RPPM 3.0 Responsib.+ Implement.

3.1 Radiation Safety Office (RSO)

The RSO is responsible for maintaining support programs and services to assure safety and compliance in all possession and use of ionizing radiation at RSC-approved, posted radiation use locations.
The RSO support programs and compliance assurance activities include:
ALARA oversight through on-going assessment of:
Worker radiation exposure levels;
Routine monitoring of radiation exposure levels in restricted use areas and areas adjacent to these posted locations. Monitoring is performed using:
- Direct meter surveys performed by RSO staff to obtain immediate measurements of ambient radiation exposure levels;
- The placement of environmental dosimeters for weekly, monthly or quarterly assessment of ambient radiation levels.
Oversight of ordering, receipt, survey, and delivery of radioactive material;
Maintenance of radioactive material, radiation machine and radiation protection instrument inventory tracking systems, records and reports;
Assurance of appropriate radiation protection instrument quality control;
Performance of routine radiation use and restricted area audits and surveys;
Performance of bi-annual leak testing and physical inventories of sealed sources;
Oversight and inspection of radiation-generating machines and facilities;
Packaging, labeling, and surveying of all out-going shipments of radioactive material;
Maintaining a radioactive waste disposal program;
Verification and documentation of proper decommissioning of radiation facilities and equipment;
Investigation and report preparation for radiological incidents including any unexpected release of radioactive materials or exposure of individuals;
Maintenance of RPP records through their required regulatory retention period;
Spill, Incident and Radiological Emergency Response.

The RSO is responsible for implementing all directives of the WA DOH and the University Radiation Safety Committee in support of the RPP.
The RSO’s administration of the Radiation Protection Program is audited annually by the Radiation Safety Committee to ensure that the University’s RPP is compliant with all Federal and State regulations and that radiological safety is being appropriately maintained.
Each RSO support program is outlined in more detail below in RPPM 3.4.

3.2 Authorized Users of Radiation

An approved Authorized User (AU) is considered to be a sub-licensee of all applicable licenses, permits and/or machine registrations.
By applying for and accepting an Authorization to use radiation in their work activities at the University, an AU is committing to adhere to:
The policies outlined in SPPM Chapter 9.0, Radiation Safety and in RPP requirements and protocols, as outlined in this RPPM;
All applicable regulatory, license and Radiation Safety Committee requirements and directives.
An Authorized User must be a permanent member of the University faculty or staff and must be authorized (sub-licensed) by the Radiation Safety Committee for each specific type(s) of use (i.e. – research or teaching; radioactive materials or machines) they wish to participate in.
The Authorization application submission and review process is administered by the RSO and RSC (see RPPM 4.0).
An approved Authorized User is responsible for:
Submitting all required Amendment and Renewal applications to assure on-going and timely updating and RSC review of their Authorization(s) with regards to:
All planned use(s) of sources of ionizing radiation and use facilities;
All required inventory control and security of sources of radiation held under their Authorization;
All safety and ALARA protocols put in place to assure the safety of radiation workers; the general public; and the environment.
Operating in conformance with all applicable University licenses, permits and policies, and the regulations of federal, state, local radiation control entities;
Implementing standard operating and emergency procedures for managing all sources of ionizing radiation and any uses or use locations;
Training of employees and/or students in specific safety practices, correcting work errors, identifying and correcting inappropriate working conditions, and developing accident prevention awareness in workers;
Responding to spills, releases or loss of control of any source of radiation held under their Authorization;
Properly decontaminating equipment and facilities as needed to meet regulatory requirements and to maintain safe operations;
Investigating and reporting to the Radiation Safety Office following any incident, accident, unintentional release or exposure of an individual to ionizing radiation;
Ensuring compliance with all radioactive material acquisition, inventory control, security, transfer, shipping, transport and disposal requirements;
Maintaining control and security for all sources of radiation in their possession until their Authorization has been formally deactivated (terminated) by the RSO and/or RSC.

All AUs must be familiar with the RSO support programs and services that are applicable to their use(s) of radiation at the University (see RPPM 3.4) and should seek the guidance of the RSO (wsu.edu) whenever questions arise related to radiological safety and compliance.

3.3 Radiation Workers

The term “radiation worker” is used to identify an individual who is approved to use a source of ionizing radiation in their work or study at the university.
The individual may be a principal investigator, undergraduate or graduate student, technician, post-doctoral research associate, visitor, or any other individual who has a:
Current, legal affiliation with the University;
Sponsoring AU who will supervise their work, or are the approved AU of record on the Authorization;
Need to use radioactive materials or radiation machines in their work or study.
A radiation worker must be pre-approved by the RSO (see RPPM 3.4 and A) and must assume certain responsibilities in their work with ionizing radiation;
Radiation safety and compliance begins and ends with the individual who handles the source(s) of radiation. Only the individual actually performing the work can assure that the source of radiation is handled safely and in compliance to regulations and policies;
The radiation worker is the “first line of defense” in protection of people and the environment against undue risks of radiation exposure and/or contamination;
It is critical that all radiation workers be aware of the risks, safe practices and requirements for the use of ionizing radiation and specifically the sources under their control.

Radiation workers should adhere the following guidelines
Each worker must complete required training associated with their responsibilities as a radiation worker, including:
All required basic (initial) and refresher on-line training modules applicable to their use(s) of radiation that are provided at RSO training;
All function and use specific training provided by the Authorization(s) under which they work.
Workers are responsible for adhering to all laws, rules, regulations, Authorization and University license conditions that pertain to their use(s) of radiation;
Workers must practice ALARA (As Low As Reasonably Achievable) in their work in order to minimize the potential for exposures, contamination or release of radioactive materials;
Workers are responsible for maintaining security of radioactive materials or any machines capable of producing ionizing radiation in their work area(s);
Workers must wear their assigned radiation dosimetry or radiation worker ID tag and must wear appropriate PPE (personal protective equipment) when in a restricted area of the University (see RPPM 10A);
Workers are responsible for informing the RSO of unsafe situations or compliance concerns within their work area and of any unplanned and/or unexpected exposures to them self or others that occur during their employment or study at the University.

All radiation workers must be familiar with the RSO support programs and services that are applicable to their use(s) of radiation at the University (see RPPM 3.4) and should seek the guidance of the RSO whenever questions arise related to radiological safety and compliance (wsu.edu).

3.4 RSO Support and Service Programs

3.4.1. Radiation Worker Training, Safety and Exposure Tracking

3.4.1.1 Radiation Worker Training and Approval

Individuals seeking initial approval to be a radiation worker, or a previously approved radiation worker at this University who has had a lapse in active use for two or more years, must:

Complete all required basic radiation safety training that is appropriate and required for their future planned use(s) (see RPPM 10.A).
Have a sponsoring Authorized User who has agreed to supervise their work and provide training appropriate to their planned future use of radiation;
Complete and submit to the RSO an Application to be a Radiation Worker (see RPPM 10.A and 10.E);
Respond in a timely manner to RSO dosimetry coordinator requests for information and/or clarifications regarding their application and planned use(s) of radiation;
Complete all AU-provided hazard and task specific training relative to the specific work they are assigned; are responsible for; and tasks they are required to perform.

Radiation Worker Training = Radiation Protection
The RSO provides basic radiation safety training via on-line modules at RSO Training;
RSO on-line basic radiation training and refresher training modules are appropriate to maintain safety and compliance at the University (see RPPM 10A);
Upon successful completion of each training module quiz, a record of completion of the training is documented and maintained for each worker on the Office of Research electronic records management system (MyResearch).
Additional types of training offered is offered to specific groups of workers and includes:
Regulatory-required and/or RSC-directed as results from a “corrective actions directive”;
In-lab radiation protection program orientations for new AUs and/or update training for AUs, laboratory supervisors or radiation workers resuming work following a prolonged lapse in radiation use;
RSO on-line module radiation hazard awareness training for ancillary staff and visitors who are allowed un-escorted access to a restricted areas and/or who are concerned about their personal safety at the University;
Limited, site and/or project specific training for maintenance and contracted worker who are required to work near areas where there are radiological hazards;
Underage worker radiation safety awareness training (worker and guardian);
Declared pregnant radiation worker hazard awareness training, and, if requested, confidential fetal risk counseling.
The RSO verifies during routine audits of radiation use facilities the required hazard awareness and function specific training is being provided and documented by the Authorization. This training may include:
AU-provided hazards awareness training for individuals who routinely are allowed unescorted access to an AU-supervised radiation use area(s);
Radiation worker training that is specific to the hazards held in inventory and to the responsibilities assigned to a radiation worker under the Authorization;
Site and work project specific safety training for maintenance and contracted workers who are required to enter a restricted area;
Underage worker and/or University volunteer hazard awareness training for both the worker and/or parental guardian who approved an under-aged worker’s participation in a radiation use activity.

Radiation machine operator training
A radiation worker must be complete and document performance-based training for each specific machine the worker is approved to operate;
The machine training log must list the name of the worker, the trainer, the date of training; and any limitations assigned to the specific worker relative to the use of the machine.
Each machine operator must be trained in emergency response protocols for the specific machine and use area.

3.4.1.2 Radiation Worker Safety and the Assurance of ALARA

All Authorized Users and their radiation workers are to use all reasonable methods to reduce exposure to radiation and to maintain safety.

Many factors influence the success of the ALARA program, including:
Pre-planning and written radiation safety; radiation use; and spill and emergency response protocols that are known and used by all radiation workers;
The performance of routine audits of radiation use areas by AUs and the RSO to identify possible non-ALARA issues and to allow the timely implementation of corrective actions to improve radiation safety;
On-going review of occupational radiation exposures and the timely investigation of exposure circumstances, with implementation of corrective actions by the RSC and URSO when a breach of the ALARA policy is identified.

3.4.1.3 Exposure monitoring for Radiation Workers

External Exposure Tracking for Individual Radiation Workers
The RSO provides dosimetry to radiation workers who, in their work at the University, are at risk to receive 10% or more of their annual exposure limit (see RPPM 10.A).
The RSO bases the determination of a worker’s need for dosimetry:
On the worker’s described plan for use of radiation, as specified in their application to be a radiation worker;
The Authorized User’s plan(s) and description of the work and use(s) the worker will be participating in under their Authorization.
The RSO also assigns dosimetry to workers if there type of radiation use is associated with a risk for a high exposure event, even though their routine work is of a low potential risk (i.e. – reactor operators; veterinary technical personnel; accelerator operators, etc.);
Each worker assigned dosimetry must wear their dosimetry whenever they are in a designated University radiation use area;
Dosimetry must be stored at in a low backgound area of the Authorization’s use facility when not in use (evenings and weekends);
There must be a timely exchange of dosimetry at the RSO’s established exchange interval (monthly or quarterly) so that exposure readings can be determined in a timely manner to facilitate effective corrective actions to assure ALARA.
RSO-provided ID tags for radiation workers not assigned dosimetry
When the potential for radiation exposure (risk) to a worker is less than 10% of the occupational annual limit, the RSO provides the radiation worker with a identification tag;
The radiation worker must wear their radiatio n worker ID tag whenever they are in a designated radiation use area at the University;
The ID tag allows radiation safety auditors who enter a work area (RSO or WA DOH) to quickly identify personnel who have radiation safety training and are approved to be in a restricted area;
A worker must contact the RSO dosimetry program if their type of radiation use changes or the number of hours working with radiation significantly increases so that their need for dosimetry can be re-assessed.

Bioassays for Assessment of Internal Radiation Exposure
Iodine radionuclides (I-125 and I-131) and tritium (H-3) are of primary concern when considering the need for internal exposure monitoring.
Radioiodines are hazardous and volatile radionuclides. The RSO performs thyroid scans (timed direct meter counts) to evaluate a worker for an intake and potential for receiving an internal dose to their thyroid glands following the use of unbound and un-contained radioiodine(s) (see RPPM 10.B);
Tritium is among the least hazardous of radionuclides with regards to external exposure, but is easily absorbed through the skin and can be an internal dose hazard. An in vitro procedure (urinalysis) for H-3 concentration is used to detect and measure the intake of tritium by a worker.
The RSO will notify an Authorization if the possession limit and use of H-3 could put a worker at risk and if bioassay procedures are required;
When required, tritium screening bioassays must be performed by the AU and radiation worker using an RSO approved assay protocol;
The RSO will use a qualified, WA DOH-approved service provider (analytical lab) to confirm and follow-up any significant positive tritium screening bioassay result to document and maintain an accurate record of the worker’s combined external and internal annual dose to assure ALARA and regulatory limits are maintained.
An accidental high exposure to a dispersible form of certain other radionuclides could require a radiation worker to participate in an internal dose determination protocol. The RSO will perform, or will arrange for a qualified expert to perform, any needed evaluation of a potential internal exposure;
The RSO will notify an AU when their dispersible RAM use(s) protocol indicates there will be, or has been, a potential for an internal intake that requires a workers entry into the bioassay program.

Radiation worker exposure records
An individual worker’s radiation dose records are confidential and the release of this information is restricted to the individual and the University staff who are responsible for ensuring radiation safety at the University (RSO, RSC members and supervisory AU).
Individual worker exposure records are only provided to other appropriate entities (i.e. – other licensed employers) upon written authorization from the radiation worker to the RSO;
A copy of each worker’s annual exposure report for the prior calendar year, or last calendar year that they were a radiation worker, will be made available to the worker upon written request.
At the time of the request, the individual must provide the RSO with an address or preferred method for the transmission of their confidential record;
The annual reports are made available to the RSO by the contracted dosimetry service provider shortly after the first of each calendar year.
If a radiation worker is employed or working with sources of radiation under more than one licensed entity during a calendar year (i.e. – employed by WSU and another licensee that has an exposure tracking program), the RSO is required to document the individual’s total occupational exposure for that calendar year.
The worker must provide the RSO with a signed Radiation Worker Exposure Record Release Form authorizing the RSO to obtain radiation exposure reports from the licensed alternate employer(s) (see RPPM E, RSO Forms);
For worker’s who are assigned dosimetry, the worker’s annual dose report for any year of radiation work at the University will include the worker’s tracked occupational exposure for all licensed sources of radiation.

3.4.2 Radioactive Materials Receipt, Inventory, Control and Security

Delivery of packages containing RAM to University locations
- Pullman campus
Central Receiving (CR) and/or RSO Deliveries
The RSO picks-up RAM-containing packages that are delivered to CR by commercial carrier (i.e. – FedEx) shortly after the delivery on each work day;
Courier deliveries (i.e. – radiopharmacy deliveries) may be made to CR or, with pre-notification, directly to an RSO posted facility (i.e. – Dodgen building);
Radiation workers and security and business office personnel are not to accept direct delivery of package(s) that contain radioactive material at any time (business or non-business hours) unless a pre-approved receipt and packaging protocol is in place and all workers receiving deliveries have received function-specific DOT compliance training.
RSO Pullman campus RAM package re-delivery to Authorization location(s)

The RSO performs a compliance and safety assessment of all in-coming RAM-containing packages at a secure, RSO-counting laboratory. The process includes the following steps:

Inspection of the condition and DOT-regulatory compliance of the package;
Inspection of shipping papers to verify the documentation is compliant and accurate, including verification that the package contents are as indicated on the pre-approved requisition form or transfer request form;
Entry of the RAM receipt information into the all University RAM inventory tracking database (AU name: material description and quantity, date of receipt and radiation worker accepting delivery; approved location of secure storage and use);
Measurement of exposure readings and contamination surveys performed on the outside of the package to assure regulatory compliance and safety;

NOTE: Unless there is visible damage to the package, the RSO verifies that there is no radiation risk associated with the outside of the package only. All radiation workers must wear appropriate PPE and follow proper protocols for opening and documenting the receipt of radioactive material (see RPPM 10.B).

If the receipt; data related to the material; and safety surveys are correct and compliant:
The package is re-delivered to the recipient AU’s secure RAM posted location;
The RSO provides a copy of the RSO Package Receipt and Survey Form for the Authorization’s records.

RSO-handling and resolution of RAM package receipt and re-delivery problems
If the RSO identifies a safety or compliance problem with an in-coming RAM package, the package is held at the RSO counting lab until all safety, inventory record, possession limit, or other issues are resolved;
If there is visible damage to an in-coming RAM-containing package, the RSO may contact the material provider; shipping contractor; and/or AU to determine appropriate handling of the package and disposition of the contents.
If there is an unsafe level of contamination or radiation exposure levels, the package will “bagged and tagged” for appropriate disposal. The WA DOH and commercial carrier will be notified so that any public contamination hazards may be investigated and controlled.
If the contamination level on an in-coming is measureable but within DOT compliance levels, the package may be “bagged and tagged” and the AU consulted.
The package may be:
Delivered to the AU’s facility and responsible laboratory personnel notified to assure the package is processed using appropriate safety and contamination control methods;

Designated as unusable and “bagged and tagged” for appropriate disposal. The RSO and/or AU will contact the provider and notify them of the contamination problem and required corrective action.

If the RSO cannot assure proper security and/or handling of an in-coming RAM package at the time of attempted re-delivery at the recipient location, the package is returned to the RSO counting lab. The lAU and/or lab supervisor will be contacted via the contact phone numbers listed in the RSO Authorization file.
The AU and/or ordering department must confirm with the vendor and/or commercial package delivery service that orders of perishable materials will be scheduled to arrive during non-business hours (i.e.- weekends and holidays). It is recommended that all RAM packages be scheduled for arrival on the Pullman campus:
Early in the week and/or only on University business days;
Before 3:00 p.m. on any work day (2:00 p.m. in summer).

Non-Pullman Radioactive Materials Package Receipt and Processing
Federal and State shipping laws and regulations apply to all receipt of packages containing radioactive materials.
The package delivery location (campus CR or a specific building/office at a research station) must be specified on the vendor’s shipping papers.

NOTE: It is the ordering department’s responsibility to specify the correct delivery address for the provider/vendor when ordering and arranging for the delivery at a non-Pullman location. If a RAM-containing package is miss-delivered to Pullman CR, the RSO will take custodial possession and contact the intended recipient. The RSO does not re-deliver packages to non-Pullman locations.

At the time of a RAM-package delivery, trained receiving personnel (radiation worker who has received RSO-provided and documented DOT package receipt; RAM-package processing; and records management training) must immediately:

Secure and maintain restricted access to the package;

Transport the unopened package to the Authorization’s posted facility;

Process the package into the Authorization’s stock inventory.

NOTE: The RSO must pre-approve any worker who is assigned this responsibility and provide them training in the performance of a RSO pre-approved protocol. The approved protocol is to be followed for the receipt and opening of any RAM-containing packages at the non-Pullman University location.

The radiation worker assigned and performing this responsibility must contact the RSO to arrange for training and protocol pre-approval prior to receiving or handling any incoming RAM packages.

RAM Package Opening Protocol for Authorization Radiation Workers
Broadscope license conditions require that in-coming RAM-containing packages be processed (opened and inventoried) by the AU, or their designee, within 24 hrs of the receipt of the package;
During RSO RAM package re-delivery and/or at the time of routine Authorization audits, the RSO will assess the appropriateness of radiation worker knowledge and ability to follow the required RAM-package opening process as described in RPPM 10.B.

In-lab RAM Inventory and Records Management
A Use Log(s), specifically for each container of RAM stock material(s) received under an Authorization, must be started (created and in place as a record in the use/storage facility) upon the receipt and opening of a newly received package and before placing RAM stock container(s) into their designated secure storage location.
The Use log should record the following information and must be kept up-to-date on an on-going basis RPPM 10.B.

Authorized User Name: _____________________Date Received: _________________________

Radionuclide: ____________________________ Chemical form:__________________________

Activity per vial (mCi): ______________________Reference Date: _____________

No. of vials: ________Concentration (µCi/µl):__________ Original Volume per vial (µl): ________

Vendor_______________________Catalog #: ________________Lot #: _____________________

As material from a stock container is removed and used, or re-alliquoted to smaller stock containers, the radiation worker must record accurate information into the specific stock container’s Inventory/Use Log (i.e. – There must be an entry in the log for each removal of material from the stock container);
Each log entry must include the initials of the radiation worker; the date of removal; volume (amount) of material removed; the estimated percentage and activity of removed material that will be transferred to RAM waste container(s);
The Authorization’s Inventory Use Log management protocol should be the same for every “user” working under the Authorization and must be performed accurately and consistently;
RSO auditors examine use logs, at a minimum, on a quarterly basis;
RSO auditors perform a physical audit of an Authorization’s dispersible RAM stock inventory and Use Log records, at a minimum, on an annual basis.

Security of Radioactive Materials and Stored Radioactive Waste Containers
Whenever the RSO staff is in a restricted area where RAM stocks or radioactive waste containers are stored, they assess the appropriateness of radioactive materials security and the performance of radiation workers in restricting access to the materials (see RPPM 10.A, B, and 10.C);
Security protocols for areas where stocks of radioactive materials, sealed sources and/or radioactive waste containers are stored must assure that an individual who is not listed on the Authorization cannot access stored radioactive materials inventory;
Authorized users and their radiation workers are required to maintain constant surveillance (direct line of sight) on any stock containers that are out of the secure storage location.
The security of radioactive materials stock containers that are not under the direct surveillance and physical control of an authorized user or radiation worker can be accomplished by any effective methodology, including:
Storage in a “lockable” lock box, container within a refrigerator or cabinet;
Storage in a locked refrigerator or freezer;
Storage in a locked room where all entrances are locked when a radiation worker

is not present within the room.

NOTE: If a lock box or other small lockable container is used as a RAM security method, it MUST be physically attached to the larger permanently installed storage unit (e.g., chained, bolted or strapped to the refrigerator) and it MUST be locked so as not to be accessible to individuals not listed on the Authorization.

Sealed sources and radioactive waste containers require the same security considerations given to stock containers of dispersible radioactive materials;

3.4.3 Radiation Protection Instrument Quality Assurance Program

All radiation protection instruments (survey and dose rate meters; LSCs and gamma counters; etc.) used at the University for safety and compliance purposes must be:
Registered with the RSO (wsu.edu);
Tracked in the RSO database that lists the type of instrument (manufacturer and model); serial number; storage location; primary custodian (AU/owner); and the “due for calibration date”.
The Authorization applicants must list the radiation protection instrument that will be available during their use(s) of radiation.
During the application review and approval process, the RSO and RSC evaluate the suitability of the listed instruments for the planned use(s) of radiation, as described in the application (see RPPM 10.A);
If the listed instruments are not appropriate or are considered to be in adequate for safety and compliance, the RSO will contact the applicant.
The RSC may approve an Authorization application with a condition requiring the acquisition of acceptable instrumentation prior to any acquisition and/or use of radiation.
The RSO provides a Radiation Protection Instrument QA Notebook that is to be maintained by the Authorization’s radiation workers at the storage location of each instrument (see RPPM 10.A).
The RSO audits the QA Notebooks on a routine and on-going basis to assure that all instruments used in the RPP are:
Properly maintained and operating to manufacturer specifications.

[NOTE: All maintenance, servicing and repair must be logged in the notebook];

Calibrated on an annual basis and after any repair;
Quality controlled prior to its use for a compliance purpose using a written performance assessment protocol that is included in the QA Notebook. All pre-use operational performance checks are to be logged in a log maintained in the QA Notebook.

3.4.4 RSO Authorization Audits and Facility Inspection/Surveys

Any Authorization and/or facility approved for the use of a dispersible form of RAM is subject to the University policies and procedures as required to document compliance to the University’s Broadscope and Radioactive Air Emissions license (see SPPM, Chapter 9).

The RSO performs audits, inspections and radiological monitoring surveys of all active Authorization facilities approved for a use of radiation or storage of radioactive materials or wastes. The frequency of audits is set by the RSC and URSO, and will be as needed to ensure adequate oversight of safety and compliance at all University locations.

The RSO will modify the audit format as needed to include items specific to the:
Authorization and its approved radiation use(s);
Facilities and safety equipment;
Knowledge and required skills of radiation workers listed on the Authorization;
Any specific area(s) of radiation safety or compliance that requires enhanced oversight.
The RSO auditors evaluate appropriate adherence to ALARA and provide suggestions for improvement or may implement corrective actions if needed.
If an out-of-compliance or safety concern is noted during an audit:
The RSO auditor will point out and discuss the finding(s) with radiation workers in the lab while the audit is being completed and will try to identify the cause and history of the problem;
It is preferred that radiation workers, lab managers and/or AUs address and/or correct an identified problem immediately and resolve the issue before the completion of the RSO audit procedure;
When an identified concern cannot be corrected immediately, the AU will receive a memo from the RSO auditor specifying all non-compliance and/or safety findings and the need for their timely implementation of corrective actions to resolve all concerns.
RSO auditors will perform follow-up visits on an escalating frequency at facilities were there are unresolved safety of compliance concerns and will inform the URSO of any unresolved safety or compliance issues to assure the concern is addressed properly and in a timely manner.

Inactive RAM-use facilities or Inactive Authorizations
An Authorized User may request one or more of their approved RAM use facility(s) be placed into an “inactive status” (see RPPM 10.B). A specific facility inactivation may be requested when the AU:
Is the primary and sole AU approved to use the specified radiation facility;
Has suspended all approved radiation storage and use in the use area;
Has completed and documented contamination surveys and decontamination activities;
Has no plan(s) to re-initiate RAM work in the facility for at least 6 consecutive months.
An Authorized User may request that their Authorization be placed into an “inactive status” if:
They have no dispersible RAM inventory or intend and make arrangement with the RSO to formally transfer all inventory in their possession to another AU or to the RSO;
They have no plan(s) to re-initiate work with RAM under their Authorization for 1-2 years.
They have suspended all use of RAM in the facilities listed on their Authorization and placed all RAM-use facilities in to inactive status;
If the RSO identifies, at the time of routine audits, that an Authorization and/or RAM facility is “inactive”, the RSO may request the Authorization and/or any or all of the approved use facilities be placed into an “Inactive status”.

RSO Audit of Inactive RAM-use facilities or Inactive Authorizations
When an Inactivation Request has been submitted by an AU, the RSO staff will coordinate with the AU and their radiation workers to schedule and complete all actions required for inactivation (see RPPM 10.B).
When a specific radiation use facility, where there has been prior storage or use of a dispersible form of RAM, is in ‘inactive status” the following conditions apply;
The RSO must document by appropriate audits and radiation surveys that the facility is free of, and remains free of:
All dispersible forms of RAM or radioactive waste;
Removable contamination on exposed surfaces;
Radiation field(s) within the facility that are above background.
The RSO will super-impose a notice of “Inactive status” over the RAM postings at the entrance(s) of the facility;
The URSO will provide the AU with an updated Cover Sheet for their Authorization, that must be posted in a conspicuous location, that describes all changes and modifications of the Authorization and applicable conditions, including an appropriate reduction in periodicity survey requirements;
The RSO will not deliver RAM packages to the facility;
There can be no RAM use in the facility until it is formally re-activated by the RSO and the AU has received a written notification and updated Authorization Cover Sheet indicating the re-activation from the URSO;
The AU must maintain full control of the facility and appropriately restrict access and use (i.e.- no food and drink restrictions remain in place though-out the inactive period);
Use of the facility, it’s primary function, must remain the same (i.e. – a research lab);
There can be no significant remodeling or re-assignment of the facility without the pre-approval of the RSO or RSO-documented decommissioning and free-release of the facility;
All prior Inventory, use and survey logs must be maintained within the facility of in immediate proximity and available for inspection by the RSO and WA DOH auditors;
There can be no storage of RAM stock materials or radioactive waste or waste containers in the facility and no transport of RAM through the facility if it is not in tertiary containment;
The facility will remain in the RSO Audit and Survey Program, but RSO oversight frequency will be reduced.
When a radiation use Authorization is processed into “Inactive Status”, the RSO:
Any standing blanket orders will be suspended and the RSO will not approve any new radioactive materials acquisitions;
All dosimetry assigned to radiation workers under the Authorization will be suspended;
The requirement for the performance of periodic facility surveys will be suspended;
All approved use facilities must be processed into inactive status, as described above;
Inventory records, Use Logs and Survey records must remain in the use facility and must be available to WA DOH inspectors.
RAM posted facility control and restrictions must be enforced by the AU and lab personnel (i.e. – No food and drink).
[NOTE: these requirements will remain in place until the facility is, at some future date, processed though to a formal decommissioning and free-release.]
When an Authorization remains in a prolonged inactive period (> 2 years), followed by a request for a re-activation of an Authorization,:
The AU must submit an Authorization Amendment application for review and approval by the RSC. No acquisition or work with radiation may be initiated until the Authorization re-activation is approved and processed by the RSC and RSO;
All radiation workers listed on the amended application, including the AU, must document proper up-dating of their radiation safety training and skills.
The URSO may require an Authorization that remains in a prolonged Inactive status over two years to de-activate (terminate) the Authorization; inactivate all facilities and to eventually decommission all RAM use facilities as soon as possible. NOTE: Facilities must be emptied and cleared of all movable materials and equipment for complete cleaning and a thorough RSO or WA DOH verification decommissioning survey before they can be free-released for an alternate (non-RAM) use.

Authorization Terminations and Facility Decommissioning
An AU may initiate a deactivation (termination) of their Authorization and decommissioning of their RAM use facilities (either concurrent or as independent events) by notifying the RSO (wsu.edu).
An RSO staff member will contact the AU to facilitate the request;
The AU must maintain control and restriction to access to all facilities and equipment that have been associated with the use or storage of dispersible forms of RAM until the RSO free-releases the facility or equipment for an alternate use (see RPPM Chapters 5, Chapter 6 and 10B, 10C).
The AU must have trained radiation workers who are listed on their Authorization clear, clean and survey their use areas prior to contacting the RSO to schedule a decommissioning verification survey;
If an AU is not available to oversee an Authorization deactivation (termination) and/or the decommissioning of their posted facilities and equipment (i.e. – due to illness; resignation; and/or an unplanned departure from the University) the RSO will contact the department head to coordinate the Authorization deactivation and facility decommissioning process.
The department must maintain control and restriction to access to all facilities and all potentially contaminated and posted equipment.
Only trained radiation workers from the department who are listed on the Authorization and/or who are familiar with the types of radiation hazards held under the Authorization may clear, clean and survey the facilities that had been used under the Authorization.

3.4.5 Sealed Source Management and Control (also see RPPM Chapter 10.C)

Specifications for designation of a radioactive item (material) as a radioactive sealed source
The definition and descriptions used in WAC regulations will apply for all licensed materials that are designated as sealed sources of radiation under the University’s Broadscope license (http://apps.leg.wa.gov/wac/default.aspx?cite=246-220-010);
The final designation of whether a material will be inventoried, tracked, handled and controlled as a sealed source” will be made by the URSO, following any specific clarification required from the WA DOH.

Sealed Source Inventory Tracking
- The RSO maintains a tracking database of all sealed source inventory held by each Authorization.
- The information maintained by the RSO on each sealed source enables the University (licensee) to provide regulators with an all-inclusive sealed source inventory report, as required by licensing and regulations;
- The RSO database tracks the most recent physical inventory date and wipe testing results for each sealed source, or the date the source was removed from inventory through to its disposition transfer or disposal through the RSO waste management program;
- The information tracked by the RSO for compliant records management includes the :
Radionuclide(s) within the sealed source;
Source manufacture date, model number, activity, serial number;
Any assigned uniqueIdentifier for the device;
Current activity of the source, accounting for decay;
Authorized User or entity in possession and control of the source;
Secure storage location of the source;
Record of its final disposal or transfer to another licensed entity.
No sealed source, even those obtained as generally-licensed or thought to be depleted and/or without value are to be transferred or disposed of by the AU or any radiation worker.

Sealed Source Leak Tests
To maintain compliance to the regulatory requirements the RSO will:
Perform a physical inventory and appropriate leak tests on all sealed sources (ss) with an activity >7 MBq (1 pCi), or as specified by the WA DOH through regulation or license condition;

Prepare and maintain records of sealed source inventory and leak test results. These records will be:

Available for inspection by the WA DOH;

Retained for a minimum of three years after the leak test is performed, or as specified by regulation or license condition.

The RSO will collects inventory tracking data and performs physical inventories and wipe testing on sealed sources that are acquired under the authority of the University as generally-licensed items from commercial suppliers (i.e. – small calibration and teaching set sealed sources, etc.).
Sealed sources acquired as “generally-licensed devices” and held at the University must be included in the radioactive materials inventory reported to the RSO and WA DOH;
The University must assure that such sources are controlled appropriately and are disposed of through the RSO radioactive waste management program.
When a sealed source is in long term storage within shielded containment (i.e. – leaded cask or pig), the properly labeled and sealed storage container must be inventoried by the RSO but will not be opened to perform a physical inventory or leak test leak test on the contained sealed source(s) until there is an impending use or transfer planned for the sealed source.

The RSO sealed source leak test protocol will:

Take the wipe sample at the nearest accessible point to the sealed source where contamination might accumulate;

Be performed every six months, or as required by regulation or license condition.

If a sealed source wipe test reveals the presence of 185 Bq (0.005 microcurie) or more of removable radioactive material, the sealed source must be removed from service immediately.

The RSO will assure the source is decontaminated, repaired, or is properly contained and disposed of through the radioactive waste management program;

All equipment associated with a leaking source will be checked for contamination and, if contaminated, must be decontaminated or properly contained and sent for disposal.

Possession of generally-licensed sealed sources and devices containing sealed sources
- The RSO should be notified prior to the acquisition of a generally-licensed device or device that has a manufacturer-installed sealed source (i.e. – GLC or static eliminator).
The RSO will assess if the device is legally-transferable and appropriate to be held in inventory under the University’s Broadscope license;
The RSO will notify the worker if an Authorization is required for the acquisition and use of the device.
- An AU or University worker who acquires, or has in their possession a generally-licensed device such as a sealed source or equipment containing a sealed source, must notify the RSO so that:
The radioactive material can be tracked in the University inventory, as required by the Broadscope license;
Leak testing can be performed by the RSO, if required, and the device can be added to the RSO sealed source leak testing program.
Records can be maintained to document the sealed source is eventually disposed of through the RSO waste management program or transferred to an appropriate recipient.

Use, Storage, Transport and Security of Moisture/Density Gauges
All radiation workers handling these devices must complete:
RSO-provided on-line training for users of moisture gauges (see RSO Training);
All instrument safety and use training provided by the manufacturer for the specific device they will be operating;
Safety and performance-based training provided by the AU or their designee;
Appropriate security and DOT transport training (required on an annual basis), applicable to any device they will be transporting on a public highway;
All required and appropriate annual refresher training.
The RSO will provide regulatory-required hands-on training related to the security and transport of these devices;
The AU is required to provide and document the training provided to all radiation workers approved to handle a moisture gauge under an Authorization.
A training log is to be maintained by the AU listing the radiation workers who complete training, the instructor, the topics covered and the date the training was completed.
Transport papers, prepared by the RSO RAM transport/shipping coordinator, must be in the University vehicle (State-owned) and readily accessible.
The driver of the vehicle must be a current employee of the University and meet the requirements specified in SPPM 7.1.
These transport documents for each gauge that is transported, and a written emergency response protocol prepared by the AU, must be available for inspection by regulatory authorities.

3.6.6 Radiation Machine Program

Possession and use of a machine capable of producing ionizing radiation
In the state of Washington, the WA DOH oversees the locations of use; installation; and use of machines capable of creating a radiation exposure risk to workers or the general public. (doh.wa.gov/CommunityandEnvironment/Radiation/XRay.aspx).
The University must register and pay an annual fee to the State Department of Business licensing (WA DBL) for each machine that is in active use at a University facility or that is being used within the State under the authority of the University (http://bls.dor.wa.gov/xray.aspx);
All acquisitions, installations and uses of machines at a University location must be pre-authorized and overseen by the Radiation Safety Committee and RSO;
To be used at a University facility and/or under the authority of the University, a machine capable of producing ionizing radiation must be supervised by an Authorized User who has been approved by the RSC (see RPPM 10.A and D).

RSO oversight of Machine Acquisitions and Installations
The RSO must be notified of departmental or AU intent or plans to acquire equipment capable of generating ionizing radiation(i.e. -purchase or accept a transfer/donation);
The RSO will review the planned acquisition and will pre-approve the acquisition and:
Serve as liaison for any required regulatory pre-notifications or oversight ;
RSC review and approvals.
The RSO should be contacted well in advance of any anticipated machine acquisition or installation to avoid unnecessary approval delays associated with facility shielding assessments that may be required for the installation of a radiation-generating machine of the following types:
Computed Tomography (CT) (all new and replacement medical use units)
Industrial-use particle accelerators
Non-mobile use fluoroscopic (mobile unit used primarily in only one room)
Non-mobile use radiographic (mobile unit used primarily in only one room)
Permanent fluoroscopic installations
Permanent radiographic installations
Positron Emission Tomography/CT (PET/CT)
X-ray installations
X-ray therapy
A facility shielding assessment may be required prior to or after machine installation.
The shielding assessment and a report reflecting the results of the assessment, must be performed and completed by a qualified expert approved by the WA DOH;
The AU or supporting department are responsible for all costs associated with the shielding assessment and any required remodeling of the facility to meet State safety requirements.
Plans and specifications for the construction of new facilities, or for a major modification of an existing facility, to house a radiation machine shall be approved by the RSO. The information provided to the RSO must include:
The technical specifications of the equipment that will be acquired and installed;
The facility layout and as-built facility construction plans and all installed or planned shielding (location and composition);
Desired/planned beam orientation(s);
Occupancy of adjacent areas, including specific use(s) and number and type of individuals having access to and frequenting adjacent areas during planned machine operation hours;
Summary of proposed operations including operating voltages, beam on times, and expected radiation levels within and immediately outside controlled areas.
Security protocol to assure the machine cannot be operated by any individual not listed on the Authorization as an approved machine operator.
The RSO and/or RSC may require a site visit(s) prior to granting a machine Authorization based on the level of hazard or risk associated with the equipment, installation or proposed use.

RSO Authorization and Machine Facility Audits and Machine Inspections
The RSO performs Authorization audits and facility and machine radiation surveys for all active machines capable of producing ionizing radiation that are located at University facilities. The inspection includes:
Post-installation/pre-operation Facility and Machine Inspections;
Routine Authorization audits and inspections;
Post repair, machine modification or facility remodeling inspections.
The RSO audit and inspection protocol will meet all regulatory requirements and will be appropriate for the type of machine; facility; and machine use(s) (see RPPM Chapter 6 and D).

Inactive Radiation Machines
An Authorized User must notify the RSO when they are maintaining a machine under their Authorization that is inactive (no use) and will remain inactive for a prolonged period of time (> 1 yr);
The RSO will notify the State that the machine is Out-of-Service and will request the machine be removed from the University’s list of registered and active machines. Once the machine registration is suspended, the machine must be operationally “locked-out”.
The RSO will install a power cord lock box or other device to assure the machine is not operated until re-activated;
The RSO will continue to track the machine in inventory until it is removed (uninstalled and removed from the University’s equipment inventory.
If an inactive machine remains in a University facility after an Authorization is terminated, the department housing or storing the machine must assign a custodial machine RSO contact person.
The power cord lock box or other device that assures the machine cannot be operated must remain in place;
The RSO will continue to track the machine in inventory until it comes under another approved Authorized User or is removed from the University’s inventory.

Transfer or Disposal of a Radiation Machine
No radiation machine may be removed from campus or deactivated without prior approval of the RSO. The RSO will oversee and document all machine transfers and disposals.
Transfers within WSU, AU to another pre-approved AU, must be overseen by the RSO.
Notification to the RSO may be in the form of an email sent from the current Authorized User’s University email account to the RSO (wsu.edu);
The RSO will contact the AU to coordinate the transfer.
The recipient AU must have an active machine Authorization and be an approved operator of the machine that they are acquiring under their Authorization;
No machine is to be relocated prior to RSO notification and approval of the relocation.
Once a machine is relocated and prior to it’s active use, the RSO must perform a pre-use audit, machine inspection and facility surveys.
The RSO will notify the AU and provide a copy of the Approved Machine Cover Sheet that must be posted on or nearby the machine when it is in “active use” status.
Transfer of a radiation machine to surplus services for sale or disposal must be overseen and coordinated by the RSO
The University is required to document all transfers of machines and devices capable of producing ionizing radiation that could create a risk to the general public;
If a machine is in working order, it may be transferred to an individual or entity that is qualified and authorized to accept the equipment safely and responsibly. The RSO will verify that the recipient (i.e.- purchaser) is qualified to take possession and control of the device;
If the machine is capable of generating ionizing radiation but is being transferred to a recipient who is not qualified to receive an operational machine (i.e. – metal recycler), the RSO permanently disables the equipment and verifies that the equipment does not contain other hazardous materials (i.e. – PCBs) prior to the release of the equipment.
The RSO must be notified of any planned transfer of a radiation machine to a manufacturer or qualified service provider for a planned refurbishment; replacement; trade-in; or disposal. The RSO will verify the recipients licensing status in the State of Washington to assure the transfer is appropriate and compliant with regulations.

3.4.7 Radioactive Materials Transport and Shipping

Regulatory oversight of Radioactive Materials Shipping
Many regulatory entities have some part in the regulatory oversight of radioactive materials shipping and transport in the U.S. and internationally:
Department of Transportation (DOT) http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/RAM_Regulations_Review_12-2008.pdf
Nuclear Regulatory Commission (NRC) nrc.gov/reading-rm/doc collections/cfr/part071/full-text.html);
Federal Aviation Administration (FAA) also has regulations for shipment of hazardous materials, radioactive materials, or biohazards as air cargo.
International Atomic Energy Agency (IAEA);
International Air Transportation Association (IATA).
Due to the complexity of RAM shipping regulations and the consequences for non-compliance, the University maintains a highly trained and experienced staff of hazardous materials shipping coordinators through the Office of Research Assurances (ORA). (ora.wsu.edu/shipping/training.asp).
The RSO specifically oversees the shipment and transport of radioactive materials.
RSO Shipping coordinator responsibilities include:
Providing guidance to all University personnel preparing to ship radioactive materials or equipment containing radioactive material;
Ensuring all packages offered for shipment to a commercial shipping contractors are in compliance with the rules and regulation governing shipping and material transportation;
Performing; evaluating and documenting all package contents and package surveys;
Serving as the liaison with a commercial carrier concerning shipments of radioactive material that originate from the University and contain licensed materials;
Ensuring that there is an arrangement in place for 24-Hour emergency response coverage to provide any necessary information to requesting authorities for radioactive material being shipped under the authority of the University;
Preparing and retaining all necessary shipping papers and records for the duration of the required retention period.

Transport of Radioactive Materials by University Radiation Workers
When a radiation worker must transport licensed material outside of the Authorization’s approved use facilities (building and rooms), they must:
Notify the RSO (wsu.edu) one workday prior to the transport and provide the:
Authorization under which the material is held in inventory;
Name of the radiation worker who will perform the transport;
Material to be transported (radionuclide; physical form; quantity, associated non-radiologic hazards);
Purpose of the transport;
Intended route of the transport (“from and to” locations (buildings and rooms).
Review the appropriate standard operational guidance for such transport (see RPPM 10.A).
If a formal transfer of radioactive materials between approved Authorizations is associated with an on-campus transport procedure, the following requirements must also be met:
An RSO Transfer Request form (see RPPM 10.E) must be completed and submitted for pre-approval by the RSO;
The worker must perform the transport using tertiary containment of properly labeled materials;
The transport must be completed on foot or by use of a State vehicle during a time when the buildings and campus are not busy or congested.
To perform a transport of RAM between in-state University locations (campuses or research stations) an Authorization radiation worker must:
Submit an RSO Transfer Request form (see RPPM 10.E) for pre-approval;
Coordinate with an RSO shipping and transport coordinator to receive appropriate RSO-prepared shipping papers that must be carried in a State vehicle driven by a qualified driver (licensed University staff member);
Package and appropriately label the radioactive materials in shielded tertiary containment and place the package securely in the transport vehicle away from all occupants.
If an Authorization radiation worker plans to transport licensed material outside the State of Washington they must:
Pre-notify the RSO well in advance to assure adequate oversight and compliance to all regulatory requirements, including the notification and approval of all involved state and Federal agencies (i.e. – current Reciprocity Agreement in place prior to transport);
Comply with applicable US DOT and WAC regulations pertaining to the following modes of transportation:
Rail – 49 CFR Part 174: Subparts A through D and K;
Air – 49 CFR Part 175;
Vessel – 49 CFR Part 176: Subparts A through F and M;
Public Highway – 49 CFR Part 177 and Parts 390 through 397;
WAC 246-231 (http://apps.leg.wa.gov/wac/default.aspx?cite=246).

Reciprocity Agreements for use of licensed RAM outside of Washington
An Authorization planning out-of-state transport and use of a licensed source of radiation must be pre-approved for the use by the RSC through their current Authorization or must submit an amendment Authorization application for review and approval by the RSC;
The use of RAM (dispersible form or sealed source) outside of Washington requires a Reciprocity Agreement with the licensing agency with jurisdiction at the proposed use location;
Reciprocity Agreements (temporary out-of-state use license) are typically granted by the licensing entity to allow temporary use of the licensed material within their jurisdiction for 180 days;
The AU must contact the RSO in advance (months) so that a Reciprocity Agreement for the specified use at a specific location can be obtained from the jurisdictional licensing;
All costs for reciprocal licensing are the responsibility of the AU or department conducting the work.

3.4.8 Radioactive Waste Management

Radioactive waste management is a very complex and highly regulated program.
Radioactive waste management is the most costly and difficult to maintain radiation user support service that the Radiation Safety Office coordinates;
The categorization, management, handling, processing, transport and disposal of radioactive waste is a difficult task and confusing topic;
There are more oversight agencies, both Federal and State; more licenses and permits that must be maintained; and more regulations and rules to interpret and “keep up with” than any other program area of the RPP;
The annual cost to the University for radioactive waste management and disposal is substantial and constantly increasing;
Each Authorized User and all radiation workers must be aware of, and follow, the waste management standard operating guidance that is pertinent to their uses of radiation and that has been provided in RPPM 10A, 10B, 10C;
Appropriate radioactive waste minimization protocols should be in place for all uses of radioactive materials. This includes, assuring that non-radioactive wastes or items that can be easily decontaminated or held for decay (10 x T1/2 of < 90 days) are not included in the University’s radioactive waste disposal burden.

The RAM waste generation potential, as described in an Authorization application, is reviewed and considered prior to RSC approval of the specified radiation use.
The RSC will consider all aspects of radioactive waste generation and management when reviewing and considering the approval of a radioactive materials use Authorization, whether a new, amendment or renewal application.
The following items will be considered during the RSO and RSC review on an application:
- Is a radioactive waste minimization plan being implemented ?
- Will wastes be managed in a manner consistent with established procedures?
- Are there any potential occupational and public hazardous materials exposure risks (e.g., toxicity, carcinogenicity, pathogenicity, flammability)?
- What are the immediate and long term consequences of the wastes that will be generated?
Methods of Radioactive Waste Disposal Available to the University
The primary methods of disposal used by the RSO depend on the type of waste and radionuclide(s) present, and include:
Release to the Sanitary Sewer, in compliance with State and Federal limits;
Release to Air – as regulated by the Federal Clean Air Act and the Pullman campus Air-Operating Permit (AOP) and Radioactive Air Emissions License (RAEL);
Decay-in-Storage (DIS) is the disposal method used for most short-lived, non- mixed dry wastes. In this process,:
Sealed and labelled radioactive waste containers are stored securely for 10 x the longest T ½;
It is verified by direct radiological survey and documented that each waste container meets regulatory release limits;
The container labeling indicating it is a radioactive waste is obliterated and the container is incinerated or released to landfill disposal.
Incineration (Pullman campus only) is limited by licenses and permits to only H-3,

C-14, S-35 and DIS dry wastes;

Sealed Source Transfer to an alternate recipient (i.e.– licensed manufacturer for recycling and/or disposal of equipment-installed sealed sources);
Transfer to a contracted, licensed waste broker for off-site disposal after compaction, bulking and packaging of low-level radioactive wastes (LLRW).

3.4.9 Spill and Incident Response

All AUs and radiation workers have responsibilities when faced with an emergency situation. For radiation workers these include, but are not limited to:
Notifying the Pullman Fire and Police department; their department; and University Public Safety and RSO personnel when an emergency (personal injury, fire, etc.) occurs in their work area;
Assisting First Responders and RSO staff who must deal with an emergency that may involve the dispersal of radioactive materials that are held under their Authorization.

General guidance for radiation workers concerning spill management
All spills are important and can have significant consequences to the individuals involved and the University’s commitment to ALARA. Any “spill” must be contained and resolved in an efficient manner;
A minor spill may become a radiological Incident if:
The spill goes unrecognized or is “ignored” until later;
It is inadequately cleaned up or is cleaned up but not documented properly through the completion of survey records;
It results in the contamination of the radiation worker, or other staff and students;
It is tracked from a restricted access lab into public areas (corridors, rest rooms, elevators).
All radiation workers who handle or work in areas where dispersible forms of RAM are stored and used must know how to perform a self-survey and how to decontaminate them self and/or co-workers.
Please see RPPM 10.B and 10F and the contamination control training at RSO Training. http://emergency.cdc.gov/radiation/screeningvideos/index.asp.

The RSO must be notified and is required to assist and document the following radiological incidents:
An incident that involves the contamination or non-ALARA exposure of an individual;
Contamination that extends into a public area or that is released into the environment (atmospheric, ground or storm sewer releases);
The breach of a commercially distributed sealed source that results in personal or facility contamination.

RSO responsibilities and response capabilities
The RSO staff are not trained or certified as emergency first responders but do:
Serve as consultants to Pullman Fire and Police personnel who may be required to respond to an emergency on the Pullman campus that has a potential for involve a radiological risk;
Work to identify and contain a radiological hazard in a University facility or at a location owned or operated under the authority of the University;
Assist in the protection all individuals from the hazards associated with sources of radiation held under the authority of the University.
The main emphasis of the RSO is the prevention of radiological spills, incidents or emergencies.
Upon initial and follow-up review of Authorization applications, the RSO and RSC identify safety concerns and resolve the concern before granting approval of the Authorization.
During routine visits to radiation use areas (i.e. – deliveries, audits, waste pick-ups, etc.), the RSO staff:
Note and identify any facility hazards, hazardous material or personnel performance concerns that indicate a breach or lapse in University or radiation safety policies and procedures;
Provide timely notice to Authorized Users (verbal and/or written) of safety and non-compliance concerns that were not corrected during an audit or visit to the AU’s facilities, and providing the AU with recommended corrective actions to resolve the situation;
Conduct timely follow-up visits to use facilities to verify resolution of the radiological safety hazards;
Identify non-radiological safety hazards, communicate the location to personnel in the appropriate alternate University safety oversight unit (EH&S; Biosafety; Public Safety; etc.).
Prepare formal Incident Reports for URSO and RSC review and action.
The Incident Report is a record describing the initial finding; personnel and facilities involved; response activities; and current status of a non-ALARA personnel exposures or unresolved or repetitive safety or non-compliance situation.
The report is provided to the URSO and/or RSC in a timely manner so that, if required, a corrective action can be implemented to resolve any radiological hazard or concern.
During routine audits and surveys of radiation use areas RSO staff:
Assure that appropriate hazard posting and Spill and Emergency Response Instructions and Call lists are conspicuously posted;
Audit the availability and content of the Authorization’s Spill and Emergency Response protocol and assess radiation worker’s familiarity with spill and emergency response protocols;
Assure that each facility where dispersible forms of radioactive materials are used has appropriate resources available to control and resolve an unintended release of radioactive materials (i.e. – radiation protection instruments and equipment; PPE; spill kit; etc.).