Conducting Radiation Safety Audits and Inspections

Good day, Dr. Zoomie! So I just got an RSO job for a small lab and I saw that I need to do audits and inspections. I’m not quite sure what that means or what I ought to be doing – can you give me some suggestions? And, for that matter, do I really need to audit and inspect my program? There aren’t many radiation workers and they all seem pretty careful.

You know, I spent a lot of time thinking along these lines when I was in the Navy as well as during various stints as RSO. In the Navy, for example, we’d have annual inspections to check our operational readiness, how well we managed the reactor and propulsion plants, our tactical expertise, and much more. Let’s face it – not only were we highly trained with years of experience at our jobs, but our officers and chiefs ran (literally) a pretty tight ship – what of significance could some outsiders find in a few days? And, of course, we knew the dates of our various inspections months in advance, giving us time to practice and to go over our paperwork, clean the sub from top to bottom, and more – how could our score on such an inspection reflect how well we worked day-to-day?

What occurred to me is that, to some extent, they don’t…but that’s OK. At the very least, an annual inspection forced us to be at our best – operationally and administratively – and keeping us from backsliding too far if we were so inclined. Not to mention that even an outsider who’s only present for a brief time can make constructive comments, find mistakes, and suggest better work practices; what I’d neglected to consider is that the folks who inspected us…well, they inspected a lot of submarines and they’d seen a lot more than just the one sub I worked on.

So let’s bring this to your facility. Your regulators will inspect your program from time to time, keeping you on your toes, forcing you to keep your paperwork and other aspects of your radiation safety program up to snuff, and offering (one can hope) constructive suggestions and criticisms as well as looking at your program with an expert and experienced eye. And the same with your internal inspections, helping to keep your radiation workers, researchers, and lab staff on track. Inspections are a pain in the neck, but they’re a necessary pain in the neck as, if everyone knows that nobody is ever going to check on them, there’s a tendency for even the most conscientious to put off (or to let slide) boring or onerous chores. And to keep yourself honest, you should also be auditing yourself every so often – going through your own paperwork and making sure you haven’t overlooked or missed anything. And I know that sounds a bit vague, so lets talk about how all of that works.

Let’s start with auditing your program – I gave a high-level view of this in an earlier post; here are some details about some of the areas you’ll need to look at. It’s not very exciting, admittedly, but it needs to be done.

Every year you need to take a close look at your radiation safety program, which is mostly going through your paperwork to make sure that everything is in order, that you’re meeting all of your regulatory requirements, that you can account for all of your radioactive sources, and so forth. Let’s go through these one at a time.

Radioactive sources

Regulations require that you inventory your radioactive materials at least twice annually. For your sealed radioactive sources this means going through your list of sealed sources, and finding every one of them. Most of the time this will mean opening your source storage safe or drawer and checking the sources one by one – confirming the nuclide and activity as well as the source serial number, initialing next to each source to record your inventory. In some cases you won’t be able to look at the source itself – or you might not want to do so. At my current job we have a few devices that contain radioactive sources, but my license doesn’t permit me to disassemble the device to inventory the source (not to mention that would invalidate our warranty). For this one, since the device won’t work properly if the source is missing, I just turn it on to confirm it’s working. For another, I can survey next to the source compartment to confirm the dose rate is elevated (which wouldn’t be the case if the source were missing).

If you’ve got unsealed sources (which often happens at research facilities) then it’s a little more complex as you need to account for the radioactivity that arrives at your facility, the amount removed to mix with experiments, what was disposed of, and what’s still in the researchers’’ refrigerators, freezers, and in storage. Also, since many research nuclides are relatively short-lived, don’t forget to account for their decay!

The other thing you’ll need to do twice a year is to make sure your sources aren’t leaking – at least, for the alpha-emitting sources with more than 10 µCi and beta-gamma sources with more than 100 µCi of activity. For this, just wipe the source with a piece of filter paper (I usually just use a 1” piece of filter paper or a cotton-tipped applicator) and put it in a small envelope that I mark with the source serial number. In my case, I have a wipe counter I can use to see if the wipe picked up any radioactivity; if you don’t have that option, there are a lot of companies you can mail the wipes to and who will count them for you. Another option is to see if there’s a nearby research university who offers this service – when I was a university RSO we’d do this for local businesses for a nominal fee. Record the results (I record them on the same sheet as the inventory) and, as long as no wipe reads more than 185 Bq (11,100 dpm), then Bob’s your uncle!

Instruments and surveys

This one’s pretty simple – you just need to make sure that all of your instruments are calibrated annually (and that you have the calibration certificates) and that you’ve been performing radiation and contamination surveys periodically. Most of the time a semi-annual radiation survey will suffice, and contamination surveys should be performed as necessary. If you’re not using unsealed sources then you don’t really need to do the contamination surveys unless you find a leaking source. If you are using unsealed sources then a monthly contamination survey is a good idea; weekly if you’re using isotope more than a few times a week. Make sure you record your survey results on a survey map, initial or sign it, and jot down the date as well.

Inspections

I’ll go over how to do inspections below – your audit should simply make sure that you’re performing inspections as required by your license conditions or your internal policies; usually this will be quarterly or semi-annually. Here, again, you’ll need to make sure you sign or initial the inspection report and include the date.

Dosimetry

You’re required to give dosimeters to any radiation worker who has a reasonable expectation of exceeding 10% of a dose limit. In practice, this usually includes anybody who works with millicurie quantities of gamma and/or high-energy beta emitters, but you can differ from this as long as your regulators agree. Whatever you do, you’ll need to make sure that dosimeters are exchanged and read with the requisite periodicity (usually monthly or quarterly) and – most importantly – make sure that nobody has exceeded a dose limit.

Transportation and Shipping

And then we get to transporting and shipping radioactive materials, including any radioactive waste you send for disposal. If you’re not transporting or shipping radioactive materials then this one is going to be easy for you; if you are then you’ve got a little work. Earlier posts have discussed labeling packages for shipping, receiving packages, packaging and transporting radioactive materials, so no need to go into that here. What you need to do for your annual audit is to make sure that, for whatever packages you received, packaged, and shipped (or transported in your own vehicles) – make sure that you have the shipping papers, that they’re properly filled out (and, of course, signed and dated!), and that you performed and recorded all of the required radiation surveys.

So that’s the audits – now a quick bit about inspections!

The reason for performing your own inspections is to make sure your radiation workers are following your procedures and policies and that they’re doing their work properly. The most important thing about inspections is that they be fair and consistent. With a large license I ensured both of these by developing an inspection checklist (that I shared with the radiation workers and researchers), and by inspecting against that checklist. What you put on your own checklist will depend on the sort of work that’s going on – laboratory research, manufacturing, analyzing medical samples, and so forth.

Some things to consider looking at are:

• Administrative
  • Are rooms marked and posted properly?
  • Are records available, complete, and filled out properly?
• Radioactive materials
  • Are all isotopes authorized for use?
  • Is inventory up to date (including correcting for radioactive decay)?
• Radiological surveys
  • Are surveys performed as required? Are any surveys missing?
  • Are survey instruments calibrated?
  • Are survey instruments appropriate for the nuclides being used?
  • Do surveys include all work areas as well as random locations?
• Training records
  • Are there training certificates for all radiation workers?
  • Are all workers’ refresher training up to date?
• Laboratory safety and radiological work practices
  • Are personnel wearing their dosimeters?
  • Do personnel wear appropriate PPE (e.g. gloves, lab coat, etc)?
  • Is there evidence of eating, drinking, or food storage in posted rooms?
  • Are all radioactive materials secured or in use?
  • Is contaminated equipment properly labeled and stored?
  • Did any locations have more than 200 dpm/100 cm² of loose surface contamination when smear wiped by the inspector?
  • Did any locations have a dose rate higher than 0.2 mR/hr in an accessible area when surveyed by the inspector?
• Radioactive waste
  • Are any containers overly full?
  • Is there an inventory record for each waste container?
  • Is waste segregated and marked (incinerable/non-incinerable, biohazard, mixed waste, sharps, etc)?
  • Is liquid waste segregated (aqueous/organic, mixed waste, specific chemical hazards)?
  • Is there secondary containment for liquid wastes?
• Level of knowledge
  • Did any personnel receive less than 70% on verbal examination?
    • Verbal exam might include, say, 10 questions from a question bank of 20, covering basic radiation safety information and specific questions about radioactive materials used in each individual work area. Some possible questions are:
      • Who is the Radiation Safety Officer?
      • Who regulates our radiation safety program?
      • Who do you contact if there is a rad accident after hours?
      • What isotopes are used in your work area and what kind of radiation do they emit?
      • What instruments do you use to survey for the isotopes used in your work area?
      • What actions do you take in the event of a radioactive spill?
      • What is your annual dose limit?
      • What is the maximum allowed level of contamination?
      • What do you do if you get radioactive liquid on your skin?
      • How often should your radiation instruments be calibrated?

Documentation:

A big part of your audit deals with paperwork, and a big part of your regulatory inspections (and the inspections you perform) will be about the paperwork as well. But you need to generate your share of paperwork by documenting your audits and inspections – if it’s not written down somewhere then you can’t prove that the work was done, nor that the requirement was met.