Answer to Question #4205 Submitted to "Ask the Experts"

Senior management of my hospital says it is a trend for the safety officer of the hospital to also assume the duties of the radiation safety officer. Is this a trend that you are finding? I can't believe there would be a person with the education and qualifications for both or who would want the responsibilities of both. Can you tell me your experience in this matter? Do you find this a recommended practice?

Great question—a tough one to answer, though.  Depending on the organization's criteria for the two positions, safety officer (SO) and radiation safety officer (RSO), someone could meet the qualifications of both.  Some organizations may not require certification or much experience for either, then the person needs only to meet the Nuclear Regulatory Commission (NRC) or Agreement State requirements for an RSO.  If it is a small academic organization, then all one needs is 40 hours of training and experience with radioactive materials.  So, someone's "ability" to do both jobs is based on one's qualifications, regulatory requirements, and the organization's criteria.

I am not aware that anyone has investigated whether there is a "trend" that SOs also take on RSO duties or, vice versa, that RSOs take on SO duties.  I am familiar with a few organizations (large academic/medical sites) where the RSO has become the safety director.  In these cases, individuals reporting to the RSO/safety director had the necessary safety credentials (for example, certified safety professional, certified industrial hygienist).

Is it recommended?  If the organization is smaller and/or with fewer uses of radiation, it is probably doable.  When the organization gets larger, and depending on safety program staffing levels, it would seem that one or the other (general safety or radiation safety) might suffer and put the organization at higher risk for regulatory citation or, worse yet, a serious employee injury.

I know this information doesn't give you a bottom-line answer to your question, but I don't believe anyone has ever investigated the topic in any detail.  I would encourage you, at some point, to pursue it further and publish the information.  It would be interesting to know if those individuals who have assumed both duties feel they can do so without diluting their attention.

Kelly Classic
Certified Medical Health Physicist

Editor's Note:  You might find the following two documents of interest:

1. The American Academy of Health Physics and the Medical Health Physics Section of the Health Physics Society, SQ/P-002 Standards of Qualification and Practice (SQ/P) "Qualifications for Healthcare Facility Radiation Safety Officer."
    
2. An excerpt from Nuclear Regulatory Commission regulations on Radiation Safety Officer Requirements.