Answer to Question #1445 Submitted to "Ask the Experts"

Q

Could you please send me a summary of the required elements of a Radiation Safety Program and the responsibilities of a Radiation Safety Officer? Also, how do requirements between the OSHA and NRC regulations differ? Thanks.

A

Administrative Aspects of a Health Physics Program—The "required" elements of a Radiation Safety Program are typically agreed to in a facility's radioactive materials license and/or are required by federal or state regulations (depending on the jurisdiction). The extent and content of these elements vary by type of license and scope of use of radioactive materials (this also applies for radiation-producing equipment). There are numerous references that contain recommended elements of a Health Physics Program. These include a text published as the Health Physics Society's 1998 Summer School proceedings (Management and Administration of Radiation Safety Programs) and various U.S. Nuclear Regulatory Commission NUREG documents regarding licensing (NUREG-1556 series—"Consolidated Guidance About Materials Licenses") and program management (NUREG-1516—"Management of Radioactive Material Safety Programs at Medical Facilities"). All of these documents offer various aspects, elements, and approaches to structuring a Radiation Safety Program. As a general summary, the following was taken from class notes from a graduate-level health physics course:

 

1. Management
   • Train and work with employees
   • Must work with users in an effective, yet helpful and amiable, fashion
   • Must be a recognized chain of command, as direct as possible up to the chief administrative officer of the institution
     • Need line authority to shut down unsafe practices as necessary
     • Need Radiation Safety Committee to advise Radiation Safety Officer
   • Establish budget and budget justification
      
2. Measurements
   • Calibration of sources and detection systems
   • Monitoring criteria, etc.
      
3. Record Keeping
   • Personnel exposure histories
   • Lab surveys, incoming radioisotope shipments, encapsulated sources, waste drums, etc.
   • Leak tests
   • Instrumentation calibrations (source calibrations)
   • License applications, maintenance, renewal
   • Orders Waste and waste storage, shipment
   • Develop more efficient means of data storage and retrieval
   • Repetitive review of protocols by Radioisotope or Radiation Safety Committee
   • Bioassays, air sampling
      
4. Training and Information
   • Offer lectures/courses for radioisotope users
   • Responsibility to present radiation safety to general public
   • Prepare and update a Radiation Safety Manual
      
5. Enforcement
   • Action when personnel exposures exceed ALARA trigger levels
   • Action if surveys are in excess of action levels (sealed sources, removable contamination, nonremovable contamination, ambient dose rate)
   • Action if procedures used are contrary to ALARA practice

(taken from class notes by Ralph Christensen, PhD, "Radiation Hazards and Protection—HRS545," University of Kentucky, 4/17/89) The above list may be modified based on the scope of the intended program. Some smaller programs, for example, do not require or need a Radiation Safety Committee. Responsibilities of a Radiation Safety Officer (RSO) In general, the RSO is responsible for implementing the day-to-day aspects of the Radiation Safety Program. Many of the licensing categories do not have specific rules regarding responsibilities of the RSO. Two categories that do, however, are Medical Use and Industrial Radiography. For medical use, the RSO responsibilities are specific:

1. Investigate overexposures, accidents, spills, losses, thefts, unauthorized receipts, uses, transfers, disposals, misadministrations, and other deviations from approved radiation safety practice and implement corrective actions as necessary.
    
2. Establish . . . and implement written policy and procedures for:
   • Authorizing the purchase of byproduct material
   • Receiving and opening package
   • Storing byproduct material
   • Keeping an inventory record of byproduct material
   • Using byproduct material safely
   • Taking emergency action if control of byproduct material is lost
   • Performing periodic radiation surveys
   • Performing checks of survey instruments and other safety equipment
   • Disposing of byproduct material
   • Training personnel who work in or frequent areas where byproduct material is used or stored
   • Keeping a copy of all records and reports, regulations, licenses, amendments, and written policies and procedures
      
3. Brief management once each year on the byproduct material program.
    
4. Establish personnel exposure investigational levels and investigate cause of exposure when these levels are exceeded.
    
5. Establish personnel exposure investigational levels and perform prompt investigation of cause and consideration of actions to be taken when these levels are exceeded to reduce the probability of recurrence.
    
6. For medical use not at a medical institution, approve/disapprove minor changes in radiation safety procedures.
    
7. For medical use at a medical institution, assist the Radiation Safety Committee in the performance of its duties.

(taken from 10 CFR 35 "Medical Use of Byproduct Material") Note that the above items can also pertain to naturally occurring or accelerator-produced radioactive materials and/or radiation-producing machines. Although this list is medical specific, it can be adapted to other specialties and modified as needed as to the scope of the program. Difference between OSHA and NRC requirements The main rule regulating radiation in the OSHA rules is 29 CFR 1910.1096. In this rule there are dose limits, requirements for training individuals in restricted areas, etc., much like 10 CFR 20. In general, the OSHA rule is provided in the case that an individual in a workplace does not fall under regulations provided by NRC or an equivalent Agreement State.

Ken (Duke) Lovins, MS, CHP