NRC Regulatory Guide 8.29
Massachusetts is an Agreement State
Any of the following sources of ionizing or nonionizing radiation.
- X-ray generators
- Lasers (refer to Chapter VII(b) for laser requirements)
- Radiofrequency Electromagnetic Fields (10 kHz – 300 GHz)
- Ultraviolet B, C, Vacuum (320 – 170 nm): excluding fluorescent lamps used for lighting
- Infrared (750 – 3000 um)
CONTROLLED RADIATION SOURCE:
Radiation sources for which the Radiation Safety Committee requires the submission of protocols or registration. Includes all radioisotopes and x-ray generators. Requirements for laser use are detailed in Chapter VII(b). The requirements of this Chapter, VII(a), do not apply.
A faculty member who is “approved” to purchase and use controlled radiation sources. In cases where controlled radiation sources are used for instructional purposes, the instructor must be the Investigator.
One who is permitted to work with or handle controlled radiation sources in research or educational activities under the supervision of an Investigator.
Commonwealth of Massachusetts Department of Public Health (DPH) license # 01-4621 granted to Smith College as required by 105 CMR 120.000
Massachusetts Department of Public Health Registration #5580 granted to Smith College for X-ray sources as required by 105 CMR 120.000.
Clark Science Center Radiation Safety Committee. Committee composition includes the Science Center Director as chair, the Radiation Safety Officer, representatives of the Biology, Chemistry, Geology, and Physics Departments, and any other Department using controlled radiation sources.
Two-thirds of Radiation Safety Committee Membership constitutes a quorum.
RADIATION SAFETY OFFICER:
The individual designated by the Clark Science Center Radiation Control Program as the Radiation Safety Officer (RSO).
B. RESPONSIBILITIES OF THE RADIATION SAFETY COMMITTEE
The Radiation Safety Program is administered by the Radiation Safety Officer (RSO) under the guidance of the Radiation Safety Committee. The Committee meets twice a year or more frequently as necessary. The functions of the Committee include the following.
- Review and approve notifications and protocols for proposed use of radiation sources.
- Withdraw permission for use of radiation sources in cases of failure to respect radiation protection requirements of the College, the DPH Radiation Control Program, or any other accepted protection standard or when use is inconsistent with that approved in the Investigator’s protocol.
- Develop policies and procedures governing the use of radiation sources.
- Serve as a liaison with their Department with regard to radiation use and safety.
C. RESPONSIBILITIES OF THE RADIATION SAFETY OFFICER
The Radiation Safety Officer must be approved by the Massachusetts Department of Public Health (Radiation Control Program) and specifically listed on the DPH License. The RSO is responsible for the following.
- Draft policies and procedures governing the use of radiation sources for review and approval by the Committee.
- Advise the Committee and Investigators on technical and administrative radiation use and safety issues.
- Serve as the College’s representative in all contact with federal, state, and local agencies regarding radiation use and safety.
- Perform periodic inspections of all areas of radioisotope use, including “walk through” inspections monthly, and semiannual surveys using survey instruments and/or wipe tests.
- Arrange for disposition of all radioactive waste.
- Maintain all records pertaining to the radiation safety program.
- Distribute film badges on a monthly basis.
- Maintain survey instruments in good operating condition and arrange for annual calibration.
- Assist Investigators in monitoring of radioisotope spill clean-up activities.
D. NOTIFICATION OF RADIATION SOURCE USE
All faculty and staff using radiation sources as defined above must notify the Radiation Safety Committee of their use on the form included in Appendix A. The Radiation Safety Committee will then determine if the radiation source is a controlled radiation source thereby requiring approval as described in Section E. Users of radioisotopes and x-ray generators, which are automatically defined as controlled radiation sources, should proceed with submission of protocols as defined in Section E in lieu of notification.
E. APPROVAL REQUIRED FOR USE
The right to purchase and use radiation sources under the Smith-DPH license and non-DPH controlled radiation sources is granted to an Investigator by the Radiation Safety Committee by the vote of a quorum with, at most, one dissenting vote. For DPH regulated sources all Investigators must be listed on the DPH license. All Investigators must submit protocols satisfactorily outlining the proposed use of the specific radiation source and containing at a minimum the information described in Section H. Each new or different investigation or experiment requires a separate protocol and approval. DPH license amendments to add new Investigators will be filed by the Radiation Safety Officer upon approval of the new protocol(s) by the Committee. The protocols will be reviewed annually by the Committee and at other times as the Committee deems necessary.
All purchases of controlled radiation sources must be verified and processed by the Stockroom Manager. The Radiation Safety Officer will provide the Stockroom Manager with a list of Investigators, types, and amounts of material which may be ordered. Records of all purchases are reviewed by the RSO regularly and maintained for review at Committee meetings.
In no case will radiation sources ordered under the DPH License be used outside of the Science Center. Likewise, radiation sources ordered or obtained from another DPH Licensee will not be used in the Science Center without prior approval of the Radiatio Safety Committee.
All Investigators will be held responsible for the safe and proper use of radiation sources in investigations and experiments under their jurisdiction. It is expected that the Investigator will be present when controlled radiation sources are being used unless alternative supervisory arrangements are clearly defined and approved in the protocol. Delegation of the responsibilities of an Investigator is not permitted except on prior approval of the Radiation Safety Committee. Specific duties of each Investigator include the following.
- Prepare and submit protocols to the Committee for review and approval.
- Supervise the use of radiation sources under their jurisdiction.
- Train all users in all aspects of safe handling as described in Section I.
- Post all required signs and notices required as described in Section K.
- Provide the RSO with information requested pertaining to radiation use and safety.
For Investigators using radioisotopes, the following additional duties apply.
- Perform surveys using a survey meter (for applicable sources) or wipe tests daily when radioactive material is being used.
- Perform wipe tests on at least a weekly basis when radioactive material is in use unless otherwise specified and approved i the protocol.
- Report all spills to the RSO and supervise clean-up.
- Maintain a log book in the laboratory for recording information regarding radiation use including receipt of shipments, monitoring results, and spill reports.
Violations of safe practices, failure to observe regulations, ignoring established procedures, or not exercising appropriate supervision may lead to revocation of approval to use controlled radiation sources by the Radiation Safety Committee. The DPH can also withdraw or curtail the DPH License in incidents where an Investigator is found to be at fault or negligent in the proper use of radiation sources.
Each Investigator using DPH regulated sources (radioisotopes) must meet the qualifications as set forth in DPH regulations namely, that the Investigator (1) possess a baccalaureate degree in a science or engineering field, or the equivalent in experience and education; and (2) has 40 hours of training in the hazards and safe use of radiation sources, or the equivalent in training and experience. The Radiation Safety Committee will interpret compliance with these requirements.
G. SELECTION OF USERS
The Investigator will select Users, who will be permitted to handle controlled radiation sources involved in the experiment or investigation; these Users may be undergraduate or graduate students, technicians, graduate assistants or other faculty members. The Users must be trained as described Section I and in the Investigator’s protocol. All Users, including students, must be registered with the Radiation Safety Officer for the master file and for film badge exposure records when applicable. Registration must include name, date-of-birth, social security number and sex. Persons who are not registered are not permitted to work with or otherwise handle controlled radiation sources. For instructional use, the Investigator must keep a log of students using radiation sources and will submit a copy of that log to the Radiation Safety Officer.
A written protocol is required for each investigation or experiment using a controlled radiation source including those for instructional purposes. This protocol should include the following information when applicable to the specific investigation.
- Description of the Radiation Source including Energy Potential
- Maximum Amount of Source On-Hand (radioisotopes)
- Source Toxicity Rating (radioisotopes)
- Location of Use and Storage
- Expected and Maximum Exposure Rates
- Associated Health Hazards
- Detailed Experimental Procedure
- Shielding Requirements
- Personal Protective Equipment
- Radiation Monitoring Procedures
- Records/Logs Kept
- User Training
- Waste Generated, Handling Procedures, and Minimization Program (radioisotopes)
- Labeling of the Area and Equipment
- Spill Clean-Up Procedure (radioisotopes)
- Proximity of the Investigator during Source Use
- Investigator Qualifications
I. PERSONNEL TRAINING
The qualifications of each Investigator must be described in all protocols submitted. The Committee will evaluate those qualifications and suggest additional training or restrictions on the protocol as appropriate.
Each Investigator is responsible for the training of all Users selected prior to their handling of controlled radiation sources. The training must include the following elements:
- health effects of radiation exposure (NRC Regulatory Guide 8.29, Instruction Concerning Risk from Occupational Radiation Exposure, and NRC Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure, must be discussed and made available for review from each Investigator),
- purpose and function of protective equipment (e.g., shielding), and monitoring equipment including film badges if applicable,
- precautions necessary to minimize exposure,
- responsibility to report to the Investigator or RSO any conditions that may lead to unsafe working conditions or DPH violations,
- emergency response procedures, and
- access to film badge records.
The referenced NRC Regulatory Guides are provided to each Investigator by the RSO.
All Users must be made aware of the DPH restriction of 10 percent of the acceptable dose to persons under 18 years of age (105 CMR 120.217) and the DPH restriction for a declared pregnant woman which also restricts the acceptable dose to the fetus to 10 percent of acceptable dose (105 CMR 120.218).
Each User, with the exception of instructional use, must complete a User training record (Appendix B). Originals of User training records must be sent to the Radiation Safety Officer.
The RSO will conduct training for ancillary personnel including: custodial staff, security, and selected tradespeople at least annually.
J. PERSONAL MONITORING AND EXPOSURE REPORTING
External whole-body radiation monitoring for exposure to X-ray, beta and gamma radiation is conducted, if appropriate for the radiation source in use, using film badges. Badges are exchanged on a monthly basis and analyzed by a NVALP certified laboratory. Similarly, finger badges are used for procedures using .5mCi or more of 32P. Given the nature of investigations using radiation sources at the Science Center, exposures to radiation are not routine and each exposure is thoroughly investigated to determine necessary remedial action.
Upon receipt of a radiation badge report indicating that an exposure has occurred the Radiation Safety Officer immediately contacts the analyzing laboratory to ascertain any additional information available on the exposure, and does a preliminary evaluation of the legitimacy of the exposure record. For all legitimate or questionable exposures the RSO notifies the individual concerned, the Investigator and the Radiation Safety Committee within 5 days. Subsequent to that notification the Investigator and RSO review all potential sources of exposure and reports back to the Committee.
The RSO is responsible for reporting overexposures to the Massachusetts Department of Public Health as required by 105 CMR 120.282 and 120.283.
K. POSTING OF NOTICES AND SIGNS
Appropriate warning sign(s) as specified in individual protocols must be posted in the primary radiatio use area of each Investigator.
Investigators using radioisotopes under the DPH license must also post the following notices
- DPH Form MCRP 120.750-1 “Notice to Employees“,
- Smith College “Safety With Radioisotopes“,
- Smith College “Radiation Safety Notice: Posting of Notices to Workers“.
Copies of these notices are available from the RSO.
L. RECEIPT OF RADIOISOTOPE SHIPMENTS
Radioisotope shipments are accepted during normal business hours at the Receiving Dock by the Stockroom Technical Support Specialist or Technical Assistant and the Investigator is contacted. If the Investigator is not immediately available, it is placed behind two locked doors which require two different keys to enter. In any case, when the order is placed arrangements are made so that either the Investigator or the RSO will be able to survey the package within three hours of receipt.
The Investigator takes the package to the radiation handling area of the approved laboratory and, wearing gloves, surveys the exterior of the box and all packing materials with a survey meter (32P, 33P, 35S, 45Ca) or wipe tests (3H, 14C). If no contamination is found the packing material is handled as normal waste. If contamination is found the RSO and supplying vendor are contacted. Record of shipment receipt is recorded in the laboratory log book.
If a shipment must be received after hours, the Investigator or the RSO must be available to accept the shipment.
M. RESTRICTION ON USE OF ORGANIC SCINTILLATION FLUIDS
The use of organic scintillation fluids with flash points less than or equal to 140oF is prohibited. This is necessary to ensure that we do not produce any “mixed waste”, waste which is both radioactive and hazardous.
N. RADIOISOTOPE WASTE MANAGEMENT
Each Investigator must describe in each protocol waste types generated, laboratory handling procedures, and a waste minimization program for the laboratory.
Contaminated wastes are collected in each laboratory in specially marked containers. Waste handling procedures must be included in each protocol. Removal of the waste to the radioactive waste storage area in Sabin Reed SB13 is the responsibility of the Investigator. All waste bags must be transported in a secondary container, a rolling drum is available in the waste room for use by Investigators. A description of all waste must be entered into the log book and the waste placed in the appropriate location as defined by posted signs.
All waste contaminated with materials with a physical half-life of less than 120 days must be segregated from longer half-life wastes. Additionally, no radioactive labels should be included in this waste.
The RSO is responsible for managing the waste storage area including Sabin Reed SB13 and SB14. Wastes being held for decay (those with a physical half-life of less than 120 days) are stored in this area, as are wastes being stored on-site pending disposal.
Revised: September 2004
USER TRAINING RECORD