Radiation Safety Officer (RSO) Qualifications

TYPE A LICENSE
10 CFR 33.13 Requirements for the issuance of a Type A specific license of broad scope.

An application for a Type A specific license of broad scope will be approved if:
(c) The applicant has established administrative controls and provisions relating to organization and management, procedures, record keeping, material control, and accounting and management review that are necessary to assure safe operations, including:
(2) The appointment of a radiological safety officer who is qualified by training and experience in radiation protection and who is available for advice and assistance on radiological safety matters.

TYPE B LICENSE
10 CFR 33.14 Requirements for the issuance of a Type B specific license of broad scope.

An application for a Type B specific license of broad scope will be approved if:
(b) The applicant has established administrative controls and provisions relating to organization and management, procedures, record keeping, material control and accounting, and management review that are necessary to assure safe operations, including:
(1) The appointment of a radiological safety officer who is qualified by training and experience in radiation protection and who is available for advice and assistance on radiological safety matters.

TYPE C LICENSE
10 CFR 33.15 Requirements for the issuance of a Type C specific license of broad scope.

An application for a Type C specific license of broad scope will be approved if:
(b) The applicant submits a statement that byproduct material will be used only by, or under the direct supervision of, individuals who have received:
(1) A college degree at the bachelor level, or equivalent training and experience, in the physical or biological sciences or in engineering; and
(2) At least 40 hours of training and experience in the safe handling of radioactive materials and in the characteristics of ionizing radiation, units of radiation dose and quantities, radiation detection instrumentation, and biological hazards of exposure to radiation appropriate to the type and forms of byproduct material to be used.

BROAD SCOPE GENERAL
NUREG 1556, Vol 11 Licenses of Broad Scope
8.7.3 Radiation Safety Officer
Criteria: Type A and Type B broad-scope licensees must have a Radiation Safety Officer (RSO) who is qualified by training and experience in radiation protection and who is available for advice and assistance on radiological safety matters. The RSO's training and experience must include the types and quantities of licensed material to be authorized on the license. While regulation does not require Type C broad-scope licensees to have an RSO, 10 CFR 33.15 requires that the licensee establish administrative controls and provisions relating to procurement of byproduct material, procedures, record keeping, material control and accounting, and management review to assure safe operations. Type C broad-scope licensee management should appoint someone responsible for the day-to-day operation of the radiation safety program, such as an RSO.

When selecting an RSO, the applicant should keep in mind the duties and responsibilities of the position and select an individual who is qualified to serve as the RSO. The RSO will need a basic technical knowledge sufficient to understand, in general, the majority of the work being done with byproduct materials under his or her responsibility. NRC recognizes that an RSO cannot be an expert in all areas that might be involved in a broad-scope program. The RSO should be qualified by training and experience to perform the duties required for the position.

MANUFACTURING
NUREG 1556, Vol. 12 Manufacturing and Distribution
8.7.1 Radiation Safety Officer
Criteria: RSOs must have training and specific experience with the types and quantities of licensed material to be authorized on the license.

The RSO needs independent authority to stop operations that he or she considers unsafe. He or she must have sufficient time and commitment from management to fulfill certain duties and responsibilities to ensure that radioactive materials are possessed and used in a safe manner. NRC requires the name of the RSO to be listed on the license to ensure that licensee management has identified a responsible, qualified person and that the named individual knows of his or her designation as RSO.

The amount of training and experience will depend on the type, form, quantity, and proposed use of the licensed material requested. For instance, in addition to a college degree, RSOs at a manufacturing company where workers handle curie quantities of radioactive material should be specialists in the field of radiation protection and may need 40 hours of radiation safety training specific to their job duties as well as a year of experience with similar types, forms, quantities, and uses of radioactive material before the individual is qualified to be RSO. On the other hand, RSOs at "manufacturers" who are importers of timepieces containing tritium that are received in the United States as completed products that will be distributed as exempt quantities may only require a few hours of radiation safety training and no prior experience with timepieces containing tritium to be qualified as an RSO. The proposed RSO's training and experience must be sufficient to identify and control the anticipated radiation hazards. For example, the RSO should have experience planning and conducting evaluations, surveys, and measurements similar to those required by the licensee's Radiation Safety Program. In addition, the RSO designee should have obtained the above training in a formal course designed for RSOs, presented by an academic institution, commercial radiation safety consulting company, or professional organization of radiation protection experts.

ACADEMIC, RESEARCH
NUREG 1556, Vol. 7 Academic, Research and Development, and Other Licenses of Limited Scope
8.7.1 Radiation Safety Officer (RSO)
Criteria: RSOs must have adequate training and experience. RSOs must also have specific experience with the types and quantities of licensed material to be authorized on the license.

The person responsible for implementing the radiation protection program is called the Radiation Safety Officer, or RSO. This individual may also be called the Radiation Protection Officer (RPO). The RSO needs independent authority to stop operations that he or she considers unsafe.

NRC believes that to demonstrate adequate training and experience, the RSO should have (1) as a minimum, a college degree at the bachelor level or equivalent training and experience in physical, chemical, biological sciences, or engineering; and (2) training and experience commensurate with the scope of proposed activities.  Training should include the following subjects:

• Radiation protection principles
• Characteristics of ionizing radiation
• Units of radiation dose and quantities
• Radiation detection instrumentation
• Biological hazards of exposure to radiation (appropriate to types and forms of byproduct material to be used)
• NRC regulatory requirements and standards
• Hands-on use of radioactive materials

The length of (2) above will depend upon the type, form, quantity, and proposed use of the licensed material requested. Ultimately, the proposed RSO's training and experience should be sufficient to identify and control the anticipated radiation hazards. In addition, the RSO designee should have obtained the above training in a formal course designed for RSOs presented by an academic institution, commercial radiation safety consulting company, or professional organization of radiation protection experts.


IRRADIATOR
NUREG 1556 Vol. 6 Irradiator Licenses
8.7.1 Radiation Safety Officer (RSO) Training and Experience
Criteria: A Radiation Safety Officer (RSO) must have adequate training and experience. Successful completion of training as described in Appendix G is evidence of adequate training and experience.

Discussion: The person responsible for the radiation protection program is called the RSO. The application must include the name and a description of the training and experience of the proposed RSO. This is to determine whether the individual is qualified to function as the RSO.

Consistent with the NRC staff's long-standing guidance, if the RSO has had neither previous formal training in health physics nor certification by the American Board of Health Physics, the RSO should complete a radiation safety course. Training should include approximately 40 hours covering the following topics:

• Radioactivity and radioactive decay
• Interactions of radiation with matter
• Biological effects of radiation
• Radiation detection using radiation detection instruments and personnel dosimeters
• Basic radiation protection principles and good safety practices (including time, distance, and shielding)
• Radiation protection regulations

The course should include a written test or evaluation of the individual's comprehension of these topics.

In addition to the above general course, if the RSO was previously an RSO at a similar licensee or was trained as an irradiator operator but has not had experience working at an irradiator, he or she should have the equivalent of at least 40 hours in self-study or directed study on information directly applicable to radiation safety at irradiators. This should include applicable regulations (10 CFR Parts 20 and 36) and reports or studies describing case histories of accidents or problems at irradiators; see Appendix G. The license application should list the documents studied or to be studied in the description of the training of the proposed RSO and should describe how the applicant will evaluate the individual's comprehension of the information studied.

The RSO should have at least three months (full-time equivalent) of experience at the applicant's irradiator or at another irradiator of a similar type. The three months of experience may include preoperational involvement, such as acceptance testing, while the irradiator is being constructed.

However, to allow flexibility, the NRC will determine the adequacy of the RSO's training and experience on a case-by-case basis, looking at his or her actual qualifications and drawing on the NRC staff's experience in reviewing such qualifications.

NUREG 1556, Vol. 6, Appendix G Training for RSO for Irradiator Licenses
Instruction may be in the form of lecture, videotape, or self-study emphasizing practical subjects important to safe use of irradiators:

Radiation Safety:

• External radiation vs. radioactive contamination
• Internal vs. external exposure
• Biological effects of radiation (e.g., why large radiation doses must be avoided)
• Units of radiation dose
• Types and relative hazards of radioactive material possessed
• ALARA concept
• Use of time, distance, and shielding to minimize exposure (e.g., how shielding and access controls prevent large doses)
• Proper use of survey meters and personnel dosimeters

Regulatory Requirements:

• Applicable regulations
• NRC dose limits
• License conditions, amendments, renewals
• Locations of use and storage of radioactive materials
• Material control and accountability
• Annual audit of radiation safety program
• Transfer and disposal
• Record keeping
• Case histories of accidents or problems involving irradiators
• Handling incidents
• Recognizing and ensuring that radiation warning signs are visible and legible
• Licensing and inspection by regulatory agency
• Need for complete and accurate information (10 CFR 30.9)
• Employee protection (10 CFR 30.7)
• Deliberate misconduct (10 CFR 30.10)

Practical Explanation of the Theory and Operation for Irradiators:

• Basic function of the irradiator
• Radiation safety features of an irradiator
• Operating and emergency procedures which the individual is responsible for performing
• Routine vs. nonroutine maintenance
• Lock-out procedures
• How an irradiator is designed to prevent contamination
• On-the-job or simulator training must be done under the supervision of a qualified irradiator operator

Supervised Hands-On Experience Performing:

• Operating procedures which the individual is responsible for performing
• Test runs of emergency procedures which the individual is responsible for performing
• Routine maintenance
• Lock-out procedures

Training for an RSO should include at least three months (full-time equivalent) of experience at the applicant's irradiator or at another irradiator of a similar type. The three months of experience may include preoperational involvement, such as acceptance testing, while the irradiator is being constructed.

Course Examination
Written examination designed to verify an individual's competency and understanding of the subject matter (e.g., 25 to 50 question, closed-book written test with 70% as passing grade)

Emphasis on radiation safety of irradiator operations and maintenance, licensee operating and emergency procedures that the individual will be responsible for performing, and other operations necessary to safely operate the irradiator without supervision

Training Assessment
Management will ensure that potential RSOs and authorized operators are qualified to work independently with irradiators. This must be demonstrated by written examination and by direct observations.


COMMERCIAL RADIOPHARMACY
NUREG 1556, Vol. 13, 8.7.1 Radiation Safety Officer
Criteria: Each licensee must appoint a qualified individual to act as the Radiation Safety Officer (RSO). The RSO must have adequate training and experience.
NRC requires the name, training, and experience of the proposed RSO to ensure that the applicant has identified a responsible, qualified person to oversee the radiation safety program. When selecting an RSO, the applicant should keep in mind the duties and responsibilities of the position and select an individual who is qualified and has the time and resources to fulfill those duties and responsibilities.
The RSO needs a level of basic technical knowledge sufficient to understand the work to be performed with byproduct materials at the radiopharmacy and to be qualified by training and experience to perform the duties required for that position. Any individual who has sufficient training and experience to be named as an authorized nuclear pharmacist (ANP) is also considered qualified to serve as the facility RSO. The same is true for an authorized user (AU) who has had adequate training and experience in the radiation safety aspects associated with the use of similar types of byproduct material.
The training and experience requirements for the RSO may be met by any of the following:

• Qualification as an ANP
• Identification as an AU on the license and experience in the use of the types and quantities of licensed material for which the individual has RSO responsibilities
• Didactic and work experience

In order to demonstrate adequate training and experience, the RSO should have (1) as a minimum, a college degree at the bachelor level or equivalent training and experience in physical, chemical, biological sciences, or engineering, and (2) training and experience commensurate with the scope of proposed activities. Training should include the following subjects:

• Radiation protection principles
• Characteristics of ionizing radiation
• Units of radiation dose and quantities
• Radiation detection and measurement instrumentation
• Biological hazards of exposure to radiation (appropriate to types and forms of byproduct material to be used)
• NRC regulatory requirements and standards
• Hands-on use of radioactive materials commensurate with the uses proposed by the applicant

The length of training and experience will depend upon the type, form, quantity, and proposed use of the licensed material requested. The proposed RSO's training and experience should be sufficient to identify and control the anticipated radiation hazards. The requisite training may be obtained from formal courses consisting of lectures and laboratories designed for RSOs presented by academic institutions, commercial radiation safety consulting companies, or appropriate professional organizations. Each hour of training may be counted only once and should be allocated to the most representative topic.

On-the-job training may not be counted toward the hours documenting length of training unless it was obtained as part of a formal training course. A "formal" training course is one that incorporates the following elements:

• A detailed description of the content of the course is maintained on file at the sponsoring institution and can be made available to the NRC upon request
• Evidence that the sponsoring institution has examined the student's knowledge of the course content is maintained on file at the institution and can be made available to NRC upon request. This evidence of the student's overall competency in the course material should include a final grade or percentile
• A permanent record that the student successfully completed the course is kept at the institution

MEDICAL
10 CFR 35.50 Training for a Radiation Safety Officer

Except as provided in § 35.57, the licensee shall require an individual fulfilling the responsibilities of the Radiation Safety Officer as provided in § 35.24 to be an individual who:

(a) Is certified by a specialty board whose certification process has been recognized by the Commission or an Agreement State and who meets the requirements in paragraphs (d) and (e) of this section. (The names of board certifications which have been recognized by the Commission or an Agreement State will be posted on the NRC's website.) To have its certification process recognized, a specialty board shall require all candidates for certification to:

(1) (i) Hold a bachelor's or graduate degree from an accredited college or university in physical science or engineering or biological science with a minimum of 20 college credits in physical science,

(ii) Have five or more years of professional experience in health physics (graduate training may be substituted for no more than two years of the required experience) including at least three years in applied health physics; and

(iii) Pass an examination administered by diplomates of the specialty board, which evaluates knowledge and competence in radiation physics and instrumentation, radiation protection, mathematics pertaining to the use and measurement of radioactivity, radiation biology, and radiation dosimetry; or

(2) (i) Hold a master's or doctor's degree in physics, medical physics, other physical science, engineering, or applied mathematics from an accredited college or university,

(ii) Have two years of full-time practical training and/or supervised experience in medical physics- 
    (A) Under the supervision of a medical physicist who is certified in medical physics by a specialty board recognized by the Commission or an Agreement State, or 
    (B) In clinical nuclear medicine facilities providing diagnostic and/or therapeutic services under the direction of physicians who meet the requirements for authorized users in §§ 35.290, 35.390, or, before 24 October 2005, §§ 35.920, or 35.930, and


(iii) Pass an examination, administered by diplomates of the specialty board, that assesses knowledge and competence in clinical diagnostic radiological or nuclear medicine physics and in radiation safety; or

(b)(1) Has completed a structured educational program consisting of both:

(i) 200 hours of classroom and laboratory training in the following areas:

    (A) Radiation physics and instrumentation 
    (B) Radiation protection 
    (C) Mathematics pertaining to the use and measurement of radioactivity 
    (D) Radiation biology 
    (E) Radiation dosimetry

(ii) One year of full-time radiation safety experience under the supervision of the individual identified as the Radiation Safety Officer on a Commission or Agreement State license or permit issued by a Commission master material licensee that authorizes similar type(s) of use(s) of byproduct material involving the following:

    (A) Shipping, receiving, and performing related radiation surveys 
    (B) Using and performing checks for proper operation of instruments used to determine the activity of dosages, survey meters, and instruments used to measure radionuclides 
    (C) Securing and controlling byproduct material 
    (D) Using administrative controls to avoid mistakes in the administration of byproduct material 
    (E) Using procedures to prevent or minimize radioactive contamination and using proper decontamination procedures 
    (F) Using emergency procedures to control byproduct material 
    (G) Disposing of byproduct material; or

(c)(1) Is a medical physicist who has been certified by a specialty board whose certification process has been recognized by the Commission or an Agreement State under § 35.51(a) and has experience in radiation safety for similar types of use of byproduct material for which the licensee is seeking the approval of the individual as Radiation Safety Officer and who meets the requirements in paragraphs (d) and (e) of this section; or

(2) Is an authorized user, authorized medical physicist, or authorized nuclear pharmacist identified on the licensee's license and has experience with the radiation safety aspects of similar types of use of byproduct material for which the individual has Radiation Safety Officer responsibilities; and

(d) Has obtained written attestation, signed by a preceptor Radiation Safety Officer, that the individual has satisfactorily completed the requirements in paragraph (e) and in paragraphs (a)(1)(i) and (a) (1) (ii) or (a) (2) (i) and (a) (2) (ii) or (b) (1) or (c) (1) of this section and has achieved a level of radiation safety knowledge sufficient to function independently as a Radiation Safety Officer for a medical use licensee; and

(e) Has training in the radiation safety, regulatory issues, and emergency procedures for the types of use for which a licensee seeks approval. This training requirement may be satisfied by completing training that is supervised by a Radiation Safety Officer, authorized medical physicist, authorized nuclear pharmacist, or authorized user, as appropriate, who is authorized for the type(s) of use for which the licensee is seeking approval.

NUREG 1556, Vol 9, Rev. 1 Medical Use Licensees
8.10 ITEM 7: Radiation Safety Officer (RSO)
Criteria: RSOs must have adequate training and experience. The training and experience requirements for the RSO are described in 10 CFR 35.50 or 35.900 and allow for the following training pathways:

• Certification as provided in 10 CFR 35.50(a) by a specialty board whose certification process has been recognized by the Commission or an Agreement State, plus written attestation signed by a preceptor RSO as provided in 35.50(d) and training as specified in 35.50(e); or
• Completion of classroom and laboratory training (200 hours) and one year of full-time radiation safety experience as described in 10 CFR 35.50(b)(1) plus written attestation signed by a preceptor RSO as provided in 35.50(d) and training as specified in 35.50(e); or
• Certification as provided in 10 CFR 35.50(c)(1) as a medical physicist under 35.51(a), plus written attestation signed by a preceptor RSO as provided in 35.50(d) and training as specified in 35.50(e); or
• Identification as provided in 10 CFR 35.50(c)(2) on the licensee's license as an AU, AMP, or ANP with experience in the radiation safety aspects of similar types of byproduct material use for which the individual has RSO responsibilities, plus training as specified in 35.50(e); or
• Until 24 October 2005, certification as provided in 10 CFR 35.900(a), for certifications listed in 10 CFR 35.900(a); or classroom and laboratory training and experience as specified in 10 CFR 35.900(b)(1) and one year of full-time experience as specified in 10 CFR 35.900(b)(2), or identification as an authorized user on the licensee's license as specified in 10 CFR 35.900(c).
• The licensee must also establish, in writing, the authority, duties, and responsibilities of the RSO as required by 10 CFR 35.24(b).

INDUSTRIAL RADIOGRAPHY
10 CFR 34.42 Radiation Safety Officer for Industrial Radiography.

The RSO shall ensure that radiation safety activities are being performed in accordance with approved procedures and regulatory requirements in the daily operation of the licensee's program.
(a) The minimum qualifications, training, and experience for RSOs for industrial radiography are as follows:

(1) Completion of the training and testing requirements of §34.43(a);

(2) 2,000 hours of hands-on experience as a qualified radiographer in industrial radiographic operations; and

(3) Formal training in the establishment and maintenance of a radiation protection program.

(b) The Commission will consider alternatives when the RSO has appropriate training and/or experience in the field of ionizing radiation and, in addition, has adequate formal training with respect to the establishment and maintenance of a radiation safety protection program.

10 CFR 34.43 Training for RSO for Industrial Radiography

(a) The licensee may not permit any individual to act as a radiographer until the individual:

(1) Has received training in the subjects in paragraph (g) of this section, in addition to a minimum of two months of on-the-job training, and is certified through a radiographer certification program by a certifying entity in accordance with the criteria specified in appendix A of this part. (An independent organization that would like to be recognized as a certifying entity shall submit its request to the Director, Office of Nuclear Material Safety and Safeguards, by an appropriate method listed in § 30.6(a) of this chapter.) or

(2) The licensee may, until 27 June 1999, allow an individual who has not met the requirements of paragraph (a)(1) of this section to act as a radiographer after the individual has received training in the subjects outlined in paragraph (g) of this section and demonstrated an understanding of these subjects by successful completion of a written examination that was previously submitted to and approved by the Commission.

(g) The licensee shall include the following subjects required in paragraph (a) of this section:

(1) Fundamentals of radiation safety including:
    (i) Characteristics of gamma radiation
    (ii) Units of radiation dose and quantity of radioactivity
    (iii) Hazards of exposure to radiation
    (iv) Levels of radiation from licensed material
    (v) Methods of controlling radiation dose (time, distance, and shielding)

(2) Radiation detection instruments including:
    (i) Use, operation, calibration, and limitations of radiation survey instruments
    (ii) Survey techniques
    (iii) Use of personnel monitoring equipment

(3) Equipment to be used including:
    (i) Operation and control of radiographic exposure equipment, remote handling equipment, and storage containers, including pictures or models of source assemblies (pigtails)
    (ii) Storage, control, and disposal of licensed material
    (iii) Inspection and maintenance of equipment

(4) The requirements of pertinent federal regulations

(5) Case histories of accidents in radiography

NUREG 1556, Vol. 2, 8.7.1 Radiation Safety Officer for Industrial Radiography
Criteria: RSOs and potential designees responsible for ensuring that the licensee's radiation safety program is implemented in accordance with approved procedures must have adequate training and experience.

To be considered eligible for the RSO position, an individual must be a qualified radiographer, have a minimum of 2,000 hours (one year full-time field experience) of hands-on experience as a qualified radiographer, and have formal training in establishing and maintaining a radiation protection program. This should be a course specifically designed to provide training in running a radiation safety program; a basic radiation safety course is not acceptable. While a course particular to industrial radiography would be highly encouraged, this is not required. Acceptable training programs would be a classroom course typical of those provided through universities or commercial training facilities. Hands-on experience means experience in all areas considered to be directly involved in the radiography process. This includes taking radiographs, surveying device and radiation areas, transporting the radiography equipment to temporary job sites, posting, work sites, radiation-area surveillance, completing and maintaining records, etc. Excessive time spent in only one or two of these operations (film development and/or area surveillance) should not be counted toward the 2,000 hours. Experience with radiography using x rays can be included; however, the majority of experience should be in isotope radiography.

Note: The NRC will consider individuals with alternative training and experience as RSOs. For example, a person certified in health physics or industrial hygiene with previous experience in managing a radiation safety program of comparable size and scope could be considered as an individual case. The qualifications, training, and experience required of the RSO may vary depending upon the complexity of the applicant's operations and number of radiography personnel.

                                                      

* 35.57  Training for Experienced RSO: (a)(1) An individual identified as a Radiation Safety Officer, a teletherapy or medical physicist, or a nuclear pharmacist on a Commission or Agreement State license or a permit issued by a Commission or Agreement State broad-scope licensee or master material license permit or by a master material license permittee of broad scope before 24 October 2002, need not comply with the training requirements of §§ 35.50, 35.51, or 35.55, respectively.
(2) An individual identified as a Radiation Safety Officer, an authorized medical physicist, or an authorized nuclear pharmacist on a Commission or Agreement State license or a permit issued by a Commission or Agreement State broad-scope licensee or master material license permit or by a master material license permittee of broad scope between 24 October 2002 and 29 April 2005 need not comply with the training requirements of §§ 35.50, 35.51, or 35.55, respectively.