ANSN Issues Resolution on NORM Management in the Oil and Gas Industry

In April, Brazil’s National Nuclear Safety Authority (ANSN) issued Resolution No. 14/2026, establishing requirements for the registration of facilities, the adoption of radiological protection measures, and the management of materials, waste and residues containing Naturally Occurring Radioactive Material (NORM) in the oil and gas industry, including decommissioning activities.

The new Resolution revokes CNEN Resolution No. 288/2021, which previously regulated only the registration of Exploration and Production (E&P) facilities engaged in cleaning and conditioning activities involving NORM-containing waste. The new framework significantly expands the regulatory scope to cover all stages of the NORM lifecycle, from generation to decommissioning, and introduces specific criteria for segregation, clearance and storage.

Key aspects of the Resolution include:

• Registration requirements: Registration with ANSN is required for (i) companies or entities directly performing activities subject to regulatory control at onshore or offshore facilities; and (ii) E&P concessionaires, regardless of whether they directly perform such activities, as the legally responsible parties for the management and final disposal of NORM materials, waste, and residues generated under their title, including those generated by contractors and subcontractors. The Resolution requires a separate registration for each facility.
• Validity of registration: ANSN registrations will be valid for five years and may be renewed upon request submitted at least 90 days prior to expiration.
• Exemption from registration: Service providers performing NORM-related activities exclusively within already-registered facilities may be exempt from registration, provided they do not assume responsibility for NORM management. Nevertheless, such service providers must maintain their own occupational dose control systems for workers.
• Obligations of registered facilities: Registered facilities must implement and maintain (i) a management system for contaminated materials, waste and NORM residues; and (ii) a Radiological Protection Service (SPR), including a duly certified Radiation Protection Supervisor. Activities must be formalized in a NORM Management Plan (PGN) and a Radiological Protection Plan (PPR), to be updated every two years or whenever relevant changes occur.
• Responsibility of concessionaires: Concessionaires are responsible for the full management of NORM materials, waste, and residues generated under their title, including those originating from contractors and subcontractors, through to final disposal. Where technically feasible, cleaning and decontamination must be prioritized.
• Exemption and clearance from regulatory control: The Resolution provides that (i) materials and waste meeting exemption criteria are not subject to regulatory control; (ii) unconditional clearance may only be applied where the criteria set forth in the applicable regulatory guidance are met; and (iii) conditional clearance may be granted, subject to ANSN approval, in cases that do not qualify for exemption or unconditional clearance.
• NORM storage: the Resolution establishes two types of storage: (i) operational storage, of a temporary nature and integrated into routine operations; and (ii) extended storage, applicable to periods exceeding those required for direct handling, restricted to E&P concessionaires or duly registered storage service providers.

For implementation purposes, reference should be made to the Regulatory Guide “NORM Management in the Oil and Gas Exploration and Production Industry,” approved by ANSN Ordinance No. 44/2026, which complements the Resolution by setting forth technical requirements and operational guidance.

The new framework represents a significant step forward in consolidating the regulatory regime applicable to NORM management in the oil and gas sector, with direct implications for operators, concessionaires and service providers, particularly with respect to the allocation of responsibilities, compliance requirements and the management of radiological risks throughout the lifecycle of activities.

Tauil & Chequer Advogados in association with Mayer Brown’s Environmental, Climate Change and Sustainability Practice remains available to provide further clarification on the regulatory impacts of the new Resolution.