Starting Your Academic Radiation Safety Program: A Guide
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Starting Your Academic Radiation Safety Program: A Guide

By Dr. Zoomie

Hi, Dr. Zoomie – got a question for you. The college I work at wants to start using radioactivity for research – I’m just a tech, but I’ve got some previous experience doing “hot” work and I guess I ran the slowest when they were looking for radiation safety officers. I have to start with writing a license application – any tips?

First – my sympathies…and congratulations? I was a university RSO for a while and worked in Radiation Safety at another. Being RSO can be a bit on the thankless side; on the other hand, there can be a bit of satisfaction in getting a new program off the ground. There are a lot of things to keep in mind when you’re running your radiation safety program – but you’ve got to have a radiation safety program to run first. So let’s see if we can help you to get a license – when you’re there, let me know and we can go through some tips on managing an academic radiation safety program.

The first thing you need to do is to talk with your boss and with whoever thought you should be the RSO. Writing the license application, getting the required training, and getting the program off the ground are going to take up a lot of your time and you’re going to need your boss and your school to understand this. In addition, you’re going to need a budget as well as someone to report to in your role as RSO – ideally, someone who gets a bit of respect among those who will be using radioactivity. As RSO, you’re not very high up in the administrative food chain – that’s OK, as long as you report to someone reasonably high up in your role as RSO. Finally, if there are going to be a lot of people using radioactivity or radiation – especially if they’re in many departments – you might need to put together a Radiation Safety Committee. These are all things that you ought to work out before you get your license.

And then you get to the license thing.

Putting together a radioactive materials license application, even for a fairly simple license, is not a simple matter. You might want to hire a consultant to help you out…or to do the whole thing yourself. Hiring a consultant will make things easiest for you – but it’s also the most expensive option. If you decide to do it yourself, you’ll save some money – best of all, you will know what’s in your license application better than anyone; that’s important because your license application is, effectively, a promise you make to your regulators if only they will grace you with permission to buy and use radioactive materials. The better you understand the commitments you make to the regulators, the better you’ll be able to remain compliant with your license.

One thing you’ll need to find out is who your regulator is. Nationwide, the Nuclear Regulatory Commission (NRC) is responsible for regulating radioactive materials, but there are 39 states that have signed an agreement with the NRC that permits the state to be the regulatory authority within their borders – if you live in one of these Agreement States then your regulator is one of your state agencies (usually the state health or environmental department). Otherwise, you’ll need to submit your license application to the correct NRC regional office. And there’s one more possibility – there are a couple of large cities that regulate radiation safety – if you’re in NYC for example, the NYC Department of Health and Mental Hygiene will be your regulator if you’re a medical, government, or academic institution. On the other hand, if you live in the State of New York and you’re not in NYC (or if you work for a company) then you’re regulated by the NY State Department of Health.

Once you figure out who’s regulating you, go to their website. There are two things you’re looking for – the license application form and guidance on how to fill it out. And from here on out I will be talking about and linking to the NRC website because, even in an Agreement State, the regulations have to be compatible with the NRC requirements. So most of the time, if you’re compliant with NRC requirements you’re going to be compliant with your state. That being said – if you’re in an Agreement State, use your state documents! Anyhow….

Most of the blocks on the license application are pretty easy to fill in – we’ll assume that you know your own name, the address of your university, and so forth. But there are a few parts that can be tough, so let’s talk about those.

First – no matter what your boss thinks, you’re not the RSO until your regulators say that you are – one part of your license application will be a summary of your qualifications to be the RSO and, if your regulators agree, then you will be named the RSO on the license, once it’s issued. NUREG 1556 (or the state equivalent) includes a list of recommended qualifications to be the RSO for a large number of licenses – for a small academic license you’ll likely want to look at Volume 7 (or your state equivalent). The requirements to be approved as an RSO will include experience using radioactive materials, education, will likely require you to take a 40-hour RSO training class, and more. You’ll need to make sure you meet these requirements (including taking an RSO course) and include documentation of this with your license application. And remember – a NUREG document is a guidance document – if you don’t meet all of the requirements, the regulators might still approve you to be an RSO as long as you can explain to them how you’ll make up that “deficit” or why you’re qualified in spite of it.

More importantly, one part of the license application will ask you to describe your radiation safety program – how you’re going to train your radiation workers, what your dosimetry program will look like, what sort of radiation instruments you’ll use, and much more. As you go through this, there are a few general things to keep in mind.

  1. There are a number of places in which NUREG 1556 (or your state equivalent) will ask you to describe your procedure for…something. Coincidentally, the guidance document contains a bunch of “model procedures” in appendices. It is perfectly acceptable for you to simply state “Radioactive Materials receipt and accountability will be conducted in accordance with the Model Procedure(s) found in Appendix J of NUREG 1556, volume 7, rev. 1 (2018).”
    • And a caveat to this – the model procedures and programs are aimed to guarantee that, if you follow them, you’ll be in compliance with the regulations. But they can be overly restrictive for some licensees. These documents are guidance documents and you can differ from them as long as you can show that your proposed program or procedure is at least as protective of worker and public health and safety as what the model program or procedure calls for.
  2. When you’re answering these questions and describing how you plan to run your radiation safety program, it’s better to avoid unnecessary specificity – as I put it, “It’s better to be generally right than to be specifically wrong.”
    • What this means is that you don’t need to try to impress the regulators by sending them (for example) a list of every radiation instrument and detector you have in every lab on campus. The reason for this is that, if your license application lists all of this, simply replacing a broken instrument with a different one can technically put you out of compliance with your license. So it’s better to simply say that you’ll have radiation instruments and detectors capable of detecting alpha, beta, and gamma radiation and contamination, and capable of measuring beta and gamma dose rates up to 10 R/hr (or whatever dose rate you might see if your highest-activity source loses its shielding). That leaves you able to use different instruments, different probes, and different manufacturers while remaining in compliance with your license application.
  3. In addition, try to keep your application as simple as possible. First, write it using simple sentences (or even bullet points). It might be aesthetically pleasing to write a long, convoluted, literary sentence with all sorts of dependent and independent clauses explaining all the nuances of your radiation safety program. The problem is that your regulators might not understand this the same way you do. It’s better to use short, declarative sentence that say exactly what you’re asking (or promising).
    • In addition, keep the concepts simple. It might be justifiable to say (for example) that anybody using a self-shielded irradiator will turn in their radiation dosimetry quarterly, those using soil density gauges will turn theirs in semi-annually, people performing iodinations will have monthly thyroid bioassays as well as a bimonthly dosimeter reading, those using x-ray diffractometers will have their extremity and whole-body dosimeters read monthly when the devices are in use and only quarterly otherwise, that those storing more than 1 mCi of gamma-emitting nuclides will have dosimeters read monthly, and that those working with anything else will have semi-annual dosimeter reads. Every one of these can be justified – but do you want to run a program like this and to try to keep track of all of these users? It might be easier to simply say that every dosimeter will be read monthly – or to decide to have only monthly and quarterly dosimeter readings.
  4. Finally, keep your license application “clean” – avoid the temptation to submit it with a lot of attachments. For example, if you want your regulators to know how you’re going to run your training program, it can be tempting to include a copy of your training booklet, the slides you plan to use, and the exam you’ll give your students. On the bright side, if you do this, your regulators will effectively be approving your training program. On the other hand, this means that you might need to let them know every time you change your slides, revise your test, or add to your training booklet. Me? I don’t attach anything to my license application unless the regulators tell me I have to – and even then I’ll add a sentence along the lines of “This document is provided at the request of the regulatory authority; (college name) reserves the right to update as necessary to reflect current practices/policies/procedures/etc.”
    • The reason for this is that I want “my” documents to be mine. In other words, if I update my training manual, if I write a new SOP for a new instrument I purchase, if one of our policies changes – I don’t want to ask my regulators for permission.

I could keep going…probably for another 5000 words (or the equivalent in food and beer if we were talking this through in person), but things start getting pretty specific, dealing with your program, pretty quickly. So this seems a good place to wrap up…for now, anyhow. Putting your license application together is not a lot of fun, but it’s the first – and more important – step in deciding what your radiation safety program is going to look like, and how it will be run. Once you get through this, you’ll need to start setting the program up, and then managing it. As I mentioned earlier, let me know when you get to that point and we’ll take it from there.

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