12.3.2.1 Background The FAO advises member states on topics of agriculture, production, processing, and storage of food as well as legislation controlling food quality and safety [8]. As a result of the Chernobyl accident in 1986, there was considerable disruption in the worldwide food distribution chain due to a lack of knowledge on radioactive contamination standards for food. The FAO convened a group of technical experts that issued two reports upon which the present recommendations for International Radionuclide Action Levels for Foods (IRALF) are based. To establish IRALFs, the following underlying principles were followed: • The IRALF should be simple, uniform and applicable to all food moving in international trade. • Consumers and food and health authorities can easily understand the IRALF. • The IRALF should be sufficiently low that no further action is neces- sary if the food is at or below the limits. 12.3.2.2 Implementation The IRALFs for three groups of radionuclides were determined by utilizing Equation 12.1. Group I covered 90 Sr and 131 I; group II, 134 Cs and 137 Cs; and group III, 239 Pu. GL D fFIDC i i i = ()( ) GL Sr− − = × 90 4 1 01 200 2 3 10 mSv/y kg/y mSv/Bq(.)( )( . )) , DK594X_book.fm Page 383 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC 384 Radionuclide Concentrations in Food and the Environment The following assumptions were made: • 100% of the diet is contaminated, f = 1. •For radionuclides with half-lives of less than 70 days, the food intake is for a period of five half-lives. For example, for 131 I, FI is the intake over 40 days. •For radionuclides with half-lives of more than 70 days, the full annual FI is assumed. • The IRALF from different groups can be applied independently of one another. • The IRALF for cesium isotopes should be limited by the sum of fractions rule. • Allowances should be made in applying IRALFs to dried or concentrated food before reconstitution and for food consumed in small quantities, such as herbs and spices (i.e., f = 0.1). Using Equation 12.1 to derive the IRALF for 239 Pu in the first year following a radiological incident, make the following substitutions: D = 50 mSv/yr, committed dose equivalent, FI = 375 kg/yr (for a child), DC = 1.7 × 10 –2 mSv/Bq, f = 1. GL Pu -239 = 8, rounded to 10 Bq/kg. The IRALFs become effective in the first and second year following an incident. Table 12.3 gives the derived IRALFs for five radionuclides ( 90 Sr, 131 I, 134 Cs, 137 Cs, and 239 Pu), and using the same methodology, IRALFs for other radionuclides can be derived. At the time of the Chernobyl accident, dose coef- ficients were available for infants and children from Johnson and Dunsford [9] and for adults from ICRP [10] and the lower limit was the recommended IRALF given in the expert report [11]. These values are also given in Table 12.3. Many countries at the time used a similar methodology to establish limits. The U.S. FDA analyzed 1,035 samples of imported food from a 400 km radius around Chernobyl in the year following April 26, 1986. The findings were that 12 samples exceeded the limits as follows [8]: •Two cheese samples, 131 I. •Five pasta samples, 134 Cs and 137 Cs. •Four spice samples, 134 Cs and 137 Cs. • One cheese sample 134 Cs and 137 Cs. IRALF Pu− − = × 239 2 50 1 375 1 7 10 mSv/y kg/y mSv()( )(. //Bq) DK594X_book.fm Page 384 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC Regulations 385 The total value of food imports from the region totaled US$5 billion and the impounded imports US$0.2 million, so the economic impact from these findings was insignificant. 12.3.3 E UROPEAN U NION 12.3.3.1 Background Regulations for radioactivity in food in the European Union (EU) are in a state of flux. Two sets of regulations are in force; the first set applies to food imported into the EU following the Chernobyl accident and the second set addresses future radiological incidents resulting in potential food contamination. Steps are being taken to rationalize and harmonize the standards. The first set of regulations (designated as Council Regulations European Economic Communities [EEC] No. 737/90) applies to imported food products orig- inating in third-world countries. The regulation has been amended several times and Council Regulations European Communities (EC) No. 616/2000 extended this regulation to March 31, 2010 [12]. Table 12.4 gives the maximum permissible limits for imported foods into the EU following the Chernobyl accident. TABLE 12.3 Food and Agriculture Organization (FAO) International Radionuclide Action Levels in Food (IRALF) Group Nuclide Target Organ Dose (mSv/yr) Dose Conversion (mSv/Bq) Food Intake (kg/yr) IRALF (Bq/kg) I 90 Sr first year 90 Sr following years Bone surface 50 10 1.9 × 10 –3 1.9 × 10 –3 375 70 20 131 I first year Thyroid (infant) 50 2.9 × 10 –3 40 400 II 134 Cs first year 134 Cs following years Whole body (adult) 5 1 2.0 × 10 –5 2.0 × 10 –5 750 350 50 137 Cs first year 137 Cs following years Whole body (adult) 5 1 1.4 × 10 –5 1.4 × 10 –5 750 500 100 III 239 Pu first year 239 Pu following years Bone surface (infant) 50 10 1.7 × 10 –2 1.7 × 10 –2 375 10 2 Source: FAO [11]. See http://www.criirad.com/criirad/actualites/Dossiers2005/MenacesRadioactivesAliments/ Extrait%20Codex%20Anglais.doc. DK594X_book.fm Page 385 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC 386 Radionuclide Concentrations in Food and the Environment The second set of regulations was passed by the EC in 1987 [13] for future radioactive food contamination incidents and was amended in 1989. These limits are called interventional levels (ILs) and are reproduced in Table 12.5. They are applicable for 3 months postincident or until amended. They apply to four radi- onuclide groups and five food groups and follow the recommendations of the ICRP [14]. There have been complaints about the regulations since the 137 Cs IL for baby foods is 370 Bq/kg for the Chernobyl contamination and 400 Bq/kg for TABLE 12.4 European Union: Maximum Permissible Levels for Imported Food Into EU Following the Chernobyl Accident Radionuclide Milk, Milk Products, and Foodstuffs* (Bq/kg) All Other Food Products (Bq/kg) 134 Cs + 137 Cs 370 600 * Intended for infants 4 to 6 months old. Source: Official Journal of the European Communities [12]. TABLE 12.5 European Union: Intervention Levels Group Radionuclide Baby Food a (Bq/kg) Dairy Products b (Bq/kg) Minor Foods c (Bq/kg) Other Foods d (Bq/kg) Liquid Foods e (Bq/kg) I Isotopes of strontium Mainly 90 Sr 75 125 7,500 750 125 Isotopes of iodine Mainly 131 I 150 500 20,000 2,000 500 II α emitters of plutonium and trans-plutonium elements 120800 80 20 III All other nuclides with T ½ >10 days, mainly 134 Cs, 137 Cs 400 1,000 12,500 1,250 1,000 a Foodstuffs meant for feeding of infants in the first 4 to 6 months of life. b Milk and cream only. c Foods consumed in very small quantities, including herbs, spices, fats, oils, preserved fruits and nuts, caviar, and truffles. d All foods not listed. e Fruit and vegetable juices, bottled water, beer, wine, spirits, and vinegar. Source: Official Journal of European Communities [13]. See http://www.es.lancs.ac.uk/casestud/case3.htm. DK594X_book.fm Page 386 Tuesday, June 6, 2006 9:53 AM © 2007 by Taylor & Francis Group, LLC [...]... are incorporated in the GLs in Table 12. 18 12. 6 NATIONAL REGULATIONS FOR RADIOACTIVITY IN DRINKING WATER 12. 6.1 U.S ENVIRONMENTAL PROTECTION AGENCY DRINKING WATER STANDARDS 12. 6.1.1 Background and Implementation The EPA is empowered by law [31] to set enforceable standards for public drinking water supplies in the U.S The drinking water standards assume a water intake (FI) of 2 l/day, 365 days/yr, and. .. independently for each radionuclide group In the case of 103Ru and 106Ru the combination DIL is limited by the sum of the fractions rule because of the wide disparity in their individual DILs The original selection of radionuclides in Table 12. 12 was based on Chernobyl experience Using the same methodology, DILs were determined for 15 additional radionuclides These results are given in Table 12. 13, but are... under existing protocols with the individual provinces and territories 12. 4.7.3 Comparison of Standards for Radioactivity in Food Health Canada guidelines [29] provide an overview of the various recommendations on radioactivity in food in a unique table The table has been updated and reproduced in Table 12. 17 in amended form It is helpful in gaining an understanding of the various regulations and recommendations... Table 12. 4 and Table 12. 5) But considering the statistical nature of radioactive decay and background subtraction, there is no significant difference between these values More significant differences exist between the tables under the heading: Other Foods for 137Cs The limit is 125 0 Bq/kg in Table 12. 5 and 600 Bq/kg in Table 12. 4 12. 3.3.2 Inspection and Enforcement Under EEC Regulation No 737/90 [12] (see... stringent drinking water standard for radioactive contamination [33] The standard specifies radon concentrations in drinking water that are close to the recently recommended WHO standard for radon in water Table 12. 21 lists the maximum acceptable values (MAVs) for gross α and β activity exclusive of radon and 40K determinands TABLE 12. 21 New Zealand: Maximum Acceptable Values for Radiological Determinands... 1991 for the most heavily affected regions of Kiev, Volynski, and Zhytomyr New updated regulations were issued and approved by the Ministry of Health in 1997, effective January 1, 1998, for acceptable levels of 137Cs and 90Sr in food for 16 food groups, including drinking water (AL-97) These are still in force and are reproduced in Table 12. 11 The standards are based on a typical Ukrainian diet and should... Bq/kg As described in the WHO [30], the value is rounded as follows: If GL is between 3 × 10n and 3 × 10n–1, then the GL = 10n Therefore, in this case, the GL of 236 is between 30 and 300, then GL = 100 Bq/l 12. 5.1.3 Inspection and Enforcement The WHO recommends that all new public drinking water supplies should be screened for their radionuclide content to comply with the screening standards mentioned... dose to the lens of the eye of 15 mSv in a year; and (d) an equivalent dose to the skin of 50 mSv in a year Throughout the nuclear complex, including industry, research institutes, universities, and hospitals where persons are working with radioactivity, there has been a cry for exempt limits for radionuclides in commodities In response, the General Conference of the IAEA passed a resolution in 2000... improve drinking water quality Fortunately radioactive contaminants in drinking water are not a common water quality problem But it is of public concern, and public health officials must screen for the presence of radioactivity in drinking water Drinking water standards are different from most limits in this chapter because they apply to public drinking water supplies with the assumption that individuals... www.unece.org/env/epr/studies/ukraine /chapter0 4.pdf 12. 4.4 U.S FOOD AND DRUG ADMINISTRATION 12. 4.4.1 Background The FDA Center for Food Safety and Applied Nutrition (CFSAN) issued the Compliance Policy Guide (CPG) for radioactivity in food starting in June 1986 in response to the Chernobyl accident In the original CPG, the concentration limit term used was levels of concern (LOC) In recent years, ILs have been used since the CAC, . LIMITS IN FOOD AND DRINKING WATER The methodology for estimating the MPC of radionuclides in food and drinking water is well established and goes back to the earliest regulations in radiation protection Radioactivity in Drinking Water 405 12. 6.1 U.S. Environmental Protection Agency Drinking Water Standards 405 12. 6.1.1 Background and Implementation 405 12. 6.2 New Zealand 407 12. 6.2.1 Background and Implementation. differences exist between the tables under the heading: Other Foods for 137 Cs. The limit is 125 0 Bq/kg in Table 12. 5 and 600 Bq/kg in Table 12. 4. 12. 3.3.2 Inspection and Enforcement Under EEC