Answer to Question #12958 Submitted to "Ask the Experts"
The following question was answered by an expert in the appropriate field:
I work for a large contractor on a multibillion-dollar project. In the course of our work we subcontract radiography to several companies. They are using iridium-192 (192Ir) for inspection of pipe welds. Each of these companies has a radiation safety officer (RS0). There is a requirement for the subcontractor to have an RSO. As the prime contractor, we do not ourselves do this work or have a radioactive material license to utilize or perform the non-destructive testing done by radiography. Is there a requirement for a company to have an RSO for oversight of a subcontractor's radiography?
The simple answer is no. Your company is not required and should not have an RSO for oversight of a separate company with their own RSO for several reasons. Radiography uses a highly active radioactive source, that if used improperly can cause very serious health effects and even death. Even to become a radiographer, training takes at least 40 hours of classroom studies and passing a written test, usually given by the state/country regulatory agency. Then the next step to qualify to be a certified radiographer takes years of experience under a qualified radiographer trainer. The RSO is identified on the regulatory agency's license; and the RSO in most cases is a qualified radiographer trainer with many years of experience conducting radiography safely. So, to be identified on an agency-issued Radioactive Material License your RSO candidate would need to describe all pertinent training and experience in the use of radiography sources to be granted the position of a Licensed RSO. Additionally, it is not a good idea to be a Licensed RSO because that carries great personal and corporate legal and liability responsibilities.
You can, as the prime contractor, ask the radiography company to provide documentation of radiographer's training and agency-issued certifications, the agency-issued license, and the company's safety procedures for your review. You can also perform onsite inspections during the radiography to assure that the radiography company is providing proper barriers and warning signs, operable radiation detectors, personnel dosimeters, etc.
John P. Hageman, CHP