Radiation Safety Training Manual: Administrative Issues

The State of California Department of Health Services is granted regulatory authority by the Nuclear Regulatory Commission to oversee the acquisition and use of radioactive materials and radiation producing machines within the state. The Dept. of Health Services considers for approval applications for radioactive materials licenses, performs inspections of licensee facilities, and issues citations for points of non-conformance.

SDSU has been granted a Broad Scope Type A Radioactive Materials License which offers the highest degree of latitude in the administration of the radiation safety program. The Broad Scope Type A License allows the licensee to propose their own methods to manage radiation related issues as determined by a Radiation Safety Committee (RSC).

The SDSU Radiation Safety Committee creates policy and regulates the acquisition and use of radioactive materials and radiation producing machines within the terms of the license.

Persons petitioning to use ionizing radiation at SDSU must submit an application for a Radiation Use Authorization (RUA). The application describes to the Radiation Safety Committee the isotopes and quantity of radioactive materials required for a specific project. If approved, the RUA limits users to the type and quantity of radioactive material requested and where the material may be used. The Principal Investigator (PI) is required to respond to periodic written correspondence from the Radiation Safety Officer in order to keep the RUA active. The RUA also directs the PI to adhere to specific responsibilities as required by the committee. In the event the PI terminates their service to the university or the RUA is to be terminated for any reason, the RSO is to receive advance notification in order to perform a decommissioning survey.

The Radiation Safety Officer (RSO) is responsible to ensure safe working conditions regarding the use of ionizing radiation. The RSO is also required to make sure all license conditions are followed and to enforce policy in accordance with directives from the RSC. The ultimate goal is to protect radiation related research by maintaining the integrity of the license and addressing radiation related safety issues. The RSO is empowered to immediately revoke any Radiation Use Authorization and confiscate all radioactive materials if there is evidence of gross negligence by laboratory personnel.

The Principal Investigators (PI) are ultimately responsible for all safety issues within the laboratory. They are responsible for performing corrective action to resolve problems noted by the Radiation Safety Officer or the Radiation Safety Committee. By signing the Radiation Use Authorization, the PI agrees to comply with the radiation safety manual and any special provision noted on the RUA. The PI is required to respond to periodic written correspondence from the Radiation Safety Officer in order to keep the RUA active and to notify the RSO in advance if the RUA is to be terminated. In the event the PI is away for an extended absence such as a sabbatical they must designate an interim PI with the authority to make decisions for them in their absence.

Approval to become a radiation worker results from the recommendation of the PI and completion of training in basic radiation safety administered by the RSO at SDSU. Radiation workers are expected to conduct themselves in a professional manner and to keep their exposure to radiation as low as reasonably achievable (ALARA). They are obligated to report radiation safety concerns to their direct supervisor or the RSO. While using radioactive materials, radiation workers are required to follow the directives in the Radiation Use Authorization and the Radiation Safety Manual.

All radioactive materials obtained under a Radiation Use Authorization or under authority of the Radioactive Materials License must be locked or secured from unauthorized removal at all times. The laboratory environment where radioactive materials are stored or permitted for use is called the “controlled area.” Usually the presence of a radiation worker in the controlled area who can prevent the unauthorized removal of radioactive material is sufficient security.

External: Monitoring devices for assessing a person’s external occupational dose from ionizing radiation are called dosimeters. They are provided at the discretion of the RSO or if the likelihood exists that a radiation worker could receive 10‰ of the prescribed occupational limits. They are issued only for projects approved by the SDSU Radiation Safety Committee. Dosimetry records are permanent legal records, therefore it is advisable to wear the dosimetry continuously while in the working environment, not only during radioactive procedures. Under no circumstances should you wear another persons dosimeter. If a dosimeter is lost or damaged, advise the Radiation Safety Officer so a replacement dosimeter can be provided before work resumes. When not in use, please keep your dosimetry in a central location to expedite quarterly replacements. Personnel may receive a copy of their dosimetry records upon written request. Currently SDSU uses thermoluminescent dosimeters (TLDs) to assess external dose. For persons who have been issued extremity dosimeters (finger rings), it is important to remember to wear the ring inside the disposable gloves.
Internal Dose: To evaluate dose resulting from an intake of radioactive material, the amount of material and the approximate time of the intake must be considered. A bioassay must be done to measure the quantity of radioactive material taken up by the body. Depending on the radioisotope and mode of intake (e.g., inhalation vs. ingestion), the amount of activity determined from bioassay data is directly proportional to the dose received by particular organs or to the entire body. Types of bioassays which may be performed are whole body counting, thyroid counting or urine bioassays.

Female radiation workers who are pregnant have the option to inform the RSO of their pregnancy. If a worker declares her pregnancy in writing, the RSO is required to evaluate work practices and make reasonable recommendations in accordance with ALARA. In some instances a fetal dosimeter is issued and replaced on a monthly basis. The dose limit for the fetus from occupational sources is 500 mrem (one-tenth of the permissible dose to the mother) over the 9 months gestation period. The declaration of pregnancy is confidential.

All radioactive materials, with the exception of smoke detectors and self luminous signs shall be received through the Department of Environmental Health and Safety. EH&S is required to inspect all radioactive material shipped to university property as specified in SDSU’s radioactive materials license. The packages are checked for physical integrity, emergent exposure rate, surface contamination and compliance with shipping regulations and intended use. A record of the receipt will be made and the package will be distributed to the authorized user. In the event a package containing radioactive material is distributed directly to the lab from a courier, please notify EH&S promptly in order to comply with the required inspection.

The regulations for shipping radioactive material are, at best, confusing. Please notify EH&S in the event you intend to ship radioactive material. Proper documentation, labeling, and packaging is important to avoid regulatory problems. Prior to shipping, a copy of the recipient’s radioactive materials license must be obtained. Advance notice should be considered when intending to ship radioactive material. The term radioactive material applies not only to radioactive solutions or samples but also to items which may be inadvertently contaminated such as refrigerators or centrifuges. Any item which leaves the campus property is considered shipping.


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	Environmental Health and Safety Radiation Safety Training Manual Administrative Issues 1. Regulatory Authority The State of California Department of Health Services is granted regulatory authority by the Nuclear Regulatory Commission to oversee the acquisition and use of radioactive materials and radiation producing machines within the state. The Dept. of Health Services considers for approval applications for radioactive materials licenses, performs inspections of licensee facilities, and issues citations for points of non-conformance. 2. Radioactive Materials License SDSU has been granted a Broad Scope Type A Radioactive Materials License which offers the highest degree of latitude in the administration of the radiation safety program. The Broad Scope Type A License allows the licensee to propose their own methods to manage radiation related issues as determined by a Radiation Safety Committee (RSC). 3. Radiation Safety Committee The SDSU Radiation Safety Committee creates policy and regulates the acquisition and use of radioactive materials and radiation producing machines within the terms of the license. 4. Radiation Use Authorization Persons petitioning to use ionizing radiation at SDSU must submit an application for a Radiation Use Authorization (RUA). The application describes to the Radiation Safety Committee the isotopes and quantity of radioactive materials required for a specific project. If approved, the RUA limits users to the type and quantity of radioactive material requested and where the material may be used. The Principal Investigator (PI) is required to respond to periodic written correspondence from the Radiation Safety Officer in order to keep the RUA active. The RUA also directs the PI to adhere to specific responsibilities as required by the committee. In the event the PI terminates their service to the university or the RUA is to be terminated for any reason, the RSO is to receive advance notification in order to perform a decommissioning survey. 5. Radiation Safety Officer The Radiation Safety Officer (RSO) is responsible to ensure safe working conditions regarding the use of ionizing radiation. The RSO is also required to make sure all license conditions are followed and to enforce policy in accordance with directives from the RSC. The ultimate goal is to protect radiation related research by maintaining the integrity of the license and addressing radiation related safety issues. The RSO is empowered to immediately revoke any Radiation Use Authorization and confiscate all radioactive materials if there is evidence of gross negligence by laboratory personnel. 6. Principal Investigator The Principal Investigators (PI) are ultimately responsible for all safety issues within the laboratory. They are responsible for performing corrective action to resolve problems noted by the Radiation Safety Officer or the Radiation Safety Committee. By signing the Radiation Use Authorization, the PI agrees to comply with the radiation safety manual and any special provision noted on the RUA. The PI is required to respond to periodic written correspondence from the Radiation Safety Officer in order to keep the RUA active and to notify the RSO in advance if the RUA is to be terminated. In the event the PI is away for an extended absence such as a sabbatical they must designate an interim PI with the authority to make decisions for them in their absence. 7. Radiation Workers Approval to become a radiation worker results from the recommendation of the PI and completion of training in basic radiation safety administered by the RSO at SDSU. Radiation workers are expected to conduct themselves in a professional manner and to keep their exposure to radiation as low as reasonably achievable (ALARA). They are obligated to report radiation safety concerns to their direct supervisor or the RSO. While using radioactive materials, radiation workers are required to follow the directives in the Radiation Use Authorization and the Radiation Safety Manual. 8. Security All radioactive materials obtained under a Radiation Use Authorization or under authority of the Radioactive Materials License must be locked or secured from unauthorized removal at all times. The laboratory environment where radioactive materials are stored or permitted for use is called the “controlled area.” Usually the presence of a radiation worker in the controlled area who can prevent the unauthorized removal of radioactive material is sufficient security. 9. Dosimetry External Monitoring devices for assessing a person’s external occupational dose from ionizing radiation are called dosimeters. They are provided at the discretion of the RSO or if the likelihood exists that a radiation worker could receive 10‰ of the prescribed occupational limits. They are issued only for projects approved by the SDSU Radiation Safety Committee. Dosimetry records are permanent legal records, therefore it is advisable to wear the dosimetry continuously while in the working environment, not only during radioactive procedures. Under no circumstances should you wear another persons dosimeter. If a dosimeter is lost or damaged, advise the Radiation Safety Officer so a replacement dosimeter can be provided before work resumes. When not in use, please keep your dosimetry in a central location to expedite quarterly replacements. Personnel may receive a copy of their dosimetry records upon written request. Currently SDSU uses thermoluminescent dosimeters (TLDs) to assess external dose. For persons who have been issued extremity dosimeters (finger rings), it is important to remember to wear the ring inside the disposable gloves. Internal Dose To evaluate dose resulting from an intake of radioactive material, the amount of material and the approximate time of the intake must be considered. A bioassay must be done to measure the quantity of radioactive material taken up by the body. Depending on the radioisotope and mode of intake (e.g., inhalation vs. ingestion), the amount of activity determined from bioassay data is directly proportional to the dose received by particular organs or to the entire body. Types of bioassays which may be performed are whole body counting, thyroid counting or urine bioassays. 10. Pregnancy Female radiation workers who are pregnant have the option to inform the RSO of their pregnancy. If a worker declares her pregnancy in writing, the RSO is required to evaluate work practices and make reasonable recommendations in accordance with ALARA. In some instances a fetal dosimeter is issued and replaced on a monthly basis. The dose limit for the fetus from occupational sources is 500 mrem (one-tenth of the permissible dose to the mother) over the 9 months gestation period. The declaration of pregnancy is confidential. 11. Shipping and Receiving All radioactive materials, with the exception of smoke detectors and self luminous signs shall be received through the Department of Environmental Health and Safety. EH&S is required to inspect all radioactive material shipped to university property as specified in SDSU’s radioactive materials license. The packages are checked for physical integrity, emergent exposure rate, surface contamination and compliance with shipping regulations and intended use. A record of the receipt will be made and the package will be distributed to the authorized user. In the event a package containing radioactive material is distributed directly to the lab from a courier, please notify EH&S promptly in order to comply with the required inspection. The regulations for shipping radioactive material are, at best, confusing. Please notify EH&S in the event you intend to ship radioactive material. Proper documentation, labeling, and packaging is important to avoid regulatory problems. Prior to shipping, a copy of the recipient’s radioactive materials license must be obtained. Advance notice should be considered when intending to ship radioactive material. The term radioactive material applies not only to radioactive solutions or samples but also to items which may be inadvertently contaminated such as refrigerators or centrifuges. Any item which leaves the campus property is considered shipping.
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