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"Radiation Safety Procedures and Training for the Radiation Safety Officer" is designed to provide radiation safety officers and users/operators of devices using radiation with the tools needed to operate a safe program, construct training materials and courses, AND to comply with regulatory requirements. It is centered primarily around radioactive materials license requirements, but much of the material can be applied to non-healing arts x-ray, accelerator, and laser operations and registrations. All of the information consists of either original text created by the author or compilations of regulatory information/requirements and of common knowledge scientific information found in standard tables and references. A minimal amount of radiation principles are offered to provide the reader/user with enough information to proceed through the material and operate a safe radiation program.

Chapter 6: Radiation Safety Officer Duties and Permit Procedures

1. Introduction
The radiation safety officer is the key person in any program that uses radiation. In general, radiation control regulations require the identification of a qualified person who will assure that all radiation safety functions are carried out, no matter how trivial they may be. This chapter addresses the procedures that the radiation safety officer will need to attend to.

2. The Radiation Safety Officer

Radiation Safety Officer
Qualifications, Duties
The Radiation Safety Officer, often referred to as the “RSO”, is the person assigned by the licensee or registrant to assure that all regulatory requirements and all radiation safety requirements are met. The RSO usually is the person that deals directly with the regulatory agency on all matters relating to the license or registration. The RSO’s supervisor is also an important position in the system as the regulatory agency will go to that person if the RSO fails in fulfilling his/her duties.

The rules require that an RSO be designated for every license issued by the agency. A single individual may be designated as RSO for more than one license if authorized by the agency. Large educational and medical facilities, which may have several licenses, often assign one person to be the RSO for all permits, licenses and registrations. Facilities with broad licenses will be required to establish a “radiation safety committee” (RSC) to oversee the radiation safety obligations. The RSC will govern the operations usually carried out by the RSO.

Radiation Safety Officer Qualifications*
The overall qualifications required of RSO’s can vary according to the regulatory body with jurisdiction. The basic or minimum qualifications are:

> possession of a high school diploma or a certificate of high school equivalency based on the GED test
> completion of the training and testing requirements specified in this chapter for the activities for which the license application is submitted
> training and experience necessary to supervise the radiation safety aspects of the licensed activity.

There will be additional requirements for certain licenses, such as: industrial radiography, well-logging, broad (scope), and most medical licenses. These will be addressed during discussion of the licensing process.

Radiation Safety Officer Duties
The specific duties of the RSO include, but are not limited to, the following:

Operating, Safety, Emergency, And ALARA Procedures
Establish and oversee operating, safety, emergency, and as low as reasonably achievable (ALARA) procedures (OSEP), and to review them at least annually to ensure that the procedures are current and conform with regulatory requirements. This is an important and primary duty of the RSO. Properly done, the RSO will probably not have very many regulatory problems nor embarrassing incidents. A well organized OSEP that conforms to the rules is an important step in the licensing process. If too few requirements are addressed, license issuance following application can take a very long time. If unnecessary procedures are adopted, compliance will be a major effort. Too many times an applicant will include unnecessary procedures in their application or OSEP because they mistakenly think that the agency will be more amenable to issuing the license promptly. All procedures should be appropriate and straightforward.

Oversee and approve all phases of the training program for operations and/or personnel so that appropriate and effective radiation protection practices are taught. A second, very important element of a solid radiation safety program is training for workers and all persons involved in the use of radiation. Most accidents, after investigation, that are not due to equipment failure are found to be due to inadequate training of the radiation worker. In some use areas, such as industrial radiography, well-logging, and medical, for example, specific training elements are required and courses must be approved by the agency. Periodic refresher training should also be incorporated, although not always required by the rules.

Radiation Surveys and Tests
Ensure that required radiation surveys and leak tests are performed and documented in accordance with the rules, including any corrective measures when levels of radiation exceed established limits. The appropriate types of radiation surveys and records are determined during the licensing process. Radiation surveys usually consist of radiation level surveys of use areas, storage areas, and transport. There are also surface contamination surveys that may be needed in the same areas. Leak test procedures were discussed in Chapter 3. How does one stay on the required schedules? Some RSO’s simply mark their paper calendar. Others, perhaps the more successful, make use of the calendar software of the computers that sit on nearly every desk. The rest seem to periodically be corresponding with the agency regarding notices of violation.

Personnel Monitoring
Ensure that individual monitoring devices are used properly by occupationally-exposed personnel, that records are kept of the monitoring results, and that timely notifications are made according to reporting requirements for overexposures. Monitoring systems are important for both assessing personnel exposures and tracking personnel work habits. An employee consistently receiving higher exposures than other workers doing the same work needs to have his/her work procedures reviewed. Higher exposures often show the worker’s indifference to the requirements and to his/her own well-being and such an employee may be an “accident waiting to happen”. Identification of such employees and retraining may prevent major compliance problems. The time limits of reporting should be adhered to.

Investigate Radiation Incidents
Investigate and cause a report to be submitted to the agency for each known or suspected case of radiation exposure to an individual or radiation level detected in excess of limits established by the rules and each theft or loss of source(s) of radiation, to determine the cause(s), and to take steps to prevent a recurrence. Prompt investigation and correction of any causative problems helps to mitigate the actions that an agency may take for violations that are involved in radiation incidents. The agency will probably look closely at proposed methods for preventing recurrence. Reporting requirements are discussed in Chapter 4, Section 3.

Releases to the Environment
Investigate and cause a report to be submitted to the agency for each known or suspected case of release of radioactive material to the environment in excess of limits established by the rules. Releases that remain onsite are fairly easy to handle. Releases offsite create additional problems since communities become quite concerned when hazardous materials blow into their areas. Again, the time limits of reporting should be adhered to.

Management and Administration Policies and Procedures
Have a thorough knowledge of management policies and administrative procedures of the company holding the license. As the interface between the licensee and the agency, the RSO must have a complete knowledge of the company’s management policies and must be able to effectively deal with the administration.

John R. Haygood earned a B.A. degree in physics at the University of Texas, Austin, and an M.S. degree in Environmental Science, with a major in Health Physics, from the University of Texas Health Science Center at Houston. He is also a Texas Licensed Medical Physicist. He has over 30 years of experience in regulation of radiation use as well as an additional 10 years of consulting in radiation regulatory and safety processes. He and his wife live in Round Rock, Texas.

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