Radiation Safety Manual The Texas A&M Health Science Center Temple Campus (IRM and MRB) The Texas A&M Health Science Center Radiation Safety Manual Level 2 Program: Doc. No.: Date: Office: Radiation Safety RAM- L05494 02-2014 Environmental Health & Safety Concurrence and Approval This RADIATION SAFETY Manual was developed for use by The Texas A&M Health Science Center (HSC), and has been approved by the HSC Director of Environmental Health and Safety (EHS) and the HSC Radiation Safety Officer (RSO). Document Custodian: Erich Fruchtnicht, MS, CHMM, RSO Approval: RSO Date Director, EHS Date Change History Revision Number 000 001 002 003 004 Interim Change No. 0 0 0 0 0 Effective Date 01/2006 06/2012 08/2013 10/2013 02/2014 Description of Change HSC Radiation Safety Manual Update Manual to Match Bryan-IBT Update branding to reflect new HSC logos Update Section 11.1.10 for I125 monitoring Explicitly added ALARA in new Section 12.3 ii The Texas A&M Health Science Center Radiation Safety Manual Level 2 Program: Doc. No.: Date: Office: Radiation Safety RAM- L05494 02-2014 Environmental Health & Safety Table of Contents Concurrence and Approval ............................................................................................................. ii Change History ............................................................................................................................... ii Section 1. Radiation Safety Manuals ......................................................................................... 1 Section 2. Radiation Safety Program ......................................................................................... 2 Section 3. Radiation Safety Committee ..................................................................................... 4 Section 4. Radiation Safety Officers(s) ..................................................................................... 6 Section 5. Principal Investigators .............................................................................................. 7 Section 6. Ordering/Receiving Radioactive Material .............................................................. 10 Section 7. Transferring Radioactive Material .......................................................................... 15 Section 8. Training Requirements for Personnel Working with Radioactive Materials.......... 16 Section 9. Routine Laboratory Procedures .............................................................................. 19 Section 10. Requirements for Posting/Labeling Labs Using Radioactive Material .................. 21 Section 11. Additional Precautions for Users of Radioiodine, Phosphorus-32, and Sulfur-35 . 22 Section 12. Personnel Monitoring.............................................................................................. 25 Section 13. Emergency Procedures............................................................................................ 31 Section 14. Guidelines for Area Contamination Surveys .......................................................... 34 Section 15. Disposal of Radioactive Materials .......................................................................... 37 Section 16. Use of Radioactive Materials in Animals ............................................................... 43 Section 17. General Instructions for Auxiliary Personnel ......................................................... 45 Section 18. Registering X-Ray Machines .................................................................................. 48 Section 19. Radiation Safety Requirements for X-Ray Producing Machines ........................... 51 Section 20. Registering Lasers ................................................................................................... 55 Section 21. Radiation Safety Requirements for Lasers ............................................................. 58 Section 22. Policy for Addressing Violations of Regulatory Requirements or Standards for Safe Work with Radiation, Radioactive Materials, and Lasers ...................................... 66 Section 23. APPENDICES ........................................................................................................ 72 iii Section 1. Radiation Safety Manuals 1.1 Introduction This manual describes policies and procedure for the use of radioactive material and radiation producing devices at the Texas A&M Health Science Center (HSC). The provisions of this manual are applicable to all users. This manual has been approved by the Texas Department of State Health Services, Radiation Control Division. Every attempt has been made to include sufficient detail to enable safe use of radioactive material and radiation producing devices by simply following its provision. It is impossible, however to anticipate all possible circumstances and situations. Due to continuing changes in state and federal regulations governing radiation, readers are advised to contact Environmental Health and Safety (EHS) at their respective location with any questions: 1.1.1 Medical Research Building (MRB) Location: 702 SW HK Dodgen Loop, Temple, TX 76504 Phone: 254-742-7024 1.1.2 Health Science Center Bryan Campus EHS Location: 1022 Medical Research and Education Building Phone: 979-436-0551 1.2 Who Needs a Manual? The Radiation Safety Manual is issued through the Texas A&M Health Science Center’s EHS. It is available to: 1.2.1 1.2.2 All personnel who use, supervise, or control the use of radioactive materials or radiation producing devices. Personnel who might have reason to enter areas where sources of radiation are present. 1.3 Location of Manuals Manuals should be located in: 1.3.1 1.3.2 Every laboratory authorized to use radioactive materials and radiation producing devices. Certain department offices (e.g. Security and Physical Plant). 1.4 Accountability Manuals are numbered for purposes of inventory and updating. Individuals to whom manuals are issued are asked to return their manuals if they terminate employment. Manuals issued to particular departments, divisions, offices, work stations, etc., should pass these on to their successors and notify EHS whenever there are changes to personnel or work practices involving radioactive materials. 1.5 Updates to the Manual Changes and corrections to this manual will be issued by Environmental Health and Safety (EHS) when needed. Such updates will be distributed to all individuals who possess a copy of the manual. Upon receipt of the update, make changes in accordance with instructions accompanying the update and notify all individuals affected. Radiation Safety Manual 1 Section 2. Radiation Safety Program 2.1 Purpose The Radiation Safety Program safeguards the health and well-being of the Health Science Center’s community and the community-at-large from the potentially harmful effects of radiation. This is accomplished by maintaining compliance with applicable federal, state, and institution regulations and through the establishment of good health physics work practices. 2.2 Scope The Radiation Safety Program applies to all persons who purchase, possess, transfer, store, use or handle radioactive material and/or radiation producing devices on or in any HSC Campus, facility, or space used by HSC personnel. 2.3 ALARA Policy The Texas A&M Health Science Center requires that: 2.3.1 2.3.2 2.3.3 All users of radiation sources receive proper safety training, and Be authorized by the Radiation Safety Committee and the Radiation Safety Officer, and Comply with applicable regulatory requirements in order to ensure that all radiation exposures are kept "As Low As Reasonably Achievable" (ALARA). 2.4 Radiation Safety Committee THE RADIATION SAFETY COMMITTEE (RSC) establishes policies for the safe use of sources of ionizing radiation on each HSC Campus holding a TDSHS-issued radioactive materials license. The committee has the authority to curtail or prohibit the use of radioactive material by anyone who is: 2.4.1 2.4.2 2.4.3 2.4.4 misusing radioactive material, or misusing a radiation producing device, or violating the terms of any radioactive material license or regulation, or otherwise creating unsafe conditions. 2.5 Environmental Health and Safety (EHS) The Office of Environmental Health and Safety (EHS) provides for compliance oversight and management of the Radiation Safety Program, through the appointment of a Radiation Safety Officer (RSO). The RSO reports to the Director of Environmental Health and Safety. 2.6 Radiation Safety Officers 2.6.1 The Institutional Radiation Safety Officer (RSO) is responsible for the management of the Texas A&M Health Science Center’s Radiation Safety Program, and is designated as the primary liaison between the HSC and all regulatory agencies involved with radiation control. All changes to radiation licenses and registrations are submitted through the Institutional RSO. 2.6.2 The Site Radiation Safety Officer (RSO) is responsible for local matters relating to radiation safety and shall be the Committee's authorized representative regarding radiation protection within each respective HSC Campus. 2.7 Principle Investigator (PI) PRINCIPAL INVESTIGATORS (PI) are specifically authorized by the Radiation Safety Committee to obtain and use radioactive materials and/or radiation producing devices at HSC. PIs Radiation Safety Manual 2 are responsible for all parts and conditions of their Permit, their Authorized Users and their compliance with all applicable policies, procedures and regulations. 2.8 Authorized Users AUTHORIZED USERS are specifically approved to work with radioactive materials under the permit of their PI. Authorized Users are responsible for working safely with radioactive material and for complying with all applicable policies, procedures, and regulations. 2.9 Documentation Policies, procedures, guidelines which define the Texas A&M Health Science Center’s (HSC) Radiation Safety Program are found in the following documents: 2.9.1 2.9.2 The HSC’s Radiation Safety Manual, (this document) Environmental Health & Safety Standard Operating Procedures Radiation Safety Manual 3 Section 3. Radiation Safety Committee 3.1 Introduction The Radiation Safety Committee (RSC) reports to both the Office of Research and the Office of Finance and Administration. The Committee meets as often as is necessary to conduct its business but at least semiannually. Members may be contacted and polled at any other time concerning specific issues. The RSC is specifically charged with ensuring that the HSC’s radiation safety program is in compliance with all state licensing requirements. 3.2 Functions and Responsibilities Specifically, the RSC will work with the RSO to: 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 3.2.6 3.2.7 3.2.8 Make policies and procedures for the protection of all individuals from the hazards related to sources of ionizing radiation. Identify areas in which radiation hazards exist or are likely to exist. Ensure that radiation laboratories are clearly designated through the use of signs or other visible indicators. Ensure safe use of radioactive materials by approving and requiring training, pre-approving sublicenses for specific use, and prohibiting use when necessary. Ensure safe use of radiation producing devices by approving and requiring training, pre-approving subregistrants, and prohibiting use when necessary. Regulate HSC facilities using radiation producing devices and radioactive materials. Investigate any possible misuse, apply and enforce any necessary disciplinary action, and notify the State of any reportable incidents. Review and approve amendment applications to the HSC Campus over which that RSC has jurisdiction prior to submittal to the State. 3.3 Membership Members of the Radiation Safety Committee and its Chair shall serve a two (2) year term. Committee membership will normally include representatives from various user groups. Total membership for the committee will consist of no fewer than four (4). All members of the Committee shall be voting members and may come from the following groups: 3.3.1 3.3.2 3.3.3 3.3.4 Radiation Safety Officer(s) Lab Operations (Administration) Members of the Scientific Staff. These members must currently hold a permit to use radioactive materials at the HSC, or have substantial experience with the use of radioactive materials. One will serve as Chair for the Committee. Representatives from the Technical Staff (Research Assistants, Lab Technologists, Lab Coordinators, etc.) 3.4 Radiation Safety Program Evaluation The RSC shall meet at least semiannually for the purpose of being briefed on the status of the radiation safety program. The agenda shall include but not be limited to the following: 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 changes of the Committee membership changes of the EHS staff changes in regulations, policies, and procedures review of incidents or accidents proposed research programs Radiation Safety Manual 4 3.4.6 future requirements of the EHS Office The RSC will also evaluate the content and implementation of the Radiation Safety Program by reviewing an annual audit performed by the RSO. 3.5 Safety Violations Investigation of safety violations can be initiated by the RSC or the RSO and will follow the policy items laid out in Section 9 below. 3.6 Annual Report The RSC shall prepare an annual report for the Office of Research Compliance summarizing committee and EHS activities for the year. These activities include but are not limited to: 3.6.1 3.6.2 3.6.3 3.6.4 3.6.5 3.6.6 3.6.7 3.6.8 Committee membership Addition/Deletions of Principal Investigators Incidents involving radioactive materials or overexposure to workers. Statistics of Radiation EHS (i.e., number of packages received, labs audited and results, waste disposal, etc.) Changes in HSC policies and procedures involving usage of radioactive materials and/or radiation producing devices Major changes to the Texas Regulations for the Control of Radiation. Results of the RSO's annual report. Plans for the next year. Radiation Safety Manual 5 Section 4. Radiation Safety Officers(s) 4.1 Radiation Safety Officers Radiation Safety Program management at the Texas A&M Health Science Center is administered through the Office of Finance and Administration, Office of Environmental Health & Safety. 4.1.1 4.1.2 The Institutional RSO provides program oversight throughout the HSC. The Site RSO is the EHS official for the specific Health Science Center Campus. 4.2 Responsibilities The Radiation Safety Officer is responsible for the following: 4.2.1 assists in the development of general policies for control of radiation 4.2.2 collects and disseminates information relative to radiation protection 4.2.3 evaluates equipment and physical facilities 4.2.4 evaluates operational techniques and procedures 4.2.5 instructs personnel in the practical aspects of radiation protection 4.2.6 conducts an inspection program to assure that laboratory facilities and procedures are in accordance with HSC policies and Texas Regulations for Control of Radiation 4.2.7 provides advice on decontamination of facilities and equipment following spills or prior to remodeling or modification of facilities 4.2.8 responds to emergencies and investigates accidental exposures 4.2.9 aids in the completion of all forms and documents associated with the Radiation Safety Program 4.2.10 conducts a program of quarterly wipe tests in the laboratory areas where the radioactive materials are handled 4.2.11 provides a personnel monitoring program (as needed) 4.2.12 receives, inspects and delivers packages containing radioactive materials 4.2.13 maintains and updates an inventory of radioactive materials 4.2.14 sets up and maintains a radioactive materials waste disposal program 4.2.15 calibrates or arranges calibration of survey instruments 4.2.16 liaisons with the State for all license and registration issues 4.2.17 maintains all records necessary for the administration of the license 4.3 Emergency Authority The Radiation Safety Officer is authorized to take prompt remedial action in radiation emergency situations without prior approval from the RSC or through the management chain. The RSO shall notify supervisory authority of the event at the earliest opportunity. Radiation Safety Manual 6 Section 5. Principal Investigators 5.1 Introduction Licenses to possess and use radioactive materials have been issued to certain Texas A&M Health Science Center (HSC) Campuses by the Texas Department of State Health Services (TDSHS). The license is called a "specific license" and which requires that final approval of Principal Investigators rests with TDSHS. Under the terms of this license, the Radiation Safety Committee is given the responsibility to review and approve applications for use prior to submittal to TDSHS. 5.2 Principal Investigator Those faculty members who, because of their training and experience, have been designated by TDSHS as being qualified to use radioactive material at a certain HSC Campus are referred to as Principal Investigators (PIs). A faculty member whose application has been denied by the RSC due to insufficient training and/or experience may use radioactive materials as an Authorized User on another Principal Investigators Permit with the condition that the training and experience requirements be completed within six months of the RSC's decision or by the end of the next training course presented by EHS to meet the training requirement. 5.3 Authorized User (AU) Those faculty, HSC post-doctoral fellows or other HSC students and staff who may work in the lab of a PI who has been authorized to work with radiation sources under the provisions of this rule. An AU does not hold a permit to perform work with radiation sources and must work under the supervision of a PI. All AUs must complete appropriate training as required by the RSC, and the RSO, and shall have laboratory specific training provided by the PI under whom the AU works. 5.4 Requirements The following educational, training and/or experience standards are established to satisfy requirements: 5.4.1 5.4.2 Formal course in radioisotope techniques, and six (6) months of experience and training under the supervision of a licensed staff member, or Having held a Radioactive Material License issued by the USNRC, an agreement state or another recognized institution for similar work. If the applicant has experience in using radioactive material but has not received formal training in radiation safety principles, then they must attend and pass the Radioisotope Handling and Procedures course offered by EHS. 5.5 Responsibilities The Principal Investigator is directly responsible for all aspects of radiation safety associated with his possession and use of radioactive materials. This responsibility includes: 5.5.1 5.5.2 5.5.3 5.5.4 complying with Texas Regulations for the Control of Radiation, complying with conditions of the HSC Radioactive Materials License, complying with the conditions of his or her permit, complying with the HSC Radiation Safety Manual and policies of the Radiation Safety Committee, Radiation Safety Manual 7 5.5.5 providing instructions on safe and proper radiation practices to all persons working within the facilities of the Principal Investigator, 5.5.6 maintaining adequate control of the radioactive material to ensure that areas beyond the Principal Investigator's control are not adversely affected by its use, 5.5.7 providing necessary equipment for safe work with radioactive material, 5.5.8 properly labeling all radiation sources and areas, 5.5.9 securing all radioactive material against theft or unauthorized use, 5.5.10 properly disposing of all radioactive waste, 5.5.11 notifying the EHS Office/Radiation Safety Officer of any accident or abnormal incident involving or suspected of involving radioactive material, and 5.5.12 informing the EHS Office of any changes in personnel and any significant changes in lab design or procedures. 5.6 Record Keeping The following records shall be maintained by the Principal Investigator. 5.6.1 5.6.2 5.6.3 5.6.4 5.6.5 Radioisotope Tracking Form Wipe Test Results Survey Meter Calibration Radiation Safety Survey Most recent permit application, the approved permit and all correspondence relating to the permit. 5.7 Application for Permit Any qualified faculty member who wishes to become a Principal Investigator to use radioactive materials must submit an application to the Radiation Safety Committee through the RSO. 5.8 Procedure To obtain a permit to use radioactive materials: 5.8.1 5.8.2 5.8.3 5.8.4 5.8.5 5.8.6 5.8.7 5.8.8 Complete an application Complete a facility inspection by the Radiation Safety Officer. The completed application and RSO recommendation will be circulated to the Radiation Safety Committee If the application is approved by the RSC, an amendment will be submitted to the State to add the new PI. Once State approval has been obtained, an HSC “Permit to Use” will be issued to the PI by the RSO. The permit will list the Principal Investigators, Authorized Users, the radionuclides and activity limits and authorized locations. Permits are valid for two (2) years. Applications for permits and a guide for completing them are included as an appendix to this Radiation Safety Manual or online by contacting the RSO. The RSO will assist all applicants in completing the forms. 5.9 Amendment of Permit Requests for changes to an RAM authorization permit can be made by completing a "Radioactive Material Permit Amendment Form" and returning it to EHS for review by the Radiation Safety Committee. 5.10 Renewal of Permit Radioactive Material Use Permits expire on the last day of the month indicated on the permit. Radiation Safety Manual 8 Prior to that date, the RSO/EHS Office will send a completed renewal application for the PI to review, sign, and return. All information previously submitted should be carefully reviewed to ensure that it accurately describes current conditions and is sufficient to meet current criteria. If the permit is not to be renewed, the application form is to be returned with a memo stating the PI's intent to let the permit expire. 5.11 Compliance Inspections of Permits EHS staff conducts audits of permit compliance at least quarterly in all areas authorized for storage and use of radioactive material. In addition, EHS staff conducts routine wipe tests and surveys to detect contamination in areas authorized for storage and use of radioactive material. Radiation Safety Manual 9 Section 6. Ordering/Receiving Radioactive Material 6.1 Introduction After authorization for the use of radioactive materials (RAM) has been issued by the RSO, the Principle Investigator (PI) may receive radioactive material in accordance with their permit. All acquisitions of RAM require pre-approval from the RSO. The PI, prior to submitting a purchase requisition to Purchasing, or prior to receipt of a free sample of radioactive materials, must notify the RSO of the intended order or receipt. 6.2 Ordering To order radioactive material (RAM), the following steps must be taken: 6.2.1 6.2.2 6.2.3 6.2.4 6.2.5 6.2.6 Complete a “Purchase Requisition Form” describing the material to be ordered. Must include: 6.2.1.1 Radionuclide 6.2.1.2 Activity (total activity not specific activity) 6.2.1.3 Chemical / physical form 6.2.1.4 Vendor 6.2.1.5 Expected delivery date NOTE: Packages must be scheduled to arrive between Monday and Thursday. Place the permit number of the PI who will be responsible for the use of the material on the form Have the form signed or initialed by the PI Fax or email a scanned copy of the form to the HSC RSO If approved for order, the originator of the request will be informed via email and/or fax When placing the order, specify your address as the “Bill to” address and give the following “Ship to” address: Radiation Safety Officer Attn: (enter PI’s name) (Building Specific Address) 6.3 Free Samples The PI, prior to receipt of a free sample of radioactive materials, must notify the RSO of the intended receipt. 6.4 Receiving For MRB: All RAM shipments must enter the HSC campus through the EHS office. Delivery carrier personnel will call the MRB EHS office upon the arrival of a radioactive material package. EHS personnel will meet carrier and accept delivery of the radioactive material package. Within three hours of receipt, EHS will: 6.4.1 6.4.2 take the package to room 320 of the MRB perform the Package Acceptance Procedure as described in Section 6.6 below Radiation Safety Manual 10 For IRM: All RAM shipments destined for the HSC IRM campus will be delivered directly to the IRM. The TDSHS requires that shipments of radioactive materials be processed as soon as is practicable but no later than three working hours after receipt of the package. To comply with this rule, within three hours of receipt the IRM staff will: 6.4.3 6.4.4 take the package to the designated RAM usage area in C179 (which has been confirmed clean by after-experiment swipe tests and Geiger-Mueller meter surveys) perform the Package Acceptance Procedure as described in Section 6.6 below 6.5 Isotope Tracking Form An Isotope Tracking Form shall be included with any package delivery at the time of package transfer to PI or lab. This form shall be used to record any and all use of the delivered radionuclide to provide an inventory record indicating zero final activity upon waste disposal. 6.6 Package Acceptance Procedure 6.6.1 6.6.2 6.6.3 Cautions 6.6.1.1 As with all exposure to radiation and radioactive material, it is important to keep your exposure as low as reasonably achievable (ALARA). 6.6.1.2 Gloves should be worn at all times while checking in radioactive material shipments. 6.6.1.3 A leaking or contaminated primary vial may result in personnel and surface contamination. If a shipping container appears damaged or wet, survey the package for contamination immediately and take extra care to prevent contamination from spreading. If a leaking package is identified, notify the EHSD immediately and survey for secondary contamination in the package check-in area. Instrumentation To accurately measure radioactive contamination and radiation levels, you must use appropriate calibrated instruments. Contact the RSO for information regarding annual calibration of these instruments. 6.6.2.1 The meters you will need for this procedure are either: 6.6.2.1.1 an Ionization chamber, or 6.6.2.1.2 an Energy Compensated Geiger-Mueller probe or uncompensated but with exposure filter attached 6.6.2.2 The instrument(s) you will need for this procedure are: 6.6.2.2.1 Liquid Scintillation Counter or similar Ordering/Receiving Radioactive Material 6.6.3.1 6.6.3.2 6.6.3.3 Radiation Safety Manual Before you order radioactive material, you must receive permission from the EHSD to place the order. Please refer to “Ordering Radioactive Material” for instructions. If the order is approved, the order shall be assigned an RSO Number, or Ship Code. If the order is denied, you will receive instructions regarding reducing your present inventory or amending your Permit to allow possession of a greater activity of the nuclide you are ordering. The TDSHS requires that the shipment of radioactive material be processed as soon as is practicable, but not later than three hours after receipt of the package at the PI’s facility if it is received during working hours. If the order is received after normal working hours (or during holidays), the shipment 11 must be checked in no later than 3 hours after the beginning of the next regular business day. Crushed, wet, or damaged packages shall be inspected immediately. 6.6.4 Package Survey 6.6.4.1 Prepare a Radioactive Materials Package Survey form. ALL BLANKS ON THE FORM MUST BE FILLED IN. 6.6.4.2 Verify the package labeling and transport index (See Section 6.7) by measuring external dose rates on contact and at one (1) meter with a properly calibrated dose rate meter. If the exposure rates at the surface of the package and at a distance of 1 meter from the package are less than 0.5 mrem/hr and 0.05 mrem/hr, respectively, these values can be recorded as simply <0.5 mrem/hr and <0.05 mrem/hr. If the radiation levels are above those values, the actual readings need to be recorded. If the exposure rate exceeds 10 mR/hr at one meter from the package or 200 mR/hr at the surface of the package, contact the RSO immediately. 6.6.4.3 Verify the type and quantity of radioactive material received as recorded on the vial against the packing slip and the purchase requisition 6.6.4.4 Check the package for contamination using a swipe test as follows: 6.6.4.4.1 The liquid scintillation counter is the preferred method of counting wipes for removable contamination. A GM survey meter will not detect 3H and the detection efficiency of the LSC for all nuclides typically found in the laboratory is higher than that of the GM survey meter. The GM should be used only if a liquid scintillation counter is not available. Wipe the exterior of the package with a filter paper or a piece of tissue, wiping an area of at least 300 cm2. Wipe the exterior of the pig and the primary vial each with a separate filter paper or a piece of tissue. The Minimum Detectable Activity (MDA) is an indication of the minimum level of contamination that a counting system can practically measure above background. At least two “blanks” should be counted to determine the background count rate. A “blank” is defined as a LSC vial with an unused tissue swipe filled with the LSC cocktail. The MDA must be calculated and entered on the receipt form. The package is then surveyed, with the results entered on the receipt form. The MDA for removable surface activity can be approximated by: ( ) √ where: MDA = activity level in disintegrations/minute B = average background counts t = counting time in minutes for sample and background counts E = detector efficiency in counts/disintegration Compare the wipe activity with the MDA. If the net wipe activity (dpm), as calculated below, is less than the calculated MDA for Radiation Safety Manual 12 that system, indicate as such by entering “< MDA” in the blank provided for the contamination level on the surface of the package. If the sample activity is greater than the MDA, indicate the calculated wipe activity. ( ) ( ) ( ( ⁄ ) ) NOTE: if none of the sample results from the LSC are greater than the average of the background samples, then the activity of “<MDA” may be used without the need to perform the above calculation as results below background will be below MDA. 6.6.5 6.6.6 6.6.7 The PI or designee is responsible for establishing the efficiency of the LSC for the nuclide in question. Contact the EHSD for assistance, if necessary. 6.6.4.5 WRITE THE INVENTORY NUMBER PROVIDED ON THE APPROVED ORDER FORM ON THE PIG AND THE PRIMARY VIAL WITH A PERMANENT PEN. If you do not have or cannot find the inventory number, contact the RSO for a copy. 6.6.4.6 Prepare an Isotope Tracking Form 6.6.4.7 Fax a copy of the Radioactive Materials Package Survey Form to the RSO at 979-436-0082 The box in which the material was shipped in may be discarded as non-radioactive waste as long as the PI ensures that the box is not contaminated (by performing and documenting a contamination survey) and obliterates any radioactive signs or symbols. 6.6.5.1 The signs and symbols can be obliterated by covering them with duct tape, destroying them by scraping them, or marking them out with a black marker. The container may then be discarded as normal non-radioactive solid waste. All material used during the package check-in procedure (gloves, wipes, etc.) should be considered contaminated and discarded in a radioactive waste container. Some vendors participate in a Styrofoam container recycling program. It is a requirement of the vendor as well as EHS that a survey of the container for removable contamination be performed and documented before the Styrofoam package is sent back to the vendor. Any questions regarding this procedure may be directed to the RSO at 979-436-0551 6.7 Package Acceptance Supplemental Information Figure 1 - White 1 Label Radiation Safety Manual Figure 2 - Yellow 2 Label 13 Figure 3 - Yellow 3 Label Radioactive Material Labeling Criteria (49CFR 172.403) External Dose rate @ 1 meter (mR/hour) ≤ background ≤1 >1 External Dose rate on contact (mR/hour) ≤ 0.5 0.5 < Dose rate ≤ 50 > 50 Label (shown above) White 1 Yellow 2 Yellow 3 6.8 Average LSC Efficiencies Isotope Tritium (3H) Carbon-14 (14C) Phosphorus-32 (32P) Phosphorus-33 (32P) Sulfur-35 Calcium-45 Iodine-125 Iodine-131 Radiation Safety Manual Type of Radiation Energy (MeV) 0.0186 0.157 1.709 0.249 0.167 0.258 0.032 0.035 0.606 0.364 LSC Efficiency 40% 85% 95% 85% 85% 90% 20% n/a 95% n/a 14 Section 7. Transferring Radioactive Material 7.1 Introduction Radioactive materials shall not be transferred to or from anyone else, within or without the HSC, without prior notification of and approval by the RSO. This approval can be obtained by telephone. Four (4) transfer situations are identified: 7.1.1 7.1.2 7.1.3 7.1.4 Transfers within HSC of entire source vial Transfers within HSC of activity less than the entire source vial Transfers from HSC to another institution. Transfers from off campus to HSC 7.2 Transfer Within the HSC A PI may transfer a source vial of radioactive materials to another PI user provided that the: 7.2.1 7.2.2 7.2.3 Recipient is authorized for the isotope and activity involved. RSO is notified prior to the transfer. RSO will generate a new inventory form for the recipient. Transferring user records the transfer on his/her inventory form 7.3 Multiple Transfers Transfers of less than full vial quantities are also allowed provided that the following provision are met: 7.3.1 7.3.2 7.3.3 Prior permission has been given by the RSO. Transfers are noted on a "Multiple Transfer Form". An entry is made on the “Isotope Tracking Form" in the lab which is supplying the RAM Limits of the Receiving PI are not exceeded 7.4 Transfer to HSC from Off-Campus The PI who will receive the radioactive material will: 7.4.1 7.4.2 7.4.3 Inform RSO of what they intend to have transferred Remind the sender to contact his own Radiation EHS for further instructions Provide RSO with the name and telephone number of the sender's EHS 7.5 Transfer from HSC to Off-Campus The sender (HSC Principal Investigator) shall: 7.5.1 7.5.2 Notify the RSO at least five (5) days before the transfer date Provide the RSO with the name and telephone number of the recipient. The RSO will make arrangements for actual transportation to the recipient The RSO shall: 7.5.3 7.5.4 Provide assistance in preparing the radioactive material for shipment (i.e., packaging, labeling and documentation) Contact the recipients EHS to obtain a copy of that institution’s license and further shipping instructions Radiation Safety Manual 15 Section 8. Training Requirements for Personnel Working with Radioactive Materials 8.1 Introduction Appropriate training for all individuals who work with or in the vicinity of radioactive material is an essential part of any radiation safety program. This includes all individuals who work with radioactive materials at HSC laboratories, regardless of employment classification (e.g., faculty member, post-doctoral fellow, graduate student, research associate, laboratory technical assistant). The HSC has an obligation to its employees and students to provide them with: 8.1.1 8.1.2 8.1.3 a safe working environment an awareness of the hazards to which they may be exposed training in methods to protect themselves against those hazards This training is required by the Texas Regulations for Control of Radiation (TRCR). It must be a joint effort between the RSO and the individuals authorized to use radioactive material 8.2 HSC Instruction In order to ensure that adequate training is obtained, the HSC EHS shall establish and administer a use and safety course tailored to the potential exposure environments present with use of radioactive materials (RAM) on the HSC campus. All individuals who work with radioactive material must successfully complete the course prior to commencement of their work with RAM. Successful completion of this course is a requisite for working with RAM at the HSC. The radiation safety course shall include the following topics: 8.2.1 8.2.2 8.2.3 8.2.4 8.2.5 8.2.6 8.2.7 Introduction to RAM Instruction on the hazards presented when working with RAM and how to use them safely. Instruction on the proper use and maintenance (as appropriate) of the radiation detection equipment Emergency procedures An exam meant to ensure all persons with access to RAM can demonstrate mastery of the course materials. The exam must be passed with a grade of no less than 70% as graded and determined by EHS. It is the sole discretion of EHS to grant a passing grade, and it is the sole discretion of EHS to accept appeals in regards to a failing grade. A biennial refresher will be required of individuals desiring continued access to and use of the RAM. Failure to attend the biennial refresher training may result in access to and use of RAM being revoked. Access revocation is at the sole discretion of the RSC and access may be reinstated at the sole discretion of RSC. PIs are exempt from the initial radiation safety training by virtue of the TDSHS’ acceptance of their status as sub-licensees. PIs are still required to complete the refresher training. 8.3 Training Exemptions Exemptions to the training requirements above will be granted on an individual basis to: Radiation Safety Manual 16 8.3.1 8.3.2 8.3.3 8.3.4 8.3.5 Individuals who can provide a copy of a certificate or letter of completion for a course on radiation safety from another institution and who successfully pass the HSC EHS radiation safety training exam with a grade of 70% or higher Individuals currently holding a certification by NRRPT and who successfully pass the HSC EHS radiation safety training exam with a grade of 70% or higher At the sole discretion of EHS, an individual who has no safety violations on his/her record and is in need of taking the HSC EHS radiation safety training course or biennial refresher training course may be allowed to take the exam without attending the course as long as the test is passed with a grade of 70% or higher. Permitting the substitution of the test for the refresher training is at the sole discretion of EHS Individuals who have had comparable training but have no documentation may be granted an exemption upon passing the HSC EHS radiation safety training exam with a grade of 70% or higher All other exemptions will be determined on an individual basis by the RSO in conjunction with the Radiation Safety Committee 8.4 Note Prior to successful completion of the course, or receiving an exemption, individuals may work with radioactive material ONLY under the direct supervision and in the immediate physical presence of another individual who has been appropriately trained. This policy does not relieve Principal Investigators of their responsibility to provide laboratoryspecific training for personnel working in their laboratory. Failure to comply with this requirement may be construed as a permit violation on the PI’s RAM use permit as it creates a hazardous working environment for the untrained individual and all those around him or her. 8.5 Laboratory Specific Training The PI who is authorized to use radioactive material or appointee shall provide training to all individuals who will be working in the laboratory before the individual begins working in the laboratory. Each individual should know: 8.5.1 AREA RESTRICTIONS - where radioactive materials are to be used, and restrictions of use to include prohibited smoking, eating and drinking. 8.5.2 STORAGE - Location of material storage facilities and procedures for storage. 8.5.3 SIGNAGE - Proper posting of signs, labels and notices. 8.5.4 PERSONNEL MONITORING - The requirement of personnel monitoring including radiation dosimetry and bioassays. 8.5.5 MATERIAL USAGE - Explanation of the research and levels used in the labs and possible hazards from each type of RAM. 8.5.6 HANDLING - Special handling techniques to be used when handling RAM (e.g., the use of remote handling devices, working behind appropriate shields). 8.5.7 PROTECTIVE EQUIPMENT - Use of lab coats, eyewear, gloves, etc. 8.5.8 RECORD KEEPING - Material accountability and preparation of radioactive waste materials for disposal. 8.5.9 RESPONSIBILITIES - Responsibilities of the licensee and of the laboratory worker. 8.5.10 CONTAMINATION SURVEYS - The procedures and frequency for wipe tests. The use of survey instruments for checking radiation levels and checking for contamination. 8.5.11 EMERGENCY PROCEDURES - Procedures to follow in case of a spill or other accidents involving radioactive materials Radiation Safety Manual 17 8.6 Documentation All radiation safety-related training or education that employees receive, whether from the RSO or within the laboratory, shall be properly documented and maintained on file for review by the Radiation Safety Officer and the Texas Radiation Control Division. The RSO will provide assistance in design of Laboratory - Specific training programs upon request. Radiation Safety Manual 18 Section 9. Routine Laboratory Procedures 9.1 Introduction A set of written procedures is required for each laboratory or area where radioactive materials are used. These procedures must describe specific rules applicable to that area. The location of these procedures shall be known and accessible to all individuals who work in the area. The following general rules apply to all personnel who use radioactive material and should be incorporated into each laboratory's written procedures. 9.2 Signs and Notices Areas where radioactive materials are used must be posted in accordance with the Texas Regulations for Control of Radiation. The following signs will be conspicuously posted and replaced if defaced. 9.2.1 9.2.2 9.2.3 9.2.4 "Caution - Radioactive Materials" signs on all doors to laboratories and storage areas "Notice to Employees" BRC Form 203-1 "Document Locator " (indicates the location of the TRCR and related documents) "Emergency Procedures" 9.3 Personnel Protection For your health and safety it is imperative that you follow the rules concerning radioactive materials. If you have any questions about the following procedures, ask your supervisor or call the RSO. 9.3.1 9.3.2 9.3.3 9.3.4 9.3.5 When required by the RSO, wear whole body dosimeters and finger dosimeters Wear lab coats or other protective clothing as an outer garment at all times when working in the laboratory. Maintain good hygiene by: 9.3.3.1 keeping fingernails short and clean 9.3.3.2 washing hands and arms thoroughly before handling any object that goes into the mouth, nose or eyes. 9.3.3.3 not handling radioactive material if there is a break in the skin below the wrist or by wearing 2 pairs of gloves when handling the material. Label permanent areas used for radioactive work (including equipment) with "Caution Radioactive Material" signs. Do not eat, drink, smoke or apply cosmetics in work areas where radioactive material is used or stored. 9.4 Storage of Radioactive Materials 9.4.1 Keep radioactive material in a leak-proof container 9.4.2 Label all radioactive material containers with an appropriate label stating: 9.4.2.1 the radionuclide 9.4.2.2 the amount of activity 9.4.2.3 the date 9.4.3 Label refrigerators or freezers with a "Caution - Radioactive Material" sign and do not store food or beverages for human consumption in them. 9.4.4 Secure and lock storage areas when materials are left unattended. 9.5 Handling of Radioactive Materials 9.5.1 Disposable gloves shall be worn when handling unsealed radioactive materials. In some uses, remote handling devices may be required by the RSO. Radiation Safety Manual 19 9.5.2 9.5.3 9.5.4 9.5.5 9.5.6 9.5.7 9.5.8 Never pipette radioactive materials (or any other materials while working with radioactive material) by mouth. Use absorbent padding or other material in areas where radioactive material is handled. Perform iodinations and use volatile radioactive material only in a fume hood specifically approved for such use by the RSO. When transporting radioactive material between labs, place primary container in a secondary container (large beaker, pan, etc.) to help contain the material in the event of a spill. Be sure to use appropriate shielding as needed. When transporting between floors, use the service elevator. When transporting several containers of radioactive materials, use a cart instead of carrying. All tools or other lab implements used with radioactive materials shall be considered contaminated, labeled as such, and reserved for exclusive use with radioactive materials until such time as they are either decontaminated and released for unrestricted use or disposed of as waste in accordance with all applicable policies. 9.6 Surveys Laboratory personnel will routinely survey the laboratory for contamination. See section entitled "Guidelines for Area Contamination Surveys" 9.7 Bioassays Laboratory personnel must comply with the policies of EHS and the Radiation Safety Committee for bioassays or other personnel surveillance operations. (See Section 12.2 below). 9.8 Radioactive Materials Waste 9.8.1 Place radioactive waste only in specially marked receptacles. 9.8.2 For further information on disposal, refer to "Disposal of Radioactive Material". 9.9 Incident Reporting Notify the RSO immediately by telephone of all incidents involving: 9.9.1 Radioactive contamination (external or internal) of personnel 9.9.2 Radioactive contamination of a large area or that you are unable to manage with the resources readily available to you 9.9.3 Release to the environment of radioactive material 9.9.4 Loss of radioactive material (including radioactive waste) 9.9.5 Known or suspected excess radiation exposure to general public or lab personnel 9.10 Equipment Repair Notify the EHS prior to the repair or removal of any equipment that may be contaminated with radioactive material or that contains a source of radiation Radiation Safety Manual 20 Section 10. Requirements for Posting/Labeling Labs Using Radioactive Material 10.1. Radioactive Material Areas: Posting and Labeling 10.1.1. A sign or label with the words “CAUTION-RADIOACTIVE MATERIAL” shall be placed on each door, refrigerator, or storage locker where radioactive materials are used or stored. The sign or label will also be affixed to storage and waste containers, contaminated waste cans, hot sinks, hoods, and work areas. In the event multiple nuclides are present, the “sum of the ratios” shall not exceed a value of 1. The reporting levels of the most commonly used radionuclides are provided in the table below. Nuclide H-3 C-14 P-32 S-35 I-125 Amount requiring posting 10 mCi 10 mCi 100 µCi 1 mCi 10 µCi Table 1 - Activity Posting Requirements 10.1.2. Laboratory equipment and containers, including beakers, flasks and test tubes, pipetters, centrifuges, and so forth, shall be labeled with a radiation symbol. 10.1.3. Containers holding radioactive materials must be labeled with the radiation symbol, the words “Caution, Radioactive Materials,” and the isotope(s) and activity contained within. 10.1.4. Exemptions to these labeling rules include: 10.1.4.1. containers when they are in transport and packaged and labeled in accordance with the regulations of the U.S. Department of Transportation. 10.2. Empty Containers Empty containers that are free of contamination and are to be discarded must have all radioactive materials labels, all radiation symbols, and all markings related to radiation or radioactive materials removed prior to disposal. If this is not possible, Radiation Safety should be contacted for assistance. 10.3. Other Postings Other postings shall be established as required by the RSO to mark radiation areas, high-radiation areas, airborne radioactivity areas, and/or controlled surface contamination areas (CSCA). A CSCA is any area in which loose surface contamination levels exceed 1000 dpm/100 cm. Access to controlled surface contamination areas shall be restricted by a physical barrier posted with a sign noting “Controlled Surface Contamination Area, Do Not Enter.” 10.4. Misuse of Caution Signs Labels and signs required in this section shall not be used for any purpose other than to warn against a radiation hazard. Radiation Safety Manual 21 Section 11. Additional Precautions for Users of Radioiodine, Phosphorus32, and Sulfur-35 11.1 Radioiodine (125I) Iodine-125 (125I) is one of the isotopes of iodine used in biological research. It is a gamma emitter and also emits low energy electrons. This isotope is of special concern because the body concentrates iodine - approximately 30% of the total free iodine in the body - in one small organ, the thyroid gland. The biological residence time for stable iodine in the thyroid is approximately 100 days. With a physical half-life of 60 days, a significant fraction of the energy of these isotopes could be delivered to thyroid tissue before appreciable excretion occurs. The following special techniques and procedures are recommended to help control exposure to radiation from 125I: 11.1.1 Free iodine in solution has a very high vapor pressure. In solutions of pH 11 or greater containing iodine, iodine is always present in the air above the solution. Acidic solutions actually drive the iodine out of solution and into vapor. Elemental iodine sublimes to vapor readily and free iodine is easily taken into the body by inhalation or absorption through the skin. A chemical technique that produces free iodine as a reaction by-product is therefore extremely hazardous. Among such techniques are iodine-labeling reactions using solutions of sodium iodide at the millicurie level. 11.1.2 Users of radioiodine should receive specialized training particularly oriented towards the hazards posed by this radioisotope. 11.1.3 Open radioiodine vials in an operating fume hood and inspect the container(s) before placement in storage. Many of the chemical forms of radioiodine as shipped are volatile, and breakage during shipment and release of vapors upon opening can present a serious hazard. 11.1.4 Opening a vial of radioiodine can result in the release of a significant quantity of iodine vapor. Try to control this by obtaining radioiodine stocks in vials with needle septa. Withdrawals can be made using a microsyringe and needle. 11.1.5 Additions can be done by piercing the septum with a vent needle and adding reagents through the septum with a second needle. If it is necessary to open the stock container, first purge the air above the solution by forcing it through an activated charcoal trap (this can be a syringe barrel fitted with a needle and filled with activated charcoal.) 11.1.6 Wear disposable gloves (double gloves are advisable) and change them frequently. Some forms of iodine can penetrate the glove if they remain in prolonged contact. Monitor and change outer gloves frequently. 11.1.7 Shield experimental set-ups and waste using sheet lead and lead glass. Also use shielding to prevent eye and face exposure 11.1.8 Direct handling of high-level sources is discouraged. Use forceps, tongs, or other remote handling equipment. 11.1.9 If required by the RSO, wear a whole body TLD (personnel monitor) and extremity badge. 11.1.10 Submit to thyroid bioassays as required by the Radiation EHS (see Section 10.1.1 above for Requirements and Section 12.2 of this manual for Bioassay Requirements and Procedures) 11.1.10.1 If quantities of I-125 equal to or greater than 10mCi are ordered by any PI, EHS will conduct weekly thyroid bioassays of the PI and Authorized Users unless a procedure schedule is provided to EHS by the responsible PI. The procedure schedule shall provide the dates on which I-125 will be used to allow for pre and post procedure bioassays. Radiation Safety Manual 22 11.1.11 Monitor hands, clothing, shoes, and work area after completion of work with radioiodine. The recommended instrument for 125I is a thin-window sodium iodide crystal probe sensitive to low energy gamma rays or a large volume GM detector such as a Ludlum model 44-7 or similar. The unit must be at the workstation and turned on during all use of radioiodine. If any significant contamination is detected during contamination surveys, clean the area with appropriate decontamination solutions (e.g., sodium thiosulfate solution). Contact the Radiation EHS for any instance of human contamination. 11.1.12 Store waste radioiodine in the fume hood, taking care not to disrupt airflow in the hood. Use deep plastic tubs to contain any spills. Keep the pH of waste liquids between 8 and 11. Seal solid wastes in plastic bags to reduce release of vapors to the environment. 11.2 Phosphorus-32 (32P) The use of phosporus-32 (32P) and other high energy beta emitters in research protocols requires that special precautions be taken. 32P decays with the emission of 1.7 MeV betas which are sufficiently energetic to penetrate the outer layers of skin and expose living tissues; it can also penetrate the eye to expose the retina. In order to avoid unnecessary radiation exposure in work with 32P, the following maxims are established: 11.2.1 Open and inspect all shipments of 32P in a radioisotope hood before placing the container(s) into storage. 11.2.2 Safety glasses or goggles also provide additional protection against beta radiation. This is important when quantities of one millicurie or more are in use. The incident dose to the eyes is reduced by one-half with plastic goggles. 11.2.3 Always wear gloves and eye protection when handling 32P. 11.2.4 Use forceps or tongs when handling 32P to reduce exposure of the extremities. 11.2.5 Wash hands in lukewarm water with detergent and survey hands after use. 11.2.6 Very high exposure rates are possible when handling high-specific activity solutions of 32 P. The surface dose rate for 1 mCi in 1 ml is 780 rad/hr, which creates the potential for an excessive and unnecessary radiation dose to the hands and face when handling uncovered vessels. Never place your hand or any other part of your body over open, unshielded containers containing large quantities of high – specific activity radioisotope. 11.2.7 Store stock solution in or behind appropriate beta particle shielding which minimizes production of bremsstrahlung radiation. Place low-density materials, such as lucite or plexiglas, close to or surrounding the source followed by lead or iron as necessary. 11.2.8 Use working shields of lucite or plexiglas 1 cm thick. Be certain the shield is tall enough to protect the face and eyes. If the procedure or apparatus permits, placing a shield close to the source can minimize the size of the shield. 11.2.9 If required by the Radiation Safety Officer, wear a whole body TLD (personnel monitor) and extremity badge 11.2.10 Monitor hands, clothing, shoes, and work area after completion of work with 32P. The recommended instrument for 32P is a Geiger-Mueller survey meter with an end- window or pancake probe. The unit must be at the workstation and turned on during all use of 32P. 11.2.11 Take special care to avoid producing aerosols during operations such as centrifuging, etc. 11.3 Sulfur-35 (35S) Radioactive sulfur-35 amino acid compounds (e.g., 35S -labeled methionine) are commonly used in cell biology research. Protein labeling techniques employing 35S have been found to produce airborne radioactive contamination in laboratory through the volatilization of 35S compounds from incubated cell cultures. The following remedial actions should be taken to minimize the amount of volatilization and contamination that can result from work with these compounds: Radiation Safety Manual 23 11.3.1 Whenever opening containers of 35S-labeled methionine, do so in an operating fume hood to avoid area and personnel contamination. Whenever possible, use fresh, highly purified 35 S compounds or methionine in cultures. In this way, the build-up of decomposition products will be minimized, which may be the cause of the volatilization. 11.3.2 Carefully monitor all work areas frequently, especially after handling open containers. Disposable gloves are mandatory when performing any work with these compounds. Radiation Safety Manual 24 Section 12. Personnel Monitoring 12.1 EXTERNAL MONITORING 12.1.1 Introduction The Texas Regulations for Control of Radiation (TRCR-TAC §289.202(q)) requires external monitoring for: 12.1.1.1 adults likely to receive a dose in excess of 500 mrem/year to the whole body or 1,500 mrem/year to the lens (eye) or 5000 mrem/year to any extremity (10% of the limits set forth in 10CFR20); or 12.1.1.2 minors and declared pregnant women likely to receive a dose in excess of 50 mrem/year and 50 mrem/9 months, respectively (10% of the limits set forth in 10CFR20); or 12.1.1.3 individuals entering a high radiation area (greater than 100 mrem/hour). HSC's Radiation Safety Officer will make the determination when monitors will be issued. A TLD badge request form must be completed and signed by the individual meeting the above criteria. Requests for personnel monitoring devices for special uses will be evaluated on an individual basis and the approval of the RSO will be required 12.1.2 Monitoring Devices 12.1.2.1 HSC uses a National Voluntary Laboratory Accreditation Program (NVLAP) certified dosimetry company to supply its personnel monitoring devices. 12.1.2.2 HSC employees requiring personal dosimetry (as determined by the RSO) shall at a minimum be issued a TLD or OSL type dosimeter. Other methods of personal dosimetry may also be worn, but never in place of the TLD or OSL. In the event that multiple badges or dose detection devices are worn, only the HSC issued TLD or OSL shall be considered the “dosimeter of record.” 12.1.2.3 Finger TLD badges will be issued at the discretion of the RSO. 12.1.3 Monitoring Reports All dosimeters and ring badges are processed by an off-site vendor. The exposure reports are sent to the RSO and reviewed by the RSO. Any exposures that exceed the maximum permissible limits or are much higher than average are discussed with the individual and the individual's supervisor and appropriate steps are taken to prevent reoccurrence. Any individual may receive a copy of his/her exposure history by requesting it in writing from the RSO. 12.1.4 Purpose The sole purpose of the dosimeter badge is to record a radiation exposure. IT DOES NOT PROTECT AGAINST RADIATION! 12.1.5 Proper Use and Care of Badges All dosimeters must be properly used and cared for in order to give an accurate reading. The following guidelines outline proper care: Radiation Safety Manual 25 For whole body badges: 12.1.5.1 Attach the badge near the collar of your upper garment (or at the waist) and wear at all times while in controlled areas. If you are wearing a lead apron, the badge should be worn at the collar outside the apron. 12.1.5.2 Leave the badge in a safe place when not being worn. Make sure it is away from all sources of radiation. Personnel dosimeters should not be taken out of the HSC. 12.1.5.3 Never wear a badge issued to another person or allow anyone else to wear yours. 12.1.5.4 Take care not to send the badge to the laundry with your lab coat or other clothing. 12.1.5.5 Make sure to return the badge at the proper time to exchange for a new one. This is your responsibility and may delay badge replacement, which could result in an interruption of your work with radiation if badging is required. 12.1.5.6 If you lose or damage your dosimeter, a replacement must be obtained from the RSO. A "Lost or Damaged Film Badge" report must be obtained from the RSO. Upon completion of this form, an exposure is assessed for the time period lost and added to your personal exposure history. 12.1.5.7 Report any other incident relative to the wearing of the badge (such as possible accidental exposure when the badge is not worn) to the Safety Office. 12.1.5.8 Do not wear your badge during any medical procedure that involves radiation or radioactive material in which you are the patient. Special considerations for ring badges: 12.1.5.9 Wear ring badges directly on your finger in contact with your skin and under any gloves or other personal protective equipment (PPE) to ensure the most accurate reading of the dose your tissue may have received. 12.2 BIOASSAY PROGRAM 12.2.1 Thyroid Bioassay Program 12.2.1.1 Introduction Because radioiodinated solutions and compounds undergo decomposition which may result in the volatilization of radioiodine, individuals working with these materials have a potential for accidental uptake of radioactive iodine. This bioassay program will enable the safety staff to determine an individual's radioiodine thyroid burden, so that a thyroid organ -dose can be determined for those who have had an uptake. In addition the program will monitor the effectiveness of isotope handling procedures. This program is designed to meet State and Federal Regulatory Agency requirements for bioassay of 125I. 12.2.1.2 Program Participation All individuals who handle unsealed quantities of 125I in excess of those listed in Table 1 and those individuals who work close enough to such handling that uptake is possible (within a few meters) shall participate in this bioassay program. The quantity limits in Table 1 apply to that amount handled either in a single usage or the total amount handled over a period of 3 consecutive months. It shall be the responsibility of the individual Principal Investigators to notify Radiation Safety Manual 26 the RSO of the names of those individuals working on his/her permit who require bioassay for radioiodine. Activity Handled in Unsealed Form Type of Operation Volatile or Dispersible Bound to Non-Volatile Agent 10mCi Processes in open room or 1 mCi bench, with possible escape of iodine from process Processes with possible 10mCi 100mCi escape of iodine carried out within a fume hood of adequate design, face velocity, and performance reliability. Processes carried out within 100 mCi 1000mCi gloveboxes, ordinarily closed, but with possible release of iodine from process and occasional exposure to contaminated box and box leakage. Table 2 - Activity Levels Above Which Bioassay for 125I is Necessary 12.2.2 Frequency Type of Bioassay Baseline or Preoperational Routine Diagnostic Emergency Postoperational Necessary when... How Often? beginning work with 125I in once, prior to beginning quantities necessitating work with radioiodine participation in the bioassay program working with quantities of radioiodine that necessitate participation in the bioassay program, to be done within 72 hours (but not less than 6 hours) of working with radioiodine an individual has exceeded as determined by the action levels Radiation Safety Officer there is a possibility that an each time it is suspected individual has received an that an uptake in excess of 0.5 individual has received an mCi, to be done as soon as excess possible following the uptake incident work with radioiodine is once, before the individual terminated, to be done leaves within three (3) days or 72 HSC hours (but not less than 6 hours) after discontinuing operations with radioiodine Table 3 - Frequency of Thyroid Bioassays After three (3) months of routine bioassays, the frequency of bioassay maybe reduced to quarterly, at the discretion of the Radiation Safety Officer. Radiation Safety Manual 27 12.2.2.1 Action Levels The thyroid burden at the time of measurement should not exceed: 0.12 µCi of 125I 12.2.2.2 Corresponding Actions 12.2.2.2.1 Whenever the thyroid burden at the time of measurement exceeds 0.12 µCi of 125I* the following actions will be taken: 12.2.2.2.1.1An investigation of isotope handling procedures shall be conducted. If this investigation indicates that a continuation of current operations would cause further uptake of radioiodine in excess of the above limits, operations using radioiodine in that lab shall be discontinued until corrective actions can be implemented that will lower the potential for uptake. 12.2.2.2.1.2The affected individual will be restricted from further work with radioiodine until the thyroid burden is less that the Action Level as described in Section 12.2.2.1 above. 12.2.2.2.1.3Diagnostic bioassays will be performed on the affected individual at biweekly intervals until the thyroid burden is less than the Action Levels. 12.2.2.2.1.4The committed thyroid dose shall be calculated based on biological half-life determined from follow up bioassays. 12.2.2.2.1.5Exposure record entries shall be made and TDSHS shall be notified as appropriate. 12.2.2.2.2 If the thyroid burden at any time exceeds 0.5 µCi of 125I, the following actions should be taken: 12.2.2.2.2.1Carry out all steps described above. 12.2.2.2.2.2Refer the case to appropriate medical consultation. 12.2.2.2.2.3Perform diagnostic bioassays at weekly intervals until the thyroid burden is less than 0.12 µCi of 125I. *Note: If the affected individual or others working in the same area are on a quarterly bioassay schedule at the time the action level is exceeded, reinstate the "routine" schedule until it can be demonstrated that further work with radioiodine will not cause the action level to be exceeded. 12.2.2.3 Bioassay Procedure 12.2.2.3.1 Prior to commencement of operations using quantities of 125I in excess of those listed in Table 1.0 in Section 12.2.1.2 above, Principal Investigators shall notify the RSO and provide the names of those individuals who meet the criteria detailed in Section 12.2.1.2 above. PIs shall not permit any individual who meets the criteria of Radiation Safety Manual 28 12.2.2.3.2 12.2.2.3.3 12.2.2.3.4 12.2.2.3.5 12.2.2.3.6 Section 12.2.1.2 to work with or near radioiodines until they have undergone a baseline bioassay. The RSO shall contact these individuals and schedule baseline bioassays at a time and place convenient to both parties. Individuals participating in this program shall notify the RSO following their initial contact with radioiodine to schedule the first routine bioassay (to be performed within 6-72 hours). Upon completion of this first bioassay, a bioassay schedule shall be established for the individual. Any individual involved in a radiological incident who may have exceeded the limits of Section 12.2.2.1 above, shall notify the RSO immediately. Any individual who is participating in this program shall notify the RSO prior to terminating employment with or otherwise leaving the HSC. Bioassays shall be performed by individuals designated by the Radiation Safety Officer. 12.2.3 Urinalysis Program 12.2.3.1 Introduction As many compounds used in laboratory research and tagged with a radionuclide other than radioiodine may be volatile, a bioassay program is in place to ensure that all laboratory personnel who work with certain quantities of any volatile substance are monitored and protected from overexposures. 12.2.3.2 Action Levels to Trigger Urinalysis Urinalysis will be required for all personnel who handle stock vials containing more than one Allowable Limit for Intake (ALI) of any volatile radionuclide or radionuclide attached to a volatile chemical. The table below describes the isotope-use limits requiring urinalysis. If isotope usage in a single application exceeds these limits, urinalysis will be required. Nuclide H-3 C-14 S-35 1 ALI 80 mCi 2 mCi 20 mCi Table 4 - Urinalysis Action Levels 12.3 12.2.3.3 Procedure If the Action Levels listed in Section 12.2.2.1 above are to be triggered, the RSO shall be notified. The RSO shall then arrange for the appropriate urinalysis process depending on the radionuclide to be used. 12.2.3.4 Verification Isotope use records will be reviewed by the RSO during inspections to ensure that bioassays are performed as required. HSC ADMINISTRATIVE DOSE LIMITS The HSC restricts the dose limits to a greater extent than those set forth in TAC§289.202(f)(1). This is to provide a higher degree of protection to those Radiation Workers who may be exposed during their employment at the HSC and follows the TDSHS mandate as part of an ALARA Radiation Safety Manual 29 program. The HSC RSO monitors the dose received by monitored personnel on a quarterly basis and, as such, the HSC administrative limits are measured quarterly. 12.3.1.1 Annual Limit The annual limit shall be the more limiting of: 12.3.1.1.1 Total Effective Dose Equivalent (TEDE) TAC§289.202(f)(1)(A)(i) The HSC limits TEDE to one third (1/3) of the prorated TEDE as defined in TAC§289.202(f)(1)(A)(i) resulting in an exposure not to exceed: 417 mrem/qtr 12.3.1.1.2 The Sum of the Single Organ Committed Dose Equivalent (CDE) and the Deep Dose Equivalent (DDE) TAC§289.202(f)(1)(A)(ii) The HSC limits CDE+DDE to one third (1/3) of the prorated CDE+DDE as defined in TAC§289.202(f)(1)(A)(ii) resulting in an exposure not to exceed: 4167 mrem/qtr 12.3.1.2 Other Annual Limits 12.3.1.2.1 Lens of the eye dose equivalent (EDE) TAC§289.202(f)(1)(B)(i) The HSC limits CDE+DDE to one third (1/3) of the prorated CDE+DDE as defined in TAC§289.202(f)(1)(A)(ii) resulting in an exposure not to exceed: 1250 mrem/qtr 12.3.1.3 Shallow dose equivalent to skin of extremity (SDE) TAC§289.202(f)(1)(B)(ii) The HSC limits CDE+DDE to one third (1/3) of the prorated CDE+DDE as defined in TAC§289.202(f)(1)(A)(ii) resulting in an exposure not to exceed: 4167 mrem/qtr Radiation Safety Manual 30 Section 13. Emergency Procedures 13.1 SPILLS PROCEDURE 13.1.1 Introduction During the course or routine operations, radioactive material may be spilled, causing contamination of lab areas, personnel, or equipment. Correct action taken during such an emergency can prevent further spread of the contamination. 13.1.2 Written Instructions A set of written procedures describing the specific steps to be taken in the event of a spill of radioactive material shall be posted in a prominent location in each laboratory or area where radioactive materials are stored or used. The procedures shall be established on an individual basis applicable to the particular area, according to the type and quantity of material used. They should include: 13.1.2.1 13.1.2.2 13.1.2.3 specific location of radioactive waste containers specific type and location of survey meters emergency telephone numbers 13.1.3 Minor Spills A minor spill shall be defined as one that results in contamination of small areas of laboratory surfaces or equipment, but do not result in: 13.1.3.1 13.1.3.2 13.1.3.3 external or internal contamination of personnel excessive external radiation exposure to personnel serious delay in work procedures The following steps should be taken in case of minor spills: STEP 1 2 3 4 5 PROCEDURE Notify all persons in the area that a spill has occurred. Cover the spill with absorbent paper Using disposable gloves carefully fold the absorbent paper and pad, insert it in a plastic bag and dispose of it in a radioactive waste container along with all contaminated material such as disposable gloves. After removing PPE to avoid contaminating the meter, use an end-window GM survey meter, check the area around the spill, and your hands and clothing for contamination. Perform follow-up wipe tests and decontaminate as necessary. Report the incident to EHS. Table 5 - Procedure for Minor Spills 13.1.4 Major Spills MAJOR SPILLS may result in any or all of the following: 13.1.4.1 13.1.4.2 Radiation Safety Manual contamination of large surface areas internal or external contamination of personnel 31 13.1.4.3 13.1.4.4 excessive external radiation exposure to personnel serious delay in work procedure The following steps should be taken in case of major spills: STEP 1 2 3 4 5 PROCEDURE Notify all persons not involved in the spill to vacate the room Cover the spill with absorbent pads, but do not attempt to clean it up. Confine the movement of all potentially contaminated personnel to prevent the further spread of contamination. Prevent personnel from entering the contaminated area. If possible, return stock vials to their shields, but only if it can be done without further contamination or without significantly increasing your radiation exposure. Notify EHS. Remove and store contaminated clothing for further evaluation by EHS. If the spill is on the skin, flush thoroughly and wash with mild soap and lukewarm water. Table 6 - Procedures for Major Spills 13.2 EMERGENCY WEATHER PROCEDURES 13.2.1 Introduction High water flooding and hurricane force winds can cause damage to laboratories that could result in spread of radioactive contamination. This emergency procedure is designed to minimize the potential for the spread of contamination. The specific response will depend upon the existing and expected weather conditions. 13.2.2 Pre-Planning Emergency weather preparedness begins long before the threat of inclement weather exists. The following measures will make it easier to prepare the lab should the emergency weather plan actually be implemented. 13.2.2.1 Dispose of used and/or decayed radioactive materials to keep the RAM inventory in the lab at a minimum. Dispose of old materials in storage. 13.2.2.2 Do not allow radioactive waste to accumulate in your lab 13.2.2.3 If the lab has outside windows, identify secure areas within the lab for storage, such as: 13.2.2.3.1 refrigerators 13.2.2.3.2 storage cabinets with doors 13.2.2.3.3 storage closets 13.2.2.3.4 rooms not susceptible to damage from high winds or flying debris (interior rooms) 13.2.2.4 Ensure that emergency telephone numbers posted in the lab are current and updated as necessary. 13.2.2.5 Keep plastic or other waterproof containers on hand to store your materials. 13.2.2.6 Keep a supply of "Radioactive" tape or labels at hand. 13.2.3 Emergency Actions In the event of a weather emergency, the following minimum action should be taken: Radiation Safety Manual 32 13.2.3.1 For Areas Susceptible to Damage from High Winds (Labs with windows) 13.2.3.1.1 If possible, place radioactive materials, in water-proof or plastic containers. 13.2.3.1.2 Securely close all radioactive material containers so that they will not lose their contents should they be upset or overturned. 13.2.3.1.3 Clearly mark all radioactive material containers as "Radioactive" and note their contents (radionuclide, activity, and inventory number) 13.2.3.1.4 Move radioactive materials and wastes into secure locations, such as: 13.2.3.1.4.1refrigerators 13.2.3.1.4.2storage cabinets with doors 13.2.3.1.4.3storage closets 13.2.3.1.4.4rooms not susceptible to damage from high winds or flying debris 13.2.3.1.5 Tape all storage cabinets closed that hold radioactive materials stored in containers that do not have secure latches. 13.2.3.1.6 Close all radioactive waste containers and move them off of the floor to a shelf or cabinet. 13.2.3.1.7 Verify that no radioactive material has been left out on an open lab bench. 13.2.3.1.8 Label all storage locations not already so marked with "Caution Radioactive Material" labels 13.2.3.1.8.1Labels on temporary storage locations must be removed after the radioactive materials are returned to their normal location 13.2.3.1.9 Lock all areas where radioactive materials are stored (e.g., laboratory doors, refrigerators, etc.) Radiation Safety Manual 33 Section 14. Guidelines for Area Contamination Surveys 14.1 Frequency of Surveys The required frequency for area surveys depends on the frequency of radionuclide use. 14.1.1 Weekly: 14.1.1.1 Areas where radioactive materials are used in activities greater than 10 mCi (i.e., use of RAM in activities of 10 mCi from a single source vial or use of multiple source vials from which 10 mCi has been used.) 14.1.2 Bi-Weekly: 14.1.2.1 Areas where radioactive materials are used in activities ranging from 5 mCi to less than 10 mCi (i.e., use of RAM in activities in the defined range from a single source vial or use of multiple source vials, the activity of which is within the range defined). 14.1.3 Monthly: 14.1.3.1 Areas where radioactive materials are used in activities less than 5 mCi (i.e., use of RAM in activities of 5 mCi from a single source vial or use of multiple source vials from which 5 mCi has been used.) For the purposes of this section, “use of RAM” shall be defined as each PI’s total inventory of that radionuclide. All non-use periods between these required surveys and wipe tests must be documented. RAM storage areas will be surveyed and wipe tested at least monthly even if no actual use occurs. 14.2 The Principle Investigator is responsible for seeing that the required surveys are performed according to the frequency described above. However, this does not relieve the Authorized Users from performing surveys after each use of RAM. These surveys include: 14.2.1 checking all work surfaces and equipment used 14.2.2 gloves and other personal protection equipment 14.2.3 any other area or objects that may have come into contact with the RAM during the procedure EHS will perform quarterly surveys during the Compliance Audit of the laboratory. 14.3 Using Survey Instruments The purpose of survey instruments is to reveal the presence of otherwise undetectable loose or fixed contamination and also to measure general area radiation levels to ensure that they are not excessive. The use of a survey instrument for contamination survey does not eliminate the requirement to perform scheduled wipe tests, but should be used to ensure that contamination is not present in other areas of the laboratory, on personnel or equipment. A survey instrument should be available in any laboratory where radioactive material is used in quantities sufficient to produce significant radiation levels or contamination. As a general rule, a survey instrument should be available if the quantities used exceed 100 µCi (except for weak beta emitters such as tritium). Survey instruments are purchased by the Principal Investigator. They are not provided by the RSO. The RSO does have information on different makes of instruments and will consult with the PI On the purchase of the best instrument for their lab). Radiation Safety Manual 34 14.4 Instrument Calibration EHS requires that all survey meters in all labs on any HSC campus or annex must be calibrated on an annual basis. Verifying calibration is part of the EHS lab inspection and an out of calibration survey meter is considered a violation of EHS radiation safety rules. 14.5 Instrument Selection Instrument selection should be based on the following criteria: 14.5.1 Survey instruments should normally be of the Geiger-Mueller (GM) type. 14.5.2 Survey instruments should be lightweight, readily portable, and easily handled by laboratory personnel. 14.5.3 The instrument should be simple to operate and the scale should read in counts per minute (CPM). 14.5.3.1 GM type survey meters are not capable of accurately reporting a dose rate value based on the physics of the detector equipment. If any GM tube has a faceplate that reads out in both CPM and any other exposure or dose rate* unit, the CPM scale is the only scale that may be recorded and used. 14.5.3.2 Any GM type survey meter’s faceplate that only reads in a unit of exposure or dose rate should be sent to the manufacturer to have the faceplate updated to only refer to CPM. 14.5.3.3 The ONLY GM type survey meters permitted by EHS to report in a unit of exposure or dose rate are specifically referred to as Energy Compensated (EC) GM tubes and have been specially designed to account for the physics of detecting accurate exposure and dose values. 14.5.4 The Geiger-Mueller detector should be a thin-window type to permit detection of surface contamination by such low-energy emitters as carbon-14 and sulfur-35. If iodine-125 is used, a low energy gamma detection probe must be available during isotope use. 14.5.5 Instrument should be regularly calibrated by a vendor approved by EHS to do so. 14.5.6 Even though a laboratory may be working with only one radionuclide, a nuclide-specific instrument should not be obtained unless the Principal Investigator knows with certainty that no other nuclides will be added at a later date. This consideration is important in order to reduce subsequent cost factors for purchase of new equipment. 14.5.6.1 If additional nuclides are requested at a later date for which the nuclidespecific instrument is not effective, EHS will require the PI purchase an appropriate meter before any of the requested nuclide will be delivered regardless of the ordering or delivery status of that nuclide. *Note: examples units of exposure or dose rate are as follows: mSv/hr, µSv/hr, mGy/hr, rad/hr, µrem/hr, µR/hr, and others. 14.6 Instructions for Conducting Contamination Survey Surveys for contamination using a G-M survey meter should be conducted in the following manner. (This procedure is for gross amounts of contamination only, and as such will only provide a qualitative determination of the presence of contamination. It is not a substitute for wipe tests.): STEP 1 2 Radiation Safety Manual PROCEDURE Turn survey instrument on away from the area of use or to be surveyed, check for proper operation and obtain a background reading. Select several radioactive material work areas in the laboratory and several areas where work with radioactive 35 3 4 5 materials does not occur, but where contamination might be spread. Move the probe very slowly over the surfaces to be checked. The probe should be perpendicular to and within 1/4" of the surface If the instrument meter reading is twice background, contamination is present Decontaminate and perform follow-up survey. Table 7 - Procedures for Contamination Survey 14.7 Important Note Significant meter readings after decontamination and negative wipe tests may indicate fixed contamination. PLEASE CONTACT THE RSO IMMEDIATELY FOR ASSISTANCE 14.8 Area wipe tests should be conducted in the following manner: STEP 1 2 3 4 5 6 PROCEDURE Put on disposable gloves if you are handling potentially contaminated items or if you are directly handling the wipe medium. Note: If you suspect contamination on the floor, wear shoe covers also. Using filter paper, cotton tipped applicator or other suitable wipe medium, wipe an area of 100 cm2 of a large surface. (Wipe an entire surface if only a small item is being tested.) Code the wipes or the counting vials and survey map for identification of the area wiped. Count the wipes in an appropriate counter for one minute each. (If the same wipe is to be counted for gamma radiation in a sodium iodide counter and beta radiation in a liquid scintillation counter, be sure to do the gamma count before adding the liquid scintillation cocktail.) Convert counts per minute (cpm) to dpm. Record this information and retain it for inspections. Table 8 - Procedures for Wipe Tests 14.9 Contamination Action Levels If wipes indicate 200 dpm/100 cm2 or greater above background, the area wiped shall be considered contaminated. Decontaminate, re-wipe and determine new contaminated level. Repeat this cycle until wipes indicate less than 200 dpm/cm2. Record these data. Radiation Safety Manual 36 Section 15. 15.1 Disposal of Radioactive Materials Introduction Each Principal Investigator is responsible for ensuring that the material under his/her permit is disposed of properly. All radioactive material waste is removed from the laboratory by the RSO or EHS. Unless approved in writing by the Institutional RSO, only EHS may dispose of radioactive waste or remove it from HSC premises. 15.2 Signs and Notices The RSO is responsible for the removal from the laboratory, storage and ultimate disposal of all wastes contaminated with radioactive materials. For assistance in matters relating to waste disposal, contact the RSO during normal working hours, 8:00 a.m. to 5:00 p.m., on weekdays. To schedule a pickup of waste, call the RSO. 15.3 Principle Investigator Responsibilities The Principal Investigator is required to implement effective radioactive waste management procedures within the laboratory. Specifically, the PI shall: 15.3.1 Provide adequate and properly labeled receptacles for each type of radioactive waste described in the following sections. 15.3.2 Ensure that radioactive wastes are placed in these assigned receptacles, and are not disposed of as ordinary wastes. You must report any such incidents or improper waste disposal to the EHS immediately upon discovery. 15.3.3 Maintain written records of the activity of all wastes on the appropriate forms 15.3.4 Assure that radioactive waste is not allowed to be stockpiled in the lab, either in the designated waste storage area, or in any other areas used for temporary storage (e.g., fumehoods). 15.3.5 Designate an area of the lab to be used as a waste area using the following guidelines: 15.3.5.1 Located away from heavy traffic or constantly used areas 15.3.5.2 Large enough to allow for shielding if necessary. High energy beta and gamma emitters must be stored behind the appropriate shielding material to minimize the external exposure to lab personnel. 15.3.5.3 Allows for containment of liquid waste in the event of a spill or failure of the plastic carboy. As the generator of radioactive waste materials, laboratory personnel have first-hand knowledge of waste content. Consequently, laboratory personnel have full responsibility for all handling requirements and documentation associated with it. 15.4 Hazard Reduction Radioactive waste containing chemical, biological, or infectious material must be treated to reduce the potential hazard from non-radiological materials to the maximum extent practicable. The goal is twofold: 15.4.1 to minimize the hazards for those persons who handle the waste at each step of the disposal process. 15.4.2 to minimize the potential impact on the environment. Accordingly, EHS requires the following: Radiation Safety Manual 37 15.4.3 Adjust the pH of all aqueous radioactive waste as close to neutral as possible. For aqueous waste containing 125I the pH shall be between 7 and 9. If necessary, solutions should be buffered to maintain this pH. 15.4.4 Autoclave or chemically treat pathogenic and infectious material. Do not autoclave if radioactive contamination will be spread as a result. Discuss with the EHS Staff prior to taking any such steps. 15.4.5 If practical, treat carcinogens, teratogens, and other highly toxic materials to reduce their impact on the environment. 15.4.6 Package syringe needles and other sharp objects so as to prevent injury to those handling the waste. 15.5 Segregation of Waste All radioactive waste (with the following exception) must be segregated according to isotope. Only Tritium (3H) and Carbon-14 (14C) can be placed in the same container; all other isotopes must be placed in separate containers. In addition to segregation by isotope, radioactive waste must also be separated by physical form. Five (5) basic physical forms of radioactive waste are identified: 15.5.1 Dry and Semi-Solid 15.5.2 Sharps 15.5.2.1 Metal sharps and glass 15.5.2.2 Plastic pipette tips 15.5.3 Liquid 15.5.4 Scintillation Vials 15.5.5 Biological The following disposal guidelines apply to the six types of radioactive waste forms listed. For radioactive wastes not adequately or properly described by one of these categories, contact EHS. 15.6 Dry and Semisolid Waste Disposal This category will likely comprise the majority of the waste generated. It is comprised of most disposable items, as well as labware that has been contaminated with radioactive materials (e.g., absorbent work surface coverings; plastic/rubber gloves, tubing, unbroken glassware, etc.). Container for disposal: 15.6.1 Plastic bags. These bags must be placed in closeable waste receptacles (e.g., plastic foot operated trash can). PIs must obtain their own receptacles. Requirements for safe handling and disposal of this type of waste are: 15.6.2 Exercise extreme care when handling radioactive wastes in any quantity. 15.6.3 Attach a completed waste tag to all bags. The bag must be sealed and all accompanying forms completed before calling the EHS for removal. 15.6.4 Deface or remove all container labels and labware labels before placing into the waste containers. 15.6.5 Inspect the plastic waste bag for leaks prior to removal from the lab. Use a second bag to contain the waste if necessary. 15.6.6 Do take care not to place anything in the bag in such a way that may tear it. 15.6.7 DO NOT, under any circumstances, place radioactive waste where it might be picked up by housekeeping personnel and be disposed of as ordinary waste in the dumpster. 15.6.8 Waste receptacles must remain covered at all times. Radiation Safety Manual 38 Compliance Note: The primary users of radioactive material shall have the responsibility for the separation of short and long-lived isotopes. Regular monitoring of waste by the RSO will occur in the individual labs. 15.7 Sharps Sharps are defined as anything that could tear or puncture the bag (e.g., needles, broken glass, glass pipettes, plastic pipette tips, razor blades, capillary tubes, etc.) Containers for Disposal: 15.7.1 An approved sharps container as described by Office of Research Compliance policies with an appropriate lid. Requirements for safe handling and disposal of this type of radioactive waste are: 15.7.2 Care must be taken to not injure oneself during placement of sharps into box. 15.7.3 Do not try to overfill. 15.7.4 Do make sure that all sharps are dry before placing into container. Special rules for plastic pipette tips: 15.7.5 Plastic pipette tips may be disposed of into an RSO approved plastic container. 15.7.6 RSO approved container may be disposed of into the dry waste container as defined above. 15.8 Radioactive Liquid Waste The category of liquid waste can be further divided into: 15.8.1 Aqueous 15.8.1.1 15.8.2 Organic 15.8.2.1 Aqueous - Water-based liquids such as saline and buffer solutions and which contain no biological, pathogenic, or infectious materials. Washings from contaminated laboratory glassware, weak acids and/or bases, etc. Organic - Organic laboratory solvents such as alcohols, aldehydes, ketones and organic acids. Note: This category does not include scintillation fluids. 15.8.3 Other Liquids 15.8.3.1 Other Liquids - Contaminated pump oil, etc. 15.8.4 Containers for Disposal: 15.8.4.1 Specially designated containers (carboys) obtained from EHS. These carboys are not to be filled above the line marked on the carboy. DO NOT OVERFILL THESE CONTAINERS. 15.8.5 Requirements for safe handling and disposal of this type of radioactive waste are: 15.8.5.1 While the container is in the laboratory it must remain in a secondary container such as a spill tray as a precaution against leakage. This will control the spreading of the liquid in the event the carboy fails, and is also necessary as pouring can be accompanied by drips, or spills. 15.8.5.2 Do not use glass containers for storage of radioactive liquid waste. If plasticincompatible contaminated organic solvents are required to be kept in glass containers, the bottle must be doubled contained. Radiation Safety Manual 39 15.8.5.3 15.8.5.4 15.8.5.5 15.9 After emptying labware of radioactive liquid, the first rinse of the labware must also be placed in the radioactive liquid waste container. Successive rinses may be released to the sanitary sewer. 15.8.5.3.1 Secondary rinses of labware that would result in liquid waste that may be hazardous for reasons other than radioactivity, must be disposed of according to any rules and guidance that govern the same No radioactive liquid is permitted to be poured down the sink; sinks will be surveyed during inspections of the laboratories. Do not mix liquid waste types in the carboys (e.g., organic with aqueous). Adjust the pH of all aqueous radioactive waste as close to neutral as possible. For aqueous waste containing 125I, the pH shall be between 7 and 9. If necessary, solutions should be buffered to maintain this pH. Liquid Scintillation Vials Examples: Glass or plastic vials containing aqueous based liquid scintillation fluid. There are two types of scintillation vials: 15.9.1 Deregulated vials. 15.9.1.1 These are scintillation vials containing 3H, 14C and/or 125I only, containing less than 0.05 µCi/mL. Since liquid scintillation counting (LSC) normally can be successfully completed with activities below this level, LSC vials containing only 3H, 14C and/or 125I are generally deregulated. These vials are to be segregated from other LS vials and labeled "Deregulated" on Waste Form. 15.9.2 Other scintillation or LSC vials. 15.9.2.1 This includes vials with all other isotopes in them or vials containing 3H, 14C and/or 125I in greater than deregulated amounts. 15.9.3 Container for Disposal: 15.9.3.1 20 ml vials - must be emptied in the labs into a five (5) gallon plastic carboy and the vials must be disposed of separately in a box lined with double plastic bags. Place absorbent material with the vials to absorb residual liquids. Do not place the empty vials in the regular solid waste. 15.9.3.2 7 ml vials - The vials should be returned to the tray for disposal. Those individuals who order vials in bulk may place them in a box which is double-lined with plastic bags. Please do not overfill the bags as they can get quite heavy. Requirements for safe handling and disposal of this type of waste are: Under no circumstances should stock radioactive material vials be discarded with scintillation vials. Compliance Note: ONLY BIODEGRADABLE LIQUID SCINTILLATION FLUIDS ARE ALLOWED AT HSC. Contact EHS if you have any questions concerning your LS cocktails. 15.10 Biological Vials This category includes waste containing biological, pathogenic, or infectious material and the equipment used to handle such material (e.g., by-product animal waste: serum, blood, excreta; contaminated capillary tubes and other equipment contaminated with animal fluids, radioactive material labeled culture media.) Radiation Safety Manual 40 Container for Disposal: Plastic bags for solids and carboys for liquids (obtained from the EHS). Requirements for safe handling and disposal of this type of waste are: Liquids must be absorbed into another material such as paper towels, sponges, gauze, etc. prior to placing into bags. 15.11 How to Complete a RAM Waste Form The "Radioactive Waste Disposal Form" is used to identify the contents of each container and must accompany each radioactive waste container that has been filled and is ready for removal from the laboratory. It must be completed and attached to or near each waste container. Below are instructions for filling out each section properly. SECTION WHAT INFORMATION IS NEEDED PI Name / Room Number Isotope Self-Explanatory List of all Isotopes present in the waste container. (Remember-only 3H and 14C can be mixed in the same container). Circle the appropriate form of waste Make an entry on the form for all waste placed in the container. Record activity in µCi units. Must be an actual description of the contents (e.g., plastic LS vials, glass test tubes, gloves, etc.) The words "Trash or Garbage" will not suffice. For bulk liquids, list the chemical names and concentrations in each container. The form must be signed by the Principal Investigator Form Disposal Information Physical / Chemical Description Certification Table 9 - Procedures for Completing RAM Waste Form 15.12 Requesting a Waste Pick-Up When the waste containers are full, but before calling the RSO: 15.12.1 Close and properly seal the container(s). Bags are to be taped, carboys must have the lids tightly in place, and boxes containing sharps must also be sealed. 15.12.2 Bagged dry and semi-solid waste must be removed from the waste receptacle and taped shut to be considered ready for pickup. 15.12.3 Full waste containers that require shielding shall not be left outside of the shield while awaiting pickup. 15.12.4 Complete the HSC Waste Disposal Form. All information requested MUST be supplied including the signature of the person completing the form. Attach the form to the waste container or have it clearly visible near the container. 15.12.5 Call the RSO and request a waste pick-up. If additional carboys are needed, please request it when calling for a waste pick-up. NOTE: Improperly documented or segregated waste will not be accepted by the RSO. If evidence of improper segregation or documentation is discovered by the RSO after waste has been removed from the lab, the waste container and its contents will be returned to the lab for proper segregation and Radiation Safety Manual 41 documentation as necessary. Radiation Safety Manual 42 Section 16. Use of Radioactive Materials in Animals 16.1 Introduction The use of radioactive materials requires additional safeguards in the handling of affected animals. In addition to their authorization to use radioactive materials, Principal Investigators (PIs) must become specifically authorized to use radioactive materials in animals. 16.2 Obtaining Authorization Complete the “Radioactive Material Use in Animals” application and return to the RSO. Procedures involving animal systems vary widely as do applicable safety requirements. The information provided on the application will enable the RSO to formulate necessary safety measures and assist the PI in implementing these measures. After review by the RSO, the application is submitted to the Radiation Safety Committee for approval. Once approved, an Authorization Permit will be issued to the PI. The HSC Institutional Animal Care and Use Committee (IACUC) will be notified and supplied a copy of the approved application and permit. NOTE: It is the PI’s responsibility to obtain the IACUC forms and seek separate approval of the Committee for their research protocol. NO research activities can begin without the approval of both the IACUC and the HSC Radiation Safety Committee. 16.3 Radiation Monitoring Radiation monitoring includes but is not limited to: 16.3.1 Radiation monitoring of the animal(s), cages, and/or the actual procedure when performed, pursuant to conditions of the Protocol. 16.3.2 Analytical determination of radioactivity in urine, feces, and bedding (when required) 16.3.3 Labeling cages containing radioactive animals. Tags for this purpose must indicate the radionuclide, the activity (in µCi or mCi) and the date. NOTE: Notify the Manager of Animal Care at least five working days prior to the actual use of radioisotopes in animal. 16.4 Radioactive Waste Disposal All animal remains, i.e., viscera, tissue, serum, or other fluids, and the carcass, containing radioactive material (except tritium (3H), carbon-14 (14C) and iodine-125 (125I) as describe below) are to be disposed of as follows: 16.4.1 Place the remains in a yellow radioactive materials waste bag. 16.4.2 Secure the bag shut with tape or other closure and label the bag with a radioactive materials tag showing the radionuclide, the activity, the date and the initials of the individual completing the tag. 16.4.3 Place the bag in the labeled container in the designated freezer. NOTE: Be sure to complete a logbook entry for all waste you place in the freezer. 16.5 Deregulated Waste Regulations promulgated by the Texas Department of State Health Services and applicable to the HSC license, allow animal remains containing tritium, carbon-14 and iodine-125, in quantities NOT EXCEEDING 0.05 microcuries (µCi) per gram body weight, to be disposed of as non-radioactive Radiation Safety Manual 43 waste. While disposals of this kind are essentially deregulated, be reminded the Principal Investigator must continue to keep an inventory record with the Date, Activity, and Isotope (3H, 14C, 125I) used in the animal and the date on which the remains were disposed. Having confirmed that the carcass meets above stipulations, this “non-radioactive” animal waste is to be placed in the non-labeled waste container and in the designated freezer. DO NOT place any radioactive material labels on the bags or contents. DO NOT use a yellow radioactive materials bag. Radiation Safety Manual 44 Section 17. General Instructions for Auxiliary Personnel 17.1 INSTRUCTIONS FOR MAINTENANCE PERSONNEL 17.1.1 Introduction Radioactive materials can be found in many locations at the HSC. Some general guidelines for specific areas are outlined below. 17.1.2 “Caution Radioactive Material” Symbol The universal symbol for radiation or radioactive material is the three-bladed caution symbol (magenta or purple on yellow background) as shown below: 17.1.3 “Radiation Area” Instructions Some general guidelines for “Radiation Area” marked rooms are outlined below: 17.1.3.1 Do not enter any of these areas without specific permission to do so either from someone in authority in that area or from the RSO. 17.1.3.2 When specifically authorized to enter such an area: 17.1.3.2.1 follow instructions 17.1.3.2.2 only perform the work required 17.1.3.2.3 leave as soon as work is complete - do not waste time STEP 1 2 3 4 5 6 7 PROCEDURE Inform the RSO of any work planned for any areas that may involve radioactive materials prior to the onset of work. Enter room unless specific signs say "Keep Out." Seek someone who works in the room and explain the work that is to be done. Before you begin work, have laboratory personnel check by instrument survey or a wipe test, to ensure the work area is free of contamination. If you cannot find someone in the area to check with, leave the room and contact EHS for further information. If it is an emergency repair job and you cannot get help from someone in the area, contact EHS. If the area is free of contamination, proceed with the job. While in the area: do not smoke, eat or drink do not enter other areas marked off as radioactive material areas watch for signs of possible contamination, such as broken labeled bottles or vials, or liquid pooled in an area Table 10 - Procedures to Follow in Rooms Marked “Caution Radioactive Materials” Radiation Safety Manual 45 17.1.4 Equipment Marked “Radioactive Material” For sinks, hoods, or other equipment marked "Radioactive Material": 17.1.4.1 have lab personnel check by wipe test or survey instrument to ensure that there is no contamination 17.1.4.2 if equipment must be taken back to shop, or there are any questions, call the RSO for supervision 17.1.4.3 call the RSO to have a hood exhaust duct surveyed 17.2 INSTRUCTIONS FOR SECURITY PERSONNEL 17.2.1 Access to Radiation Areas There is no hazard to security personnel if the guidelines below are followed: 17.2.1.1 A location labeled, "Radiation Area" can be entered for a short time to provide assistance to personnel in the area or to protect property, but for routine matters, contact the RSO personnel first. 17.2.1.2 A location labeled, "Radioactive Material" will be safe to enter unless specifically marked "Do Not Enter". While in the area: 17.2.1.2.1 do not handle containers labeled with radioactive material symbols 17.2.1.2.2 do not eat or drink in these areas 17.2.1.2.3 be wary of evidence of spills or radioactive material 17.2.2 “Caution Radioactive Material” Symbol The universal symbol for radiation or radioactive material is the three-bladed caution symbol (magenta or purple on yellow background) as shown below: 17.2.3 When to Notify the RSO You should notify the RSO: 17.2.3.1 Before entering a radiation area (with the exceptions noted above) 17.2.3.2 If any container labeled "Radioactive Material" is found broken, crushed or leaking 17.2.3.3 In case of fire in any room labeled "Radioactive Material" 17.2.3.4 When in doubt, call the RSO. 17.2.4 Package Delivery Carrier services making delivery of radioactive material packages to HSC deliver them to the loading dock. In the event that you must receive the package(s): STEP 1 If the package is . . (1) Damaged (wet, crushed, open, etc.) (2) Intact Radiation Safety Manual PROCEDURE Visually inspect the package(s) at the time of delivery Then . . . 1. Do not handle package. 2. Ask the carrier to stay until the RSO has been contacted 1. Check to be sure that the package(s) 46 are addressed to HSC. 2. Sign for the package(s). 3. Call the RSO Table 11 - RAM Package Receipt Procedures 17.3 INSTRUCTIONS FOR HOUSEKEEPING PERSONNEL 17.3.1 Introduction In order to prevent the spread of radioactive contamination or improper disposal of radioactive waste, it is important that housekeeping personnel are aware of the proper way to conduct themselves in areas where radioactive materials are used. 17.3.2 “Caution Radioactive Material” Symbol The universal symbol for radiation or radioactive material is the three-bladed caution symbol (magenta or purple on yellow background) as shown below: 17.3.3 Conduct in Laboratories Follow these guidelines in laboratories: 17.3.3.1 Note the "Caution-Radioactive Material" sign at entrance to the area 17.3.3.2 Look for and obey any other special instructions at entrances, such as "Do Not Enter." If there are no special instructions, enter the room. 17.3.3.3 Do not smoke, eat, drink, or apply cosmetics while in these areas 17.3.3.4 Do required work as quickly as possible, then leave the area 17.3.3.5 Watch for problems: 17.3.3.5.1 If you see a tape-labeled container that has spilled or leaked, leave. 17.3.4 Tables of Instructions for Specific Areas ITEM / AREA INSTRUCTIONS Bench tops labeled with tape Do Not: lean on or against it put anything down on it handle anything that is on it Floor areas labeled with tape Do Not: walk into the labeled area clean the floor within the labeled area Lab equipment labeled with tape Do not touch the equipment Refrigerators labeled with tape Do not open Trash bags or cans labeled with tape or Do not empty this trash. If there is any labeled as radioactive or containing doubt whether or not it is radioactive, radioactive material do not empty it. Sinks labeled with tape or signs Do not use this sink to get water or dispose of water Table 12 - What to do with Items Marked “Caution Radioactive Materials” If there are any questions or problems, contact the RSO Radiation Safety Manual 47 Section 18. Registering X-Ray Machines 18.1 PRINCIPAL INVESTIGATORS-SUBREGISTRANTS 18.1.1 Introduction All x-ray use at the HSC must be first approved by the RSO and then approved and authorized by the Radiation Safety Committee (RSC). These guidelines explain the application, approval, and purchase process for x-ray machines and all other registerable ionizing radiation producing devices at the HSC and should help Principal Investigators (PIs) obtain their subregistration or amendment approvals as quickly and easily as possible. 18.1.2 Registration Procedure 18.1.2.1 STEP 1: Application 18.1.2.1.1 New PIs For new users, a subregistration application must be completed, signed by the PI, and then sent to the RSO for approval by the RSO. This subregistration application must include all x-ray machines, xray users with their x-ray machine qualifications, and locations of use to be authorized under the PI. Personnel and students not listed on the subregistration permit must not be allowed to use or work with the xray machines. 18.1.2.1.2 Current PIs For approved users planning to make changes to their subregistration, a subregistration amendment application must be completed, signed by the PI, and then sent to the RSO for approval. 18.1.2.1.3 Forms There are two forms: one for equipment changes (i.e., additions or deletions) and another for personnel and location changes (i.e., additions or deletions). Equipment additions will require the approval of the RSC. The RSO will approve all other changes. 18.1.2.2 STEP 2: Purchase Approval After the review and approval of the application by the RSO, it will be presented to the RSC for purchase approval. The RSO will notify the PI when the x-ray machine(s) may be purchased. 18.1.2.3 STEP 3: Procurement All x-ray purchase requisitions must be sent to the RSO for approval by the RSO. The RSO reviews the purchase requisition and makes certain that the PI has the committee's purchase approval. Upon approval, the order is immediately sent to the Purchasing Department for processing. X-ray safety devices should be purchased with the x-ray machine if possible and installed with the x-ray machine when received. Failure to plan and install safety devices as required will delay the final approval by the committee for use of the x-ray machine. 18.1.3 Receipt and Setup 18.1.3.1 Safety Devices All safety devices must be installed and operational before final approval is given. Radiation Safety Manual 48 18.1.3.2 Notification The RSO must be notified when the x-ray machine arrives and when it is set up. The RSO will request an amendment to the HSC’s State Registration to add the additional x-ray machine(s) within 30 days of receipt and installation. 18.1.3.3 Use The x-ray machine must not be used without the final approval of the RSC. The RSO may give permission to turn on the x-ray machine for test procedures in the initial set up. 18.1.3.4 Associated Documentation The RSO will require additional specific documentation for review before final inspection. 18.1.3.4.1 X-ray machine specifications and information (part of the manufacturer's manual) 18.1.3.4.2 Receipt records (new or transfer) 18.1.3.4.3 Installation records (where applicable) 18.1.3.4.4 Start-up and operational procedures (usually in the manual) 18.1.3.4.5 Maintenance and modification plans (where applicable) 18.1.3.4.6 Safety devices plan (interlocks, warning lights, etc.) 18.1.3.4.7 Personnel radiation dosimetry applications 18.1.3.4.8 Calibration records 18.1.3.4.9 Any other requested information 18.1.4 Final Approval for Use Radiation Safety Officer Inspection The RSO will inspect the x-ray machine set up before operation begins. Appropriate installation or enclosure signs will be supplied and posted. Final Approval After finding the x-ray machine set up in compliance, the RSO will give final approval for use. New subregistrants will receive an authorization permit and a subregistration number. Upon final approval the PI may begin his or her research. 18.2 TRAINING AND RENEWALS 18.2.1 Radiation Safety Training The RSO requires that all Authorized Users attend the X-ray Safety Short Course presented by the RSO. PI’s are not required to attend unless the RSC determines that their X-ray training and experience is inadequate. The PI will also assure that specific training in the safe use of x-ray machines under his or her supervision will be provided. 18.2.2 Renewals The PI's subregistration authorization is for a two year period. Near the end of the two years, the RSO will send the PI a new subregistration application to be completed. Any new information and/or experimental procedure changes should be added to this new application. New personnel who have not completed the Radiation Safety Training Requirements must be added separately by personnel amendment forms. The Radiation Safety Committee will review the renewal application with or without changes for approval. The PI's past safety and compliance record will also be considered at this time. If there are no major problems, the RSC will then give its approval of the subregistration for another two years. The PI's research will not be interrupted during this process unless the RSC does not approve the renewal of the subregistration. Radiation Safety Manual 49 18.3 DECOMMISSIONING AND REMOVAL OF X-RAY DEVICES 18.3.1 Introduction It may become necessary to decommission and remove and X-ray device from use for the purposes of either sending the equipment to surplus, disposing of the device and removing it from the X-ray registration, or other reasons not stated above. 18.3.2 Process Please contact the HSC RSO for the coordination of any decommissioning or removal processes as there are special considerations involved in safety and compliance with regard to X-ray or other radiation generating devices. Radiation Safety Manual 50 Section 19. Radiation Safety Requirements for X-Ray Producing Machines 19.1 ANALYTICAL X-RAY EQUIPMENT 19.1.1 Introduction Texas Regulations for the Control of Radiation (TRCR) § 289.228, “Radiation Safety Requirements for Analytical and Other Industrial Radiation Machines (effective July 1, 2000)”. A copy of any referenced section of the TRCR may be obtained from the RSO. 19.1.2 Definitions 19.1.2.1 Analytical radiation machine: This includes, but is not limited to, x-ray equipment used for x-ray diffraction, fluorescence analysis, spectroscopy, or particle size analysis. 19.1.2.2 Fail-safe characteristics: Design features that cause the beam port shutters to close, or otherwise prevent emergence of the primary beam, upon the failure of a safety or warning device. 19.1.2.3 Local Components: Parts of an x-ray system that include areas that are struck by x rays, such as radiation source housings, port and shutter assemblies, collimators, sample holders, cameras, goniometers, detectors, and shielding, but do not include power supplies, transformers, amplifiers, readout devices, and control panels. 19.1.2.4 Normal operating procedures: Means operating procedures for conditions suitable for analytical purposes with shielding and barriers in place. These do not include maintenance but do include routine alignment procedures. Routine and emergency radiation safety considerations are part of these procedures. 19.1.2.5 Open-beam configuration: A radiation machine in which an individual could accidentally place some part of his/her body in the primary beam path during normal operation. 19.1.2.6 Primary beam: Ionizing radiation that passes through an aperture of the source housing by a direct path from the x-ray tube located in the radiation source housing. 19.1.2.7 Safety device: A device that prevents the entry of any portion of an individual’s body into the primary x-ray beam path or that causes the beam to be shut off upon entry into its path. 19.1.2.8 X-ray system: A group of components utilizing x-rays to determine the elemental composition or to examine the microstructure of materials. 19.2 EQUIPMENT REQUIREMENTS 19.2.1 Safety Devices 19.2.1.1 Safety Device: A device which prevents the entry of any portion of an individual's body into the primary x-ray beam path or which causes the beam to be shut off upon entry into its path shall be provided on all open beam configurations. A subregistrant may apply for an exemption from the requirement of a safety device with the RSO if an experimental design prevents the installation of the safety device. Such application shall include: Radiation Safety Manual 51 19.2.1.1.1 A description of the various safety devices that have been evaluated. 19.2.1.1.2 The reason each of these devices cannot be used, and 19.2.1.1.3 A description of the alternative methods that will be employed to minimize the possibility of an accidental exposure, including procedures to assure operators and others in the area will be informed of the absence of safety devices. 19.2.1.2 Warning Devices: Open-beam configurations shall be provided with a visible indication of: 19.2.1.2.1 X-ray tube status (ON-OFF) located near the radiation source housing, if the primary beam is controlled in this manner; and/or 19.2.1.2.2 Shutter status (OPEN-CLOSED) located near each port on the radiation source housing, if the primary beam is controlled in this manner. 19.2.1.2.2.1The x-ray control shall provide visual indication whenever x-rays are produced. 19.2.1.2.2.2Warning devices shall be labeled so that their purpose is easily identified and shall have fail-safe characteristics. 19.2.1.3 Ports: Unused ports on radiation machine source housings shall be secured in the closed position in a manner which will prevent casual opening. 19.2.1.4 Labeling: Each registrant shall ensure that each radiation machine is labeled in a conspicuous manner to caution individuals that radiation is produced when it is energized. This label shall be affixed in a clearly visible location on the face of the control unit. If the radiation machine is not visible from the control unit, the radiation machine shall have a visible indication that it is energized. 19.2.1.5 Shutters: On open-beam configurations, each port on the radiation source housing shall be equipped with a shutter that cannot be opened unless a collimator or a coupling has been connected to the port. 19.2.1.6 Generator Cabinet: Each x-ray generator shall be supplied with a protective cabinet that limits leakage radiation measured at a distance of 5 centimeters from its surface such that it is not capable of producing a dose in excess of 0.5 millirem in any one hour. 19.3 AREA REQUIREMENTS 19.3.1 Area Requirements Sufficient shielding should be located so that no radiation levels exist in any area which could result in a dose to an individual present in the area in excess of the dose limits specified in 25 TAC § 289.231. 19.3.1.1 Surveys: Radiation surveys of all analytical x-ray systems shall be performed: 19.3.1.1.1 Upon installation of the equipment 19.3.1.1.2 Following any change in the initial arrangement, number, or type of local components in the system 19.3.1.1.3 Following any maintenance requiring the disassembly or removal of a local component in the system Radiation Safety Manual 52 19.3.1.1.4 During the performance of maintenance and alignment procedures, if the procedures require the presence of a primary x-ray beam when any local component in the system is disassembled or removed 19.3.1.1.5 Any time a visual inspection of the local components in the system reveals an abnormal condition 19.3.1.1.6 Whenever personnel monitoring devices show a significant increase over the previous monitoring period or the readings are approaching the Radiation Protection Guides (radiation dose limits). 19.3.1.2 Posting: Each area or room containing analytical x-ray equipment shall be conspicuously posted with a sign or signs bearing the radiation symbol and the words "CAUTION - X-RAY EQUIPMENT," or words having a similar intent. 19.4 OPERATING REQUIREMENTS 19.4.1 Operating Requirements 19.4.1.1 Procedures: Normal operating and safety procedures shall be written and available to all analytical x-ray machine operators. No person shall be permitted to operate analytical x-ray equipment in any manner other than that specified in the procedures, unless such person has obtained written approval of the Radiation Safety Officer. 19.4.1.2 Bypassing: No person shall bypass a safety device unless that person has obtained the written approval of the Radiation Safety Officer. When a safety device has been bypassed, a visible sign bearing the words "SAFETY DEVICE NOT WORKING," or words having a similar intent, shall be placed on the radiation source housing. 19.4.1.3 Repair or modification of radiation machine: Except as specified above, no operation involving removal of covers, shielding materials, or tube housings, or modifications to shutters, collimators, or beam stops shall be performed without ensuring that the tube is off and will remain off until safe conditions have been restored. The main switch, rather than interlocks, shall be used for routine shutdown in preparation for repairs. 19.5 PERSONNEL REQUIREMENTS 19.5.1 Personnel Requirements 19.5.1.1 Instructions: No person shall be permitted to operate or maintain analytical x-ray equipment unless such person has received instruction in and demonstrated competence as to: 19.5.1.1.1 Identification of radiation hazards associated with the use of the equipment 19.5.1.1.2 Significance of the various radiation warning and safety devices incorporated into the equipment, or the reasons they have not been Radiation Safety Manual 53 installed on certain pieces of equipment and the extra precautions required in such cases 19.5.1.1.3 Proper operating and safety procedures for the equipment 19.5.1.1.4 Symptoms of an acute localized exposure; and 19.5.1.1.5 Proper procedures for reporting an actual or suspected exposure. 19.5.1.2 Personnel Monitoring: Whole Body Dosimeters shall be worn at all times when working with radiation generating devices or machines unless specific written approval is given by the RSO. Finger Dosimeters shall be provided to and shall be used by: 19.5.1.2.1 Analytical x-ray equipment workers using systems having an open beam configuration and not equipped with a safety device; and 19.5.1.2.2 Personnel maintaining analytical x-ray equipment if the maintenance procedures require the presence of a primary x-ray beam when any local component in the analytical x-ray system is disassembled or removed. Radiation Safety Manual 54 Section 20. Registering Lasers 20.1 PRINCIPAL INVESTIGATORS-SUBREGISTRANTS 20.1.1 Introduction All laser use at the HSC must be first approved by the Laser Safety Officer (LSO), and then approved and authorized by the Radiation Safety Committee (RSC). These guidelines explain the application, approval, and purchase process for lasers at the HSC and should help Principal Investigators (PIs) obtain their subregistration or amendment approvals as quickly and easily as possible. 20.1.2 Scope The laser devices governed by this manual are those that operate at energies described as Class 3b (IIIb) or higher. 20.1.3 Registration Procedure 20.1.3.1 STEP 1: APPLICATION Equipment additions require the approval of the RSC. The LSO will approve all other changes. 20.1.3.1.1 New PIs For new users, a subregistration application must be completed, signed by the PI, and then sent to the LSO for approval. This subregistration application must include all lasers, laser users with their laser qualifications, and locations of use to be authorized under the PI. Personnel and students not listed on the subregistration permit must not be allowed to use or work with the lasers. 20.1.3.1.2 Current PIs For approved users planning to make changes to their subregistration, a subregistration amendment application must be completed, signed by the PI, and then sent to the LSO for approval. There are two forms: 20.1.3.1.2.1one for equipment changes (i.e., additions or deletions), and 20.1.3.1.2.2another for personnel and location changes (i.e., additions or deletions). 20.1.3.1.3 Assistance The LSO will provide assistance to any applicant who requires additional information or has special situations. Occasionally experimental designs may require partial exemptions to the regulations. The LSO will seek an amendment to the HSC Registration, if necessary. 20.1.3.2 STEP 2: PURCHASE APPROVAL After the review and approval of the application by the LSO, he will present it to the RSC for purchase approval. The LSO will notify the PI when the laser(s) may be purchased. 20.1.3.3 STEP 3: PROCUREMENT All laser purchase requisitions must be sent to EHS for approval by the LSO. The LSO reviews the purchase requisition and makes certain that the PI has the RSC's purchase approval. Upon approval, the order is immediately sent to Radiation Safety Manual 55 Purchasing for processing. Laser safety devices should be purchased with the laser system if possible and installed with the laser when received. Failure to plan and install safety devices as required will delay the final approval by the committee for use of the laser. 20.1.4 Receipt and Setup 20.1.4.1 Safety Devices All safety devices must be installed and operational before final approval is given. 20.1.4.2 Notification The LSO must be notified when the laser arrives and when it is set up. 20.1.4.3 Use The laser must not be used without the final approval of the RSC. The LSO may give permission to turn on the laser system for test procedures in the initial set up. 20.1.4.4 Associated Documentation The LSO will require additional specific documentation for review before final inspection. 20.1.4.4.1 Laser specifications and information (part of the manufacturer's manual) 20.1.4.4.2 Receipt records (new or transfer) 20.1.4.4.3 Installation records (where applicable) 20.1.4.4.4 Start-up and standard operational procedures (usually in the manual) 20.1.4.4.5 Maintenance and modification plans (where applicable) 20.1.4.4.6 Safety devices plan (interlocks, warning lights, etc.) 20.1.4.4.7 Safety goggles information 20.1.4.4.8 Calibration records 20.1.4.4.9 Any other requested information 20.1.5 Final Approval for Use 20.1.5.1 Laser Safety Officer (LSO) Inspection The LSO will inspect the laser system set up before operation begins. 20.1.5.2 Final Approval After finding the laser set up in compliance, the LSO will give final approval for use. New subregistrants will receive an authorization permit and a subregistration number. Upon final approval, the PI may begin research. 20.2 TRAINING 20.2.1 Laser Safety Training The LSO requires that all Authorized Users attend the Laser Safety Short Course presented by EHS. PIs are not required to attend unless the RSC determines that their Laser training and experience is inadequate. The PI will also assure that specific training in the safe use of lasers under his or her supervision will be provided. 20.3 RENEWALS 20.3.1 Renewals The PI's subregistration authorization is for a two year period. Near the end of the two years, the LSO will send the PI a new subregistration application to be completed. Any new information and/or experimental procedure changes should be added to this new application. New personnel who have not completed the Laser Safety Training Requirements must be added separately by personnel amendment forms. The RSC will Radiation Safety Manual 56 review the renewal application with or without changes for approval. The PI's past safety and compliance record will also be considered at this time. If there are no major problems, the RSC will then give its approval of the subregistration for another two years. The PI's research will not be interrupted during this process unless the RSC does not approve the renewal of the subregistration Radiation Safety Manual 57 Section 21. Radiation Safety Requirements for Lasers 21.1 INTRODUCTION 21.1.1 Definitions The following requirements are adapted from applicable sections of 25 Texas Administrative Code § 289.301, “Registration and Radiation Safety Requirements for Lasers – Texas Regulations for Control of Laser Radiation Hazards (effective February 14, 1999)”. A copy of any referenced section of the Texas Regulations for the Control of Radiation (TRCR) may be obtained from the LSO. If any conflict occurs between these requirements and the Code, the latter shall prevail. The following words and terms, when used in this program, shall have the following meanings. 21.1.1.1 21.1.1.2 21.1.1.3 21.1.1.4 21.1.1.5 21.1.1.6 21.1.1.7 21.1.1.8 21.1.1.9 21.1.1.10 21.1.1.11 Radiation Safety Manual Accessible emission limit (AEL) – the maximum accessible emission level permitted within a particular class. Aperture – an opening through which radiation can pass. Apparent visual angle – the angular subtense of the source as calculated from the source size and distance from the eye. It is not the beam divergence of the source. Attenuation – the decrease in the radiant flux of any optical beam as it passes through an absorbing or scattering medium. Beam – a collection of rays that may be parallel, divergent, or convergent. Class I laser – any laser that does not permit access during the operation to levels of laser radiation in excess of the accessible emission limits. Class II laser – any laser that permits human access during operation to levels of visible laser radiation in excess of the accessible emission limits contained in 25 TAC §289.301(cc)(1), but does not permit human access during operation to levels of laser radiation in excess of the accessible emission limits contained in 25 TAC §289.301(cc)(2). Class IIIa laser – any laser that permits human access during operation to levels of visible laser radiation in excess to the accessible emission limits contained in 25 TAC §289.301(cc)(2), but does not permit human access during operation to levels of laser radiation in excess of the accessible emission limits contained in 25 TAC §289.301(cc)(3). Class IIIb laser – any laser that permits human access during operation to levels of laser radiation in excess to the accessible emission limits contained in 25 TAC §289.301(cc)(3), but does not permit human access during operation to levels of laser radiation in excess of the accessible emission limits contained in 25 TAC §289.301(cc)(4). Class IV laser – any laser that permits human access during operation to levels of laser radiation in excess of the accessible emission limits contained in 25 TAC §289.301(cc)(4). Electromagnetic radiation – the flow of energy consisting of orthogonally vibrating electric and magnetic fields lying transverse to the direction of propagation. X-ray, ultraviolet, visible, infrared, and radio waves occupy various portions of the electromagnetic spectrum and differ only in frequency, wavelength, or photon energy. 58 21.1.1.12 21.1.1.13 21.1.1.14 21.1.1.15 21.1.1.16 21.1.1.17 21.1.1.18 21.1.1.19 21.1.1.20 21.1.1.21 21.1.1.22 Radiation Safety Manual Electronic product – any manufactured or assembled product that, when in operation: 21.1.1.12.1 contains or acts as part of an electronic circuit; and 21.1.1.12.2 emits, or in the absence of effective shielding or other controls would emit, electronic product radiation; or 21.1.1.12.3 or, any manufactured or assembled article that is intended for use as a component, part, or accessory of a product described in 12.1.1.12 above and that when in operation emits, or in the absence of effective shielding or other controls would emit, such radiation. Entertainment laser – any laser manufactured, designed, intended, or promoted for purposes of entertainment, advertising display, or artistic composition. Infrared radiation – electromagnetic radiation with wavelengths that lie within the range 700 nm to 1 mm. Laser – a device that produces an intense, coherent, directional beam of light by stimulating electronic or molecular transitions to lower energy levels. “Laser” is an acronym for light amplification by stimulated emission of radiation. The term “laser” also includes the assembly of electrical, mechanical, and optical components associated with the laser. Laser product – any manufactured product or assemblage of components that constitutes, incorporates, or is intended to incorporate a laser and is classified as a class I, II, IIIa, IIIb or IV laser product according to the performance standards set by the United States Food and Drug Administration (FDA). A laser that is intended for use as a component of an electronic product shall itself be considered a laser product. A laser product contains an enclosed laser with an assigned class number higher than the inherent capability of the laser in which it is incorporated and where the product’s lower classification is appropriate due to the engineering features limiting accessible emission. Laser Safety Officer (LSO) – an individual who has knowledge of and the authority and responsibility to apply appropriate laser radiation protection rules, standards, and practices, and who must be specifically authorized on a certificate of laser registration. Maximum permissible exposure (MPE) – the level of laser radiation to which a person may be exposed without hazardous effect or adverse biological changes in the eye or skin. Protective housing – an enclosure surrounding the laser that prevents access to laser radiation above the applicable MPE level. The aperture through which the useful beam is emitted is not part of the protective housing. The protective housing may enclose associated optics and a workstation and shall limit access to other associated radiant energy emissions and to electrical hazards associated with components and terminals. Pulsed laser – a laser that delivers its energy in the form of a single pulse or a train of pulses. The duration of a pulse is <0.25 seconds in a pulsed laser. Service – the performance of those procedures or adjustments described in the manufacturer’s service instructions that may affect any aspect of the performance of the laser. Source – a laser or laser-illuminated reflecting surface. 59 Transmission – passage of radiation through a medium. Ultraviolet radiation – electromagnetic radiation with wavelengths smaller than those of visible radiation; for the purpose of this manual 180 to 400 nm. 21.1.1.25 Visible radiation (light) – electromagnetic radiation that can be detected by the human eye. 21.1.2 Laser Supervision and Control 21.1.2.1 Radiation Safety Committee (RSC) The RSC establishes and maintains adequate written policies and procedures for the control of laser hazards to assure compliance with the state regulations. The RSC approves all use of lasers at the HSC. 21.1.2.2 Laser Safety Officer (LSO) 21.1.2.2.1 Protection against laser radiation hazards is under the supervision of the LSO. 21.1.2.2.2 The LSO provides consultative services on laser hazard evaluation and control. 21.1.2.2.3 The LSO ensures adequate safety practices to insure compliance with the HSCs laser safety requirements. 21.1.2.2.4 The LSO has the authority to suspend, restrict, or terminate the operation of a laser product or installation, if laser hazard controls are deemed to be inadequate by the LSO. 21.1.2.2.5 The LSO maintains the records required by the Texas Regulations for the Control of Laser Radiation Hazards. 21.1.2.2.6 The LSO approves all protective equipment for the protection of personnel against laser radiation. 21.1.2.2.7 The LSO surveys all areas where laser equipment is being used to assure compliance with the state regulations. 21.1.2.2.8 The LSO reviews planned installations or modifications of laser equipment relative to laser hazards and their control, approving the installation or modification only if he is satisfied that laser controls are adequate. 21.1.2.2.9 The LSO is to investigate all real or suspected incidents or injuries resulting from laser operations. 21.1.2.2.10 The LSO will approve a laser system for operation only if the laser hazard controls are deemed adequate by the RSO. 21.1.2.2.11 The LSO makes certain that adequate warning systems and signs are installed. 21.1.2.3 Principal Investigators (PIs) 21.1.2.3.1 A PI shall not permit the operation of a laser unless there is adequate control of the laser hazards to employees, visitors, and the public. 21.1.2.3.2 Except for Class I lasers, a PI must submit the names of persons scheduled to work with lasers to the LSO. In addition, a PI shall submit information requested by the LSO for medical surveillance scheduling for incident or injury investigations. 21.1.2.3.3 When a PI knows of or suspects an incident or injury resulting from a laser operated under his/her supervision, he/she shall immediately notify the LSO of the incident or injury and the names of the individuals involved. 21.1.2.3.4 A PI shall assist in obtaining appropriate medical attention for individuals involved in a laser accident. 21.1.1.23 21.1.1.24 Radiation Safety Manual 60 21.1.2.3.5 A PI shall not permit the initial operation of a laser system which is under his/her supervision without prior approval by the LSO. 21.1.2.3.6 If any modification of a laser system is made which has not been evaluated by the LSO, the PI shall not energize the system until the LSO has given approval. 21.1.2.3.7 Each PI shall submit plans for laser installations or modifications to the LSO for approval. 21.1.2.4 Authorized Users (AUs) 21.1.2.4.1 A laser is not to be energized or worked with unless the AU has been authorized to do so by the PI. 21.1.2.4.2 AUs must comply with the safety rules and standards prescribed by the PI and the LSO. 21.1.2.4.3 When the AU knows or suspects that an incident or injury has occurred involving a laser operation, the AU is to immediately inform the PI and the LSO. 21.2 GUIDELINES FOR SAFE OPERATIONS OF LASERS 21.2.1 Maximum Permissible Exposure (MPE) and Nominal Hazard Zone (NHZ) [25 TAC §289.301(d)(43) and (45); 25 TAC §289.301(u)] An MPE is the level of laser exposure to which the eye or (less limiting) the skin, may be exposed without adverse effects. NHZ is the space within which the level of direct reflected or scattered radiation during operation exceeds the applicable MPE. When any class IIIb or IV laser is used at levels at or above IIIb in an open beam mode the MPE will be assumed to be exceeded in that room or area and appropriate precautions shall be taken. In other words, the NHZ will comprise the enclosure (room or area to which the beam is restricted to by virtue of walls, curtains or other barriers) in which the laser is operating if operated at or above IIIb levels. This is done to account for intentional or unintentional scattered or reflected beam. If the PI believes the NHZ does not apply to the whole area he may justify a more limited NHZ in the SOP by using information supplied by the laser manufacturer, by measurement, or by using the appropriate laser range equations or other equivalent assessments. 21.2.2 Laser Safety Standard Operating Procedures (SOPs) [25 TAC §289.301(v)(2)(B)] Each laser shall have a Standard Operating Procedure (SOP) written for its operation. The SOP must be present at the operating console or control panel of the laser. The SOP shall include at a minimum: 21.2.2.1 operating instructions 21.2.2.2 safety eyewear parameters and instructions for proper use 21.2.2.3 interlock instructions 21.2.2.4 checklist for operation 21.2.2.5 clear warnings to avoid possible exposure to laser and collateral radiation in excess of the MPE. Radiation Safety Manual 61 The SOP shall be available for inspection by the LSO or designate at any time. A template for Laser Safety Standard Operating Procedures can be found in Appendix B. 21.2.3 Safety Interlocks and Warning Systems [25 TAC §289.301(v)(2)(B) and (D)] A safety interlock is a device that automatically prevents human access above MPE limits. Safety interlocks shall be provided for any portion of the protective housing that by design can be removed or displaced without the use of tools during normal operation or maintenance, and thereby allows access to radiation above MPE limits. Adjustment during operation, service, testing, or maintenance of a laser containing interlocks shall not cause the interlocks to become inoperative except where a laser controlled area, as specified in subparagraph (E) of the referenced regulation, is established. For pulsed lasers, interlocks shall be designed to prevent firing of the laser; for example, by dumping the stored energy into a dummy load and for continuous wave (CW) lasers, the interlocks shall turn off the power supply or interrupt the beam (i.e., by means of shutters). Each class IIIb or IV laser system shall provide visual or audible indication during the emission of accessible laser radiation. The indication shall occur prior to emission of radiation with sufficient time to allow appropriate action to avoid exposure. Any visual indication (e.g., lights) shall be visible through protective eyewear for the wavelength of the laser so that eyewear need not be removed to see it. 21.2.4 Safety Interlocks – Alternatives [25 TAC§ 289.301(r)(2)(E)(II)] The regulations recognize that in situations where an engineering control (automatic safety interlock) may be inappropriate, the LSO shall specify alternate controls to obtain equivalent laser safety protection. Requests to use alternate controls may be submitted in writing to the LSO and, if accepted, will be documented in the SOP. Where safety latches or interlocks are not feasible or are inappropriate, for example during surgical procedures, a controlled area shall be established and the following shall apply: 21.2.4.1 21.2.4.2 Radiation Safety Manual All authorized personnel shall be trained in laser safety and appropriate personal protective equipment shall be provided and worn upon entry. A door, blocking barrier, screen, or curtains shall be used to block, screen, or attenuate the laser radiation at the entryway. The level at the exterior of these devices shall not exceed the applicable MPE, nor shall personnel experience any exposure above the MPE immediately upon entry. 62 If a laser is energized and operating at class IV levels then at the entryway there shall be a visible or audible signal and other appropriate signage indicating laser operations. This indicator may be interfaced with the laser itself, the power supply, or manually operated in accordance with the SOP requiring its use. 21.2.4.3.1 For indoor controlled areas, during tests requiring continuous operation, the individual in charge of the controlled area may momentarily override the safety interlock. The sole purpose is to allow access to other authorized persons if it is clearly evident that there is no optical hazard at the entry area and protective eyewear is worn by the entering person. 21.2.4.3.2 When removal of panels or protective covers and/or overriding interlocks becomes necessary, such as for servicing, testing or maintenance and laser radiation exceeds the MPE, a temporary controlled area must be established and posted. 21.2.4.3 21.2.5 Protective Eyewear [25 TAC §289.301(t)(1)] Each Sublicensee shall provide protective eyewear that meets the requirements of 25 TAC §289.301(t)(1). The eyewear shall be located where persons who operate the laser have unrestricted access to the eyewear. The eyewear shall be worn during any operation where a class IIIb or IV beam is not enclosed. This normally includes alignments. Training on identification, proper fit, location, and use of eyewear shall be included in the specific laser safety training. Protective eyewear shall meet the following requirements: 21.2.5.1 Provide a comfortable and appropriate fit all around the area of the eye 21.2.5.2 Be in good physical condition to ensure the lenses retain all protective properties during its use 21.2.5.3 Be of optical density adequate for the laser energy involved 21.2.5.4 Have the optical density or densities and associated wavelengths permanently labeled on the filters or eyewear 21.2.5.5 Be examined at intervals not less than 12 months, to ensure the reliability of the protective filters and integrity of the holders. Unreliable eyewear shall be discarded and replaced. 21.2.5.6 The optical density of the protective eyewear shall be appropriate for the specific frequency and pulse length of the laser beam in use, and shall provide reduction of the incident energy to less than the MPE of the laser. It is important to include the pulse length and frequency of pulse repetition of pulsed lasers in selecting appropriate protective eyewear. 21.2.6 Training [25 TAC §289.301(q)(1)] Every person who operates or works with a laser shall complete training in laser safety provided by the LSO or LSO-approved equivalent. This training is referred to as the General Laser Safety Training. Persons completing General Laser Safety Training shall also complete specific laser safety training given by the Sublicensee. No person may work in a NHZ prior to completing both laser safety training classes. Miscellaneous Safety and Training Issues: Radiation Safety Manual 63 21.2.6.1 21.2.6.2 Persons working in a laboratory with multiple lasers shall be made aware of the various wavelengths and other operating parameters by the laser operator/users Persons working with tunable lasers, or any laser which is frequency doubled or frequency tripled, shall be aware of the effect of frequency manipulation and shall choose protective eyewear which will provide protection for the effective wavelength of the laser. 21.2.7 Skin Protection [25TAC §289.301(t)(2)] When there is potential for skin exposure to levels exceeding the skin MPE for the laser, persons in the controlled area shall wear appropriate clothing, gloves, and/or shields. 21.2.8 Magnification of Laser Beam [25TAC §289.301(r)(2)(C)(ii)] If at any time a laser beam is optically magnified or concentrated, special precautions shall be taken by the Sublicensee to prevent specular or diffuse reflection or other exposure greater than the MPE for the laser. The special precautions shall be documented in the SOP for the laser. 21.2.9 Non-Radiation Hazards Each Sublicensee shall evaluate or have an evaluation made of nonradiation hazards. This evaluation shall include electrocution, chemical, cutting edge, compressed gases, noise, confined space, fire, explosion, ventilation, and other physical safety hazards. The evaluation shall be made part of the SOP’s and be available for review. 21.2.10 Surveys [25TAC §289.301(w)] The LSO shall perform biannual surveys of all lasers. These surveys shall include: 21.2.10.1 Ascertaining that all lasers and protective devices are labeled correctly and functioning within the design specifications. 21.2.10.2 Ascertaining that all warning devices are functioning within their design specifications. 21.2.10.3 Ascertaining that the laser installation is properly posted with warning signs. 21.2.11 Records [25TAC §289.301(ee)] Records of Surveys, Training, NHZ and MPE calculations, and other laboratoryspecific information shall be maintained in the laboratory, and shall be available for inspection/review by the LSO at any time. Records shall be maintained for a period of not less than 5 years. 21.2.12 Incident Reporting [25TAC §289.301(z)-(bb)] Each Permittee shall immediately seek appropriate medical attention for the injured individual and notify the LSO by telephone of any injury involving a laser possessed by the HSC. The LSO shall be notified within 48 hours of any non-injury incident (near miss) which involves potential exposure to laser radiation exceeding the MPE. Radiation Safety Manual 64 A written summary of an injury or non-injury incident shall be forwarded to the LSO not later than five working days following the incident. Records of any incident shall be maintained by the LSO and the Sublicensee. Radiation Safety Manual 65 Section 22. Policy for Addressing Violations of Regulatory Requirements or Standards for Safe Work with Radiation, Radioactive Materials, and Lasers 22.1 VIOLATION POLICY 22.1.1 Introduction Laboratory inspections are performed to ensure compliance with the applicable state and federal regulations and with the policies set forth in this manual. Violations of requirements will be addressed by the policies of this manual. This policy recognizes that specific circumstances and severity of violations call for different corrective or, if necessary, disciplinary actions. This policy applies to all personnel using radiation-producing devices, radioactive materials, or laser devices at any Texas A&M Health Science Center owned and/or operated facility and to all personnel using radiation-producing devices, radioactive materials, or lasers at off-site locations under the auspices of a Texas A&M Health Science Center radioactive materials license. 22.1.2 Policy 22.1.2.1 22.1.2.2 22.1.2.3 22.1.2.4 22.1.2.5 22.1.2.6 Radiation Safety Manual Violations may be noted at any time. Reporting of violations is not limited to formal inspections. Violations will be classified as either major or minor. A list of major and minor violations is in section 22.1.3 and 22.1.4 below. Two minor violations will be considered the equivalent of one major violation. Violations may be corrected on the spot by the person noting them if appropriate. Although no notice of such violations will be issued in these circumstances, the Permit Holder will be notified and a comment will be entered into the Permit Holder’s record. Violations will be counted against the specific room in which they were noted and will be charged against the permit under which that room is listed. Violations that take place in unposted laboratory spaces will be charged against the permit holder responsible for the research being performed. Violations noted in common areas (corridors, equipment rooms, etc.), unposted areas, or in laboratory space that does not belong to a radioactive materials user will be charged against the permit under which the radiation worker is listed or under which the radioactive materials were ordered, as appropriate. All letters of violation shall be approved by the RSO prior to issuing to the Permit Holder. Upon issuance, the Permit Holder shall provide a written response to the RSO within 10 working days. This written response must provide a brief description of circumstances causing the violation and note actions to be taken to prevent a recurrence of the violation. If the Permit Holder feels the violation was issued in error or that there are mitigating factors, the violation may be contested to the RSO, who will decide whether or not to withdraw the violation. All communications with the Permit Holder will be retained in the Permit Holder’s file, where they will be available for review by the Radiation Safety Committee (RSC) upon request. Permit holders who do not 66 22.1.2.7 22.1.2.8 22.1.2.9 22.1.2.10 22.1.2.11 22.1.2.12 provide a written response within 10 working days will be referred to the Chair of the RSC for further action. Any Permit Holder receiving more than four major violations or the equivalent in major and minor violations in any six-month period will be subject to further review and possible disciplinary action. In these instances, the RSO will notify the user, conduct a review to determine root causes for violations, and request the user to respond in writing detailing corrective actions. The RSO will then refer the case to the chair of the RSC together with his recommendation for disposition. If the chair considers that actual or proposed corrective actions are adequate, no further action will be taken and the RSC will be informed of the case at the next regularly scheduled meeting of the RSC. If, however, the chair of the RSC considers that disciplinary action or suspension of the permit may be warranted, he will refer the case to either the entire RSC or appoint an ad hoc subcommittee to review the case and make a determination. If warranted, the permit holder may be requested to appear before the ad hoc subcommittee or the entire committee. Disciplinary actions will be intended to discipline the Permit Holder or the responsible party for repeated violations or for particularly flagrant or egregious violations of regulations or radiation safety practices. A list of possible corrective and disciplinary actions is in sections 3 and 4 below. In the case of particularly willful, flagrant, or egregious violations of regulatory requirements, radiological safety requirements, or health and safety practices, the RSO may immediately suspend a Radioactive Materials Permit and all work under it. Such suspensions will be immediately referred to the RSC Chair for concurrence. In the absence of concurrence, the Permit will be reinstated immediately. If the RSC Chair agrees with the suspension, a subcommittee of the RSC will be formed to determine subsequent actions to be taken. Upon completion of all corrective or disciplinary actions, the RSO will perform a follow-up inspection of all spaces listed under the Permit in question to verify compliance with all required actions, regulations, and standards. Following successful completion of this inspection, the RSO will recommend restoration of the Permit and resumption of radiological work. Following Permit restoration, inspections will be performed monthly for a three-month probationary period, after which the normal (quarterly) inspection periodicity will resume. Further violations noted during this probationary period will result in a recommendation for further corrective or disciplinary actions. Copies of all notices of major violations will be sent to appropriate Department Heads. Copies of correspondence resulting from an excessive number of violations will be sent to appropriate Department Heads and Deans. Copies of correspondence regarding Permit suspensions will be sent to appropriate Department Heads, Deans, and Vice Presidents. 22.1.3 Major Violations 22.1.3.1 Loss of security for radioactive materials in excess of 1 mCi aggregate activity 22.1.3.2 Eating, drinking, or food storage in radiologically posted laboratory space 22.1.3.3 Use of radioactive materials by untrained personnel 22.1.3.4 Use of radioactive materials in an unposted lab or room 22.1.3.5 Radioactive contamination in excess of 10,000 dpm/100 cm2 in a posted area Radiation Safety Manual 67 22.1.3.6 22.1.3.7 22.1.3.8 22.1.3.9 22.1.3.10 22.1.3.11 22.1.3.12 22.1.3.13 22.1.3.14 22.1.3.15 22.1.3.16 22.1.3.17 22.1.3.18 22.1.3.19 22.1.3.20 Radioactive contamination in excess of 1000 dpm/100 cm2 in any unposted area Unauthorized receipt, transfer, or shipping of radioactive materials Loss of radioactive materials Evidence of internal exposure of radioactive materials resulting from abnormal incidents Failure to wear required radiation dosimetry Radioactive materials in nonradioactive waste containers Evidence of liquid radioactive waste disposal into laboratory sinks Persons using radioactive materials while person or laboratory is under suspension Unlabeled contaminated laboratory equipment Failure to wear proper personal protective equipment (lab coat, gloves, etc.) Failure to participate in required bioassay programs (if appropriate) Failure to perform and document monthly radioactive contamination surveys during months in which radioactive materials were used Pipetting by mouth Use of radioactive materials or a class IIIa or higher laser by untrained personnel, OR use of radioactive materials or a class IIIa or higher laser without the proper PPE. Defeating or disabling any safety interlocks or other safety features on any class IIIa or higher laser 22.1.4 Minor Violations 22.1.4.1 Evidence of eating or drinking in a radiologically posted room (i.e., presence of candy wrappers, soda cans, coffee-stained cups, etc.) 22.1.4.2 Loss of security for any amount of radioactive materials less than 1 mCi aggregate activity 22.1.4.3 Presence of radioactive contamination more than 1,000 dpm/100 cm2 and less than 10,000 dpm/100 cm2 in a posted room 22.1.4.4 Presence of detectable radioactive contamination less than 1000 dpm/100 cm2 in any unposted area 22.1.4.5 Survey meter out of calibration or use of inoperable survey meter 22.1.4.6 Radioactive check source not available for contamination survey meter 22.1.4.7 Incorrect documentation of radioactive materials inventory (i.e., no decay corrections; total activity present in waste plus stock vials does not agree with activity received and not disposed; failure to return inventory verification form) 22.1.4.8 Improper waste segregation 22.1.4.9 Score of less than 50% on verbal quiz administered during inspection (Note: Personnel failing a verbal quiz may be suspended from radioactive materials use pending attendance at a normally scheduled Radiation Safety training class.) 22.1.4.10 Failure to demonstrate proper radiological survey techniques 22.1.4.11 Poor radiological housekeeping 22.1.4.12 Improper use of a fume hood, absorbent pads, or bench covers not used in radiological work or storage areas 22.1.4.13 Failure to post Texas State information notice 22.1.4.14 Failure to remove or obliterate radiological symbols from empty containers 22.1.4.15 Failure to report a radiological incident (spill, skin contamination, loss of radioactive material, etc.) to RSO within 2 hours of its occurrence Radiation Safety Manual 68 22.1.4.16 22.1.4.17 22.1.4.18 22.1.4.19 Failure to take appropriate immediate actions in the event of radiological emergencies such as spills or skin contamination incidents Use of a class II or lower laser by untrained personnel, OR use of a class II or lower laser without the proper PPE. Defeating or disabling any safety interlocks or other safety features on any class II or lower laser Any other activities that violate Texas State regulations or the provisions of the referenced documents. 22.1.5 Examples of Possible Recommended Corrective or Disciplinary Actions 22.1.5.1 Temporary suspension of an individual’s authorization to use radioactive materials pending refresher training 22.1.5.2 Permanent suspension of a specific individual’s authorization to use radioactive materials at the HSC 22.1.5.3 Mandatory refresher training for all personnel listed under a radioactive materials permit 22.1.5.4 Suspension of authorization to order radioactive materials under a specific Permit for various periods of time up to two months 22.1.5.5 Suspension of Radioactive Materials Permit for periods of time up to one year 22.1.5.6 Complete revocation of Radioactive Materials Permit and the ability of specific individuals to use radioactive materials under any other permit at the HSC Radiation Safety Manual 69 Section 23. Records 23.1 GENERAL RECORD-KEEPING REQUIREMENTS 23.1.1 MRB and IRM campuses Retention periods are included in parentheses. 23.1.1.1 permit records (life of permit) 23.1.1.1.1 approved application for permit with original RSC signatures 23.1.1.1.2 all amendments, requests for amendment, and Permit renewals 23.1.1.2 receipt, transfer and disposal records for every licensed source of radiation (1 year after final disposal) 23.1.1.3 copies of inventory reports (1 year) 23.1.1.4 radiation surveys (3 year) 23.1.1.4.1 contamination surveys 23.1.1.4.2 radiation field surveys in restricted areas 23.1.1.4.3 radiation field surveys in unrestricted areas 23.1.1.5 survey instrument calibrations (3 years) 23.1.1.6 personnel records (1 year) 23.1.1.6.1 worker/user lists 23.1.1.6.2 training records 23.1.1.7 operating and emergency procedures (current) 23.1.1.8 procedure manuals (current) 23.1.1.9 records of radiation safety training performed by the Permittee (3 years) 23.1.2 In addition to maintaining duplicates of all records in step 1 (except 1.d, 1.g, and 1.i above), the RSO shall maintain the following records which are available for review during normal office hours. 23.1.2.1 original copy of all radioactive material licenses issued to HSC 23.1.2.2 official inventory records 23.1.2.3 inspection reports and copies of all “Notices of Violation” issued by state or federal regulatory agencies and the HSC responses to those Notices. 23.1.2.4 current version of all policy manuals and procedure manuals 23.1.2.5 calculations and reports as required for compliance with the Clean Air Act for radionuclide releases from HSC facilities 23.1.2.6 dosimetry records 23.1.2.7 leak test results 23.1.2.8 survey instrument calibrations 23.1.2.9 Radiation Safety Program review 23.2 INFORMATION REQUIRED ON SPECIFIC RECORDS MAINTAINED BY RSO 23.2.1 Radioactive material receipt surveys, radiation surveys, and contamination surveys 23.2.1.1 records shall be in units of dpm, becquerels (Bq), µCi, mR/h, mrem/h, etc., as appropriate. Units of “cpm” or “counts” are not acceptable for quantitative survey records. 23.2.1.2 records shall uniquely identify the source of the radiation 23.2.1.3 records shall clearly indicate the areas surveyed (include a map) 23.2.1.4 records shall indicate the person performing the survey and date of survey Radiation Safety Manual 70 23.2.1.5 records shall uniquely identify the survey instrument used, i.e., serial number, or other unique description 23.2.2 Training records are specified in Section 8 Radiation Safety Manual 71 Section 24. APPENDICES A. Signs and Labels 1. Notice to Employees / Document Locator 2. Laboratory Safety Data Sheets B. Forms 1. Application for a Permit for the Use of Radioactive Materials at HSC 2. Permit to Use Radioactive Material at HSC 3. Radioactive Materials Permit Amendment Form 4. Radioisotope Package Survey Record 5. Isotope Tracking Form 6. Radioactive Material Waste Disposal Record 7. Request for External Dosimetry Service 8. Declaration of Pregnancy 9. Thyroid Bioassay Record 10. Radioisotope Lab Contamination Survey Record 11. Application for Subregistration of X-Ray Producing Machines 12. Permit to Use X-Ray Machines at HSC 13. Application for Subregistration Amendment (X-Ray) – Equipment Change 14. Application for Subregistration Amendment (X-Ray) – Personnel / Location Change 15. Application for Use of Radioactive Materials in Animals 16. Application for Subregistration of Laser Systems 17. Permit to Use Lasers at HSC 18. Application for Subregistration Amendment (Laser) – Equipment Change 19. Application for Subregistration Amendment (Laser) – Personnel / Location Change 20. RAM Purchase Requisition Form Radiation Safety Manual 72
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