RADIATION SAFETY

HELPFUL REGULATORY DOCUMENTS

RADIATION SAFETY HANDBOOK (Revised & Accepted by the RSC 4/17/2025)

The Radiation Safety Handbook (including Appendixes) is available as a PDF (most updated handbook here) and the body of the handbook is copied below for your convenience.

Table of Contents

  1. DEFINITIONS
  2. RESPONSIBILITIES OF THE RADIATION SAFETY COMMITTEE
  3. RESPONSIBILITIES OF THE RADIATION SAFETY OFFICER
  4. NOTIFICATION OF RADIATION SOURCE USE
  5. APPROVAL REQUIRED FOR USE
  6. INVESTIGATOR REQUIREMENTS AND RESPONSIBILITIES
  7. SELECTION OF USERS
  8. PROTOCOLS
  9. PERSONNEL TRAINING
  10. PERSONAL MONITORING AND EXPOSURE REPORTING
  11. POSTING OF NOTICES AND SIGNS
  12. RECEIPT OF RADIOISOTOPE SHIPMENTS
  13. RESTRICTION ON USE OF ORGANIC SCINTILLATION FLUIDS
  14. RADIOISOTOPE WASTE MANAGEMENT

A. DEFINITIONS

ACRONYMS:

RSC: Radiation Safety Committee

RAM: Radioactive materials
 RSO: Radiation safety officer

DPH: Department of Public Health

ALARA: As low as reasonably achievable
 NRC: the U.S. Nuclear Regulatory Commission 

NUREG: a series of publications issued by the U.S. NUclear REGulatory Commission

RADIATION SOURCE: 

Any of the following sources of ionizing or nonionizing radiation:

Radioisotopes

X-ray generators

Lasers (refer to Part B for laser requirements)

Radiofrequency Electromagnetic Fields (10 kHz – 300 GHz)

Ultraviolet  A (315-400 nm), B (280-315 nm), C (100-280 nm), Vacuum (10 – 200 nm), excluding fluorescent lamps used for lighting

Infrared (780nm – 1 mm)

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, as well as the other sources listed above. Requirements for laser use are detailed in Chapter VII(b). 

INVESTIGATOR:

A Smith College faculty or staff member whose protocol and qualifications permit the Radiation Safety Committee to approve the purchase and use of controlled radiation sources, including radioisotopes. The staff member may hold a regular or limited-term employment position as defined in the Smith College Staff Handbook.  In cases where controlled radiation sources are used for instructional purposes, at least one faculty or staff member involved with the course must be the Investigator.

A faculty member may be approved as an Investigator for any/all types of sources of ionizing or nonionizing radiation, as long as they meet the requirements set forth by the Radiation Safety Committee and Massachusetts Radiation Control Program (where applicable).

A staff member whose terminal degree is less than a doctorate may only be approved as an Investigator for radioactive materials that meet the definitions (given below) of sealed sources or for radioisotopes containing only source material. 

RAM-Credentialed Researcher – A staff employee or faculty member paid by Smith College with a minimum of a Bachelor’s degree, ≥40 hours* of training outside of Smith College, who has been further trained by the Investigator on the specific protocol(s) they will be following, and is accepted by the RSC.  A RAM-credentialled researcher is NOT listed on the College’s License; only faculty members and the RSO will be listed, per RSC.  

*Training must occur outside of Smith College, with roughly 90% of the required ≥40 hours being hands-on experience with radioisotopes in a lab which routinely uses the same form (i.e., liquid) and ideally the same or similar isotope as the Smith Investigator’s lab

USER:

One who is permitted to work with or handle controlled radiation sources in research or educational activities under the supervision of an Investigator.  A “User” may be a faculty member, staff member, undergraduate or graduate student, or a visiting scholar.  A User must be 18 years of age or older.

LICENSE:

Commonwealth of Massachusetts Department of Public Health (DPH) license # 01-4621 granted to Smith College as required by 105 CMR 120.000

MASSACHUSETTS REGISTRATION:

Massachusetts Department of Public Health Registration #5580 granted to Smith College for X-ray sources as required by 105 CMR 120.000.

RADIATION SAFETY COMMITTEE:

Smith College Radiation Safety Committee. Committee composition includes the Radiation Safety Officer, representatives of the Biological Sciences, Chemistry, Geosciences, and Physics Departments, and any other Department using controlled radiation sources.

COMMITTEE QUORUM:

Two-thirds of Radiation Safety Committee Membership constitutes a quorum.

RADIATION SAFETY OFFICER:

The individual designated by the Smith College Radiation Safety Committee as the Radiation Safety Officer (RSO); this individual has met any requirements set forth by the Massachusetts Radiation Control Program and/or Department of Public Health and has been added to the College’s Radioactive Materials License. The Radiation Safety Officer may be a member of the faculty or a staff member.  The RSO may handle, supervise, and work with radioactive materials to the extent their responsibilities as RSO require, but any experimentation with or acting as a ‘replacement supervisor’ of others’ experimental work with radioisotopes is subject to the same approval process as any other potential Investigator.  

SEALED SOURCE means:

Any radioactive material that is used as a source of radiation and is encased in a capsule designed to prevent leakage or escape of the radioactive material.

SOURCE MATERIAL means:

  1. Uranium or thorium or any combination of uranium and thorium in any physical or chemical form; or  
  2.  Ores that contain, by weight, one-twentieth of 1 percent (0.05 percent), or more, of 

(a) uranium; 

(b) thorium;

(c) or any combination thereof.   

Source material does not include special nuclear material.

SPECIAL NUCLEAR MATERIAL means:

  1. Plutonium, uranium-233, uranium enriched in the isotope 233 or the isotope 235, and any other material that the U.S. Nuclear Regulatory Commission, pursuant to the provisions of Section 51 of the Atomic Energy Act of 1954, as amended, determines to be special nuclear material, but does not include source material; or
  2.  Any material artificially enriched by any of the foregoing but does not include source material.

BY-PRODUCT MATERIAL means:

(1) Any radioactive material (except special nuclear material) yielded in, or made radioactive by, exposure to the radiation incident to the process of producing or using special nuclear material;

 (2)(a) Any discrete source of radium-226 that is produced, extracted, or converted after extraction, before, on, or after August 8, 2005, for use for a commercial, medical, or research activity; or

(b) Any material that—

1.Has been made radioactive by use of a particle accelerator; and

  1. Is produced, extracted, or converted after extraction, before, on, or after August 8, 2005, for use for a commercial, medical, or research activity; and

(3) Any discrete source of naturally occurring radioactive material, other than source material, that:

(a) The Commission, in consultation with the Administrator of the Environmental Protection Agency, the Secretary of Energy, the Secretary of Homeland Security, and the head of any other appropriate Federal agency, determines would pose a threat similar to the threat posed by a discrete source of radium-226 to the public health and safety or the common defense and security; and

(b) Before, on, or after August 8, 2005, is extracted or converted after extraction for use in a commercial, medical, or research activity.

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, Investigators, Department Chairs and Science Center Administration 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 records pertaining to the radiation safety program:
    • Waste disposition
    • Maintain RSO’s survey instrumentation in good operating condition with annual calibration documented
    • Results of ‘leak tests’, semiannual surveys, monthly ‘walk-throughs’ and dosimetry
  • Distribute film badges on a monthly basis.
  • Assist Investigators in arranging for annual calibration of their lab’s survey equipment.
    • Assist Investigators in monitoring of radioisotope spill clean-up activities.
    • Prepare the College’s License Renewal Application as required and submit it to the DPH/RCP upon review by the Radiation Safety Committee, the Administrative Director of the Science Center and the appropriate College Responsible Official.

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/RCP license and non-DPH/RCP 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/RCP regulated sources all Investigators must be listed on the DPH/RCP license, and any areas of use (laboratories) must also be detailed in the most recent License Application or added by the submission and subsequent approval of a License Amendment to the DPH/RCP. 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/RCP License Amendments to add new Investigators or additional laboratories 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.

Approval to use licensed radioactive material in live animals (in vivo) must be specifically requested from MA Radiation Control as the College’s license and research does not currently involve this work.  Adding it to the License by Amendment is feasible, but must include information requested in NUREG 1556-7 and its Appendix D, along with ALARA considerations and staff training if the work is conducted in the Smith Animal Care Facility.  This approval would likely take anywhere from a few months to a year, depending on the complexity and the staffing at the Radiation Control Program.

All purchases of controlled radiation sources must be verified and processed by the Stockroom Manager.  The Radiation Safety Officer will approve all requisitions prior to the Stockroom placing the order for any radioactive material.  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/RCP License be used outside of the Science Center (consisting of McConnell Hall, Bass Hall, Sabin Reed Hall and Burton Hall) or Ford Hall.  Likewise, radiation sources ordered or obtained from another DPH/RCP Licensee will not be used in the Science Center or Ford Hall without prior approval of the Radiation Safety Committee.

F. INVESTIGATOR REQUIREMENTS AND RESPONSIBILITIES

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 in the protocol and approved by the Committee. 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.
  • Appropriately complete and return annual protocol renewal forms to the RSO
  • Supervise the use of radiation sources under their jurisdiction.
  • Train and document 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 in 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.
  • Only use radioisotopes in those labs where their use has been approved via protocol (and added to the College’s Radioactive Materials License if required).
  • Verify all Users are 18 years of age or older, either by collecting birthdates as well as names when documenting training for an instructional (class) use, or by completing Appendix B or C (User Training).
  • Investigators who have not used radioisotopes within a year are asked to contact the RSO prior to ordering RAM in order to arrange an orientation session as procedures and equipment may have changed since the last time RAM was used

Investigator Responsibilities which continue when their lab includes a RAM-Credentialed Researcher:

  • Signature/email signoff for each purchase of RAM
  • Signoff on all required record keeping within 2 business days (inventory, daily and weekly contamination surveys, etc)
  • Initial training of students and others using radioactive material in their lab, according to requirements in the Radiation Safety Handbook
  • Package receipt and associated contamination surveys and recordkeeping (upon prior arrangement these may be performed by the RSO if scheduling permits)
  • Investigator must be available locally during assays or make advance arrangements with another Investigator and inform the RSO of these arrangements via email

A RAM-Credentialed Researcher is able to:

  • Handle and dilute stock solution
  • Perform all steps in RAM protocol
  • Perform cleanup surveys, i.e, LSC swipes, meter surveys (Investigator must sign off within 2 business days)
  • Consign inventory and waste (with Investigator signoff, see above)
  • Assist RSO in moving liquid and solid waste to RAM accumulation area
  • May assist with spill cleanup
    • Investigator and RSO to be notified immediately
    • Investigator must be present during cleanup or make alternate arrangements in advance with another Investigator

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; in addition, all Users must be 18 years of age or older.  The Users must be trained as described in 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, Smith College ID # (or State Driver’s license # or their institution’s ID #).  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.

H. PROTOCOLS

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:

  • Investigator
  • 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
  • Verification that all Users are at least 18 years of age
  • 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 for ALL participants, including the NRC Regulatory Guide covering prenatal exposure:

  • 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
    • access to film badge records, and
    • Investigator shall train the users in the lab protocol for RAM use.

The referenced NRC Regulatory Guides are provided to each Investigator by the RSO.

All Users must be made aware of 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 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, Campus Safety, 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 radiation 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 Ford and Sabin Reed Stockrooms by the Stockroom personnel, who do not open the package and contact the Investigator immediately by phone or email. If the Investigator is not immediately available, the unopened package is placed in the Radioactive Storage area (in Ford Hall or Sabin Reed) .  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, 125I) 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, along with survey results, is recorded in the laboratory log book.  It is important to note the time of receipt and testing in the logbook, as the pickup and survey must be completed within three hours of receiving the package at Smith College, rather than when the package is picked up by the Investigator.

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 or Ford 141E is the responsibility of the Investigator; the RSO will assist with the relocation but the Investigator must complete the waste transfer log. All waste bags and containers must be transported in secondary containment on a cart. 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, and Ford 141E. 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 & Accepted by the Radiation Safety Committee:  4/17/2025