Section 4: Policies and General Procedures For Radioactive Material Use

A. General Safety Rules for Working with Radioactive Material

  1. Prior to using Radioactive Material
    1. Be familiar with the procedure being performed; perform a "dry" run to identify any potential problems; seek supervision for initial run from an investigator experienced with that particular procedure.
    2. Ensure all needed equipment is available and functioning properly.
    3. Prepare the work area with absorbent paper (absorbent side up); use absorbent lined trays when possible.
    4. Prepare for spills. Familiarize yourself with decontamination procedures. You are responsible for decontaminating your own spills.
    5. Have decontamination supplies available.
    6. Post radiation work areas, laboratories, and containers of radioactive materials with appropriate warning signs.
    7. Volatile radioactive materials or operations where significant gases or vapor could be released must be conducted in a fume hood.
  2. When Working with Radioactive Material
    1. Wear a lab coat or other protective clothing. Potentially contaminated laboratory coats should not be worn outside the laboratory.
    2. If assigned wear appropriate personnel monitoring devices.
    3. Wear gloves whenever handling unsealed radioactive material.
    4. Use remote handling tools and utilize appropriate shielding as indicated, plexiglass for 32P, lead for 125I, etc.
    5. Work in a fume hood if volatile materials are used.
    6. Secure all radioactive material when not in use.
    7. Do not eat, drink, smoke, or apply cosmetics in areas where radioactive material is used or stored.
    8. Do not pipette by mouth.
    9. Do not store food or beverages in a refrigerator designated as a radioactive materials storage facility.
    10. Use disposable absorbent pads or lipped trays to protect work surfaces and to confine spills.
    11. Hands should be checked often for contamination while working with radioactive material. If contamination is discovered, remove gloves and check hands.
    12. Limit as much as possible the amount of time spent handling radioactive material.
    13. Work with radioactive material should be confined to the work area.
    14. Radioactive materials should not be left in uncovered containers.
    15. All radioactive material containers should have the contents clearly labeled.
    16. Liquid radioactive material must be in a secondary container.
  3. Additional Rules for Nuclear Medicine
    1. Syringe shields are required for preparation of patient doses and administration to patients.
    2. Finger badges must be worn during elution of the generator, and the preparation, assay, and injection of radiopharmaceuticals.
    3. Survey generator, kit preparation, and injection areas for contamination after each procedure or at the end of the day. Decontaminate if necessary.
    4. Assay each patient dose in the dose calibrator prior to administration. Do not use any doses that differ from the prescribed dose by more than 10 %.
  4. After Completion of Work with Radioactive Material
    1. Radioactive wastes must be placed in appropriately marked radioactive waste receptacles, contained in appropriate containers (bags or bottles), and VEHS notified of the need for collection (see Appendix C Radioactive Waste Disposal).
    2. Low level radioactive liquids may be disposed in designated "hot" sinks. Normally, low level radioactive liquids are rinse water and high volume low activity waste. Sink disposal is limited to 0.2 mCi per day per radionuclide.
    3. Monitor hands, shoes, clothing and work area with a survey meter.
    4. Janitorial and other maintenance workers shall be notified whenever special precautions are required for performing their duties in the lab such as when contaminated areas or unusually high radiation exposure levels exists.

The PI has the responsibility to protect both the workers and the general public from any radioactive sources being used. The PI should be familiar with the basic principles of radiation protection and the properties of the radioactive materials being used. The PI should see that the work of the group is properly planned and that adequate instructions are provided for any operations involving radioactive material. For lengthy, repetitive procedures, the instructions should be in written form. A dry test run should precede an initial unfamiliar procedure. The PI shall see that instructions are followed and that safety rules are enforced.

B. Maximum Radiation and Contamination Levels

  1. Maximum Permissible Radiation Levels
    1. Radiation levels in unrestricted areas (i.e. areas with free access, no control over who comes and goes, such as in corridors) must be kept below both:
      1. 2 mrem (0.02 mSv) in any one hour.
      2. 100 mrem (1 mSv) per year.
    2. Radiation levels in restricted areas must be less than 5,000 mrem (50 mSv) per year
  2. Maximum Permissible Contamination Levels

    Radioactive contamination must not be allowed to remain above the limits given the Table 3. Items may be released for unrestricted use if they are below the contamination limits given in Table 3.

    Table 3: Contamination Limits
    Type of Contamination Low Toxicity Radionuclide
    (dpm/100 cm2)
    Moderate and High Toxicity Radionuclide (dpm/100 cm2) Very High Toxicity Radionuclide
    (dpm/100 cm2)
    Unrestricted areas and personal clothing  2,000  200 20
    Restricted areas  10,000 1,000 200
    Fixed contamination  10,000 1,000 200

    Note: Toxicity classes for various radionuclides may be found in Appendix B "Table of Radionuclides". Toxicity classes are defined in Table 4.

    "Removable contamination" means radioactivity that can be transferred from a surface to wipe test paper by rubbing with moderate pressure.

    Fixed contamination levels may be measured with a survey meter calibrated to read in mR/hr. The average and maximum radiation levels associated with surface contamination by beta-gamma emitters should not exceed 0.2 mR/hr with the detector 1 cm from the surface and 1.0 mR/hr with the detector 1 cm from the surface, respectively, as measured through not more than 7 mg/cm2 of total absorber.

    Table 4: Radionuclide Toxicity Class
    Toxicity class is based on the Annual Limit on Intake (ALI)
    Toxicity Class Low Moderate High Very High
    ALI (mCi) >5 0.500-4.999  0.005-0.499 <0.005

C. Posting and Labeling requirements

  1. Labs or areas where radioactive materials are used

    A "Caution, Radioactive Materials" sign must be posted in any area where radioactive material is used or stored on a regular basis. If a PI no longer intends to use radioactive material in a given room/area, contact VEHS to close out the lab. VEHS will remove all "Caution, Radioactive Materials" signs after the area has been surveyed and decontaminated as appropriate.

  2. Containers and equipment for radioactive material

    All containers of radioactive material must be labeled with a "Caution, Radioactive Material" label. The label must also provide the radionuclide(s) present, an estimate of the activity, the date for which the activity is estimated, and kinds of material. This permits individuals handling or using the containers to take the necessary safety precautions. Any hazardous chemicals should also be identified on the label.

    Any refrigerator, fume hood, incubator, or other equipment where radioactive materials are stored must be labeled. A refrigerator where radioactive materials are stored must be labeled with a "Caution, Radioactive Materials" or a "Caution Radioactive Materials No Food or Beverage May Be Stored in This Unit" sign. An incubator, fume hood, or other equipment must be posted with a "Caution, Radioactive Materials" sign. If the refrigerator, incubator, or other equipment will no longer be used with radioactive material, call VEHS to schedule an equipment check to survey the equipment for contamination and removal of the labels. If repairs need to be made to a radioactive materials refrigerator, fume hood, incubator, or other equipment, contact VEHS to schedule an equipment check to survey the equipment for contamination prior to repairs.

    Any equipment such as a pipette, centrifuge, scale, etc. used with radioactive material should be posted with a "Caution, Radioactive Materials" label.

  3. Sinks for disposal of liquid radioactive waste

    If a PI wishes to dispose of radioactive material via the sanitary sewer, then the radioactive material must be readily soluble or readily biologically dispersible material in water. The sink designated for sanitary sewer disposal must be posted with a "Radioactive Hot Sink" sign. If repairs need to be made to the sink contact, VEHS to schedule a sink check to survey for contamination prior to repairs.

  4. Radioactive waste containers

    All radioactive waste containers must be posted with a "Caution, Radioactive Materials" or a "Radioactive Waste" sign. All full waste bags must be tagged with a radioactive waste tag. The waste tag must have the radionuclide, the estimated activity, the date of the estimated activity, the name of the PI, and a signature. If a waste container with radioactive waste has been emptied by Environmental Services, contact VEHS immediately (2-2057).

  5. Signs and labels required for radioactive material use

    It is the responsibility of the user to post the appropriate caution signs in all areas. The signs and labels will be initially supplied by VEHS; however, investigators should purchase their own if they have a continuing need. Catalogs and prices are available in the VEHS office. Please consult with the VEHS staff for any needed advice and assistance in posting and labeling. The Notice to Employees (see next page) must be posted in all areas where ionizing radiation is used.

D. Sealed Sources of Radioactive Material

  1. Leak tests to check the integrity of sealed source encapsulation must be conducted at intervals not exceeding six months. If there is a reason to suspect that a source may be damaged, it must be tested before further use. This test is not required if the source is being stored and is not being used; however, such sources will require testing for leakage prior to any use or transfer. VEHS will perform all required leak tests. If the leak test reveals the presence of 0.000005 mCi (185 Bq) or more of removable contamination the source must be removed from use.
  2. Sealed sources require leak testing if they meet the following criteria:
    1. Half-life greater than 30 days
    2. Nongaseous form
    3. Activity greater than 0.100 mCi (3.7 MBq) for a beta or gamma emitter, or 0.010 mCi (370 kBq) for an alpha emitter
    4. Not required for tritium
  3. Sources obtained as sealed sources shall not be opened. The safety and handling precautions furnished by the manufacturer shall be maintained in a location that is readily available to all workers and followed.

E. Radiation Surveys

  1. Types of Surveys

    Surveys are performed to locate areas of increased exposure or removable contamination. Exposure surveys may identify areas with increased exposure or contamination. A wipe survey is routinely performed to determine if removable contamination is present. If the area is contaminated, see decontamination procedures in this manual or call VEHS (322-2057).

    A survey is required after each use of radioactive material. If the laboratory is classified as a medium hazard laboratory a survey is required to be documented weekly.

    Surveys after each use of radioactive material shall include a survey of hands, clothing, equipment, and the work areas. A GM or NaI survey meter evaluation is required unless only tritium is used, then a wipe survey should be performed. If increased readings are detected with the survey meter, a wipe survey of the area should be performed.

    Documented weekly surveys shall include all work areas, preparation areas, equipment storage areas, cabinet fronts, drawer fronts, desks, and those areas classified as "clean". A GM or NaI scintillation meter for radioiodine evaluation and wipe surveys are required.

  2. How to survey

    Geiger Mueller (GM) survey instruments can be used to detect beta and gamma radiation. When using a GM survey meter remove any protective caps. The thin window should not be covered, as it will decrease detection sensitivity. Check the calibration sticker to ensure the meter has been calibrated within the last year. Do not use the meter if more than a year has past since the last calibration. Check the batteries and do a performance check on the meter to ensure it is functioning properly. A performance check may include the use of a dedicated check source or a vial or tube containing a known amount of radioactive material. Verify background is within an acceptable range, typically 0.01-0.05 mR/hr. If there are any questionable results, e.g. no response, or the meter will not zero, call VEHS for guidance.

    To survey, slowly move the probe over the surface with the thin window facing the surface. The probe should be 1 centimeter above the surface. A NaI survey meter is operated the same way as the GM. The only difference is the NaI is used for gamma radiation (e.g. 125I).

    Laboratory personnel handling radioactive material should check hands frequently for contamination with a GM meter or NaI scintillation meter. If contamination is detected, remove gloves and resurvey hands. If contamination is detected on the skin, call VEHS immediately. Before lab personnel leave an area where radioactive material is used, use a GM or NaI for radioiodine to check hands, clothing, and feet for contamination. Also, lab personnel should check hands, clothes, and feet at the end of each day that radioactive material is used.

    Any area that has an elevated radiation exposure reading with a GM or NaI survey meter should have a wipe test performed. If the contamination is removable, then decontaminate the area. If the area cannot be decontaminated or assistance is required, call VEHS. If the exposure readings are high near a radioactive material storage area, try rearranging the containers of radioactive material to lower the exposure rates.

F. Meter Calibration Policy

Radiation survey meters are required to be calibrated annually or after repairs. A meter should be checked when there is cause for concern in the meter's performance or when a contaminated probe is suspected. VEHS cannot repair meters but can sometimes diagnose common problems and suggest corrective actions.

VEHS is required to be notified when a new survey meter is acquired so that it can be included in the calibration schedule.

The PI is responsible for making arrangements to have their survey meters calibrated. VEHS offers a meter calibration service for a fee. In order to have a survey meter calibrated contact VEHS at 2-2057 to schedule a time to have the survey meter calibrated. VEHS will pick the survey meter up from the lab for calibration and leave a loaner survey meter with the lab until the lab's survey meter has been calibrated and returned. Survey meters that cannot be calibrated to +/- 20% may need to be returned to the manufacturer for repair.

G. Portable Radiation Meter Policy

The Radiation Safety Committee has established the following portable survey meter requirements for operations involving radiation sources. The RSC may waive some requirements of this policy if it can be demonstrated that safety would not be significantly compromised. The RSC may require that a meter be obtained when this policy does not specifically require one. The Committee may also require specific types of meters or detectors, such as scintillation detectors for 125I or ion chambers for mixed gamma/x-ray radiation fields.

  1. PI's with authorized possession limits that correspond to a total of 150 or more ALI's for any combination of radionuclides are required to have appropriate radiation survey meter(s) located in each laboratory room classified as a "medium hazard". The meter must be physically present at all times in these rooms.
  2. PI's with authorized possession limits that correspond to a total of 5 or more ALI's for any combination of radionuclides must have immediate access to appropriate radiation survey meters. This access can be accomplished by:
    1. Purchasing one's own meter.
    2. Labs can share a meter if it is immediately accessible to all labs involved. A meter is considered immediately accessible if it can be retrieved within 5 minutes any time radioactive materials are being used. Meters located in another building, on a different floor of the same building, or several corridors away are not considered immediately accessible. A meter cannot be shared if it belongs to a laboratory classified as a "medium hazard" laboratory.

      If a meter is shared, a signed statement from the PI who owns the meter must be submitted with the application to use radioactive materials.

  3. PI's with authorized possession limits corresponding to less than 5 ALI's must also perform surveys for radioactive contamination and therefore should have reasonable access to survey meters.
  4. Anyone who uses radiation-producing machines may be required by the RSC to have an appropriate survey meter.

H. Guidelines for Selecting Portable Radiation Survey Meters

All meters will not detect all radionuclides. The following guidelines are designed to assist in selecting meters that are appropriate for detecting various types of radiation:

  1. For detecting beta emitters with a maximum beta energy greater than or equal to 150 keV such as 14C, 35S, or 32P either of the following are recommended:
    1. A Geiger-Mueller (GM) detector with a maximum window thickness of 1.7 mg/cm2. Pancake style GM's are recommended over thin end window GM's because pancake style GM's are generally more efficient for low energy beta emitters (14C or 35S) and the pancake's larger window surface area makes it easier to monitor large areas for contamination.
    2. A beta scintillator with a plastic scintillation detector. The cost of a GM is significantly lower than a beta scintillator, but the scintillator is generally more efficient.
      Note: A side window GM will not be approved for use as a detector for beta emitting radionuclides, since this type of probe will not detect 14C or 35S and is significantly less efficient than either thin window or pancake GM's.
  2. For surveying radiation sources that generate x- or gamma rays with energy greater than 30 keV, a GM pancake, GM thin end window, or a GM side window is usually adequate. As mentioned above, the pancake style is preferable since it has a larger window surface area that assists in monitoring large areas for contamination. However, solid detectors (i.e. NaI) are usually much more efficient and may be more appropriate if very low levels of radiation need to be detected.
  3. For PI's approved for 125I or other radiation sources that generate x- or gamma rays with energies less than 30 keV, a low energy 1" x 1 mm NaI(Tl) gamma scintillation detector is recommended.
  4. For PI's approved for both beta and low energy gamma emitters (i.e. less than 30 keV), one of the following should be purchased: (1) two meters (one with a GM probe and one with a NaI probe), (2) two probes for one meter (a GM probe and a NaI probe), or (3) a beta-gamma sandwich scintillation detector. The beta-gamma scintillation detector is a combination of two scintillation probes previously described.
  5. Ion chambers are used to detect x- and gamma radiation fields. They have an energy independent response and are therefore recommended for any dose rate measurements that are made to demonstrate compliance with Vanderbilt's license and/or State regulations. Ion chambers are not practical for the detection of contamination.

    Probes that are separate from the body of the meter are preferable. Built-in probes are often difficult to repair or replace without sending them back to the manufacturer. Separate probes can usually be readily replaced or repaired.

    Be wary of purchasing a meter if a vendor cannot or will not provide the above information. If necessary, VEHS can provide vendor information.

I. Wipe Survey - testing surfaces by wiping

Wipes should be taken for all areas that have an increased exposure reading with the GM and/or the NaI scintillation meter. Wipes are taken to determine if the contamination is removable. Wipes should also be taken on the work bench, floor, refrigerator handles, light switch, trash can lids, fume hood sill, fume hood sash, bottom of fume hood, etc. Wipe surveys should not always include exactly the same locations. Filter paper, Q-tips, or alcohol prep pads can be used for wipes, or wipes can be purchased from a vendor. A wipe should cover an area of at least 100 cm2 and should not exceed 300 cm2.

The wipes should be counted on a liquid scintillation counter (LSC) and/or a gamma counter depending on the radionuclide(s) used. If only beta emitting (i.e. 3H, 14C, or 32P) radionuclides are used, the wipes should be counted on a LSC. If only gamma emitting radionuclide(s) (i.e. 51Cr) are used the wipes can be counted on a gamma counter.

J. Radiation Survey Policy

Radiation workers are responsible for conducting surveys of their work areas to (a) ensure that radiation sources are adequately shielded and (b) to check for radioactive contamination. If gamma or high energy beta sources are used, radiation meter surveys should be made to check radiation levels in all work areas, storage areas, around waste containers, and in nearby uncontrolled areas. Contamination checks are made by using an appropriate survey meter to scan suspect surfaces or by wipe testing surfaces, i.e. rubbing a piece of paper or cotton-tipped applicator over the surface and then counting it for radioactivity with a suitable counter.

Radiation workers are personally responsible for checking themselves for contamination before leaving radioactive material areas.

A simple survey log is recommended to help the radiation worker maintain an awareness of changes in radiation levels that may indicate a need for a change in procedure.

Documented weekly surveys are required if a laboratory is classified as a "Medium Hazard"lab. If these surveys are not performed it will be necessary to downgrade the lab classification to "Low Hazard" by decreasing the PI's radioactive material possession limit.

Periodic inspections and surveys are performed by VEHS at a frequency commensurate with the hazard rating of the laboratory.

K. Facilities and Equipment

  1. Work Surfaces

    Work surfaces should be constructed of non-porous materials and covered with absorbent paper that has a plastic backing. The absorbent paper should be replaced at frequent intervals

  2. Fume Hoods

    Procedures involving aerosols, dusts, or gaseous products that might produce airborne contamination shall be conducted in a hood or glove box. Requirements to use a fume hood when working with radioactive materials are given in Table 5. The average airflow at the face of the hood must be at least 0.5 m/sec (100 linear feet per minute). Hood exhaust fans must be "on" whenever the hood is in use.

    Table 5: Fume Hood Requirements for Radioactive Material
      Number of ALI's* Used Hood Requirement
    Volatile Radioisotopes < 1 No Hood Required
    1 - 10 Standard Chemical Fume Hood
    > 10 Activated Charcoal Filter** Required
    Volatile Radioiodines < 1 Standard Chemical Fume Hood
    > 1 Activated Charcoal Filter** Required
    Non-Volatile Radioisotopes < 10  No Hood Required
    10 - 100 Standard Chemical Fume Hood
    > 100 HEPA Filter*** Required

    *ALI or Annual Limit of Intake. A list of ALI's can be found in Appendix B "Table of Radionuclides"

    **Activated charcoal filter for gaseous contamination

    ***High Efficiency Particulate Air (HEPA) filter for particulate airborne contamination

    Releases to the atmosphere shall not exceed the maximum permissible concentrations in air specified in State regulations. Traps or filters may be required to ensure that environmental releases are within acceptable limits. Should either activated charcoal filter or a HEPA filter need to be used, the filters must be incorporated into the fume hood system. As an alternative to installing a filter in an existing hood, a tabletop hood equipped with one of these filters can be placed inside of an existing fume hood.

  3. Radioactive Material Storage Areas

    Radioactive materials must be stored and shielded to maintain radiation exposure to laboratory personnel As Low As Reasonably Achievable (ALARA). If possible, radioactive materials should be stored separately from non-radioactive material. The storage area must be clearly marked with appropriate warning signs and the radioactive material must be secured from unauthorized access or removal. Radioactive material should be returned to the storage location immediately after use. Sufficient shielding to reduce radiation levels to 2 mrem/hr (0.02 mSv) at 30 cm from the storage area. All storage areas must be secured against unauthorized access and removal of radioactive material.

  4. Location of Radioactive Material Work Areas

    Radioactive materials work should be confined to only the area necessary. It is desirable to have one area designated as a "hot" work area for high activities and other areas designated as "low level" work areas. The PI should consider the effects of a possible spill, accident, and security when choosing the designated work areas. Work areas must utilize sufficient shielding to minimize radiation exposure to personnel.

  5. Classification of Radioactive Material Laboratories

    Radioactive material labs are classified on the basis of the radionuclides and the corresponding possession limits that are approved for the PI. The toxicity of radioactive material varies considerably so it is necessary to "normalize" the approved activities for the various radionuclides. This is done by determining the number of ALIs (Annual Limit on Intake) represented by each radionuclide possession limit. Labs are then classified according to the following:

    Lab Hazard Rating Approved No. of ALIs
    Slight 1
    Low 1-150
    Medium 150-100,000
    High >100,000

    The approved number of ALIs is the sum of all radionuclides for which the PI is approved. If a PI has more than one laboratory room, at least one of the rooms will be rated at the calculated level. Other rooms may be rated at a lower level.

    Example: A PI is approved for:

    3H 20 mCi (740 MBq) ALI = 80.0 mCi (2,960 MBq) # ALIs = 0.25
    125I 10 mCi (370 MBq) ALI = 0.04 mCi (1.48 MBq) # ALIs = 250.00
    32P 15 mCi (555 MBq) ALI = 0.40 mCi (14.8 MBq) # ALIs = 37.5

    Total number of ALIs = 287.75, so the major lab classification = Medium

L. Survey Instrument Requirements

Laboratories classified as Medium or High hazard labs must have a portable survey meter that is appropriate for the type of radiation being used. Laboratories with a Low rating must have ready access to a survey instrument. Labs only using 3H or 63Ni are exempt from this requirement.

Survey instruments are required to be calibrated annually or after repairs are made to the instrument. The PI is responsible for making arrangements for having survey equipment calibrated. VEHS provides a calibration service for a fee.

M. Radiation Safety Training Requirements

Prior to handling radioactive material at Vanderbilt, each person must satisfy the following training requirements:

  1. Specific Training Requirement

    All radiation workers shall be instructed in safe handling methods for radioactive material and radiation safety principles. The PI shall instruct employees in procedures applicable to the specific operation employed in the laboratory including on-the-job training.

  2. Course Requirement: Radiation Safety Principles

    Principal Investigators are responsible for assuring that their radiation workers have received adequate instruction in radiation safety principles. The three alternatives to satisfy this requirement are given below:

    1. Attend the Radiation Safety Principles course given by VEHS
    2. Furnish evidence of previous attendance at a radiation safety course
    3. Pass an exam administered by VEHS
  3. Orientation Lecture: Vanderbilt Radiation Safety Policies and Procedures

    All new radiation workers, including Principal Investigators, are required to attend this lecture, regardless of prior experience or training.

    Go to the VEHS website at www.safety.vanderbilt.edu for a complete schedule of the Radiation Safety Principles classes and the Orientation lectures.

N. Animals Containing Radioactive Materials

  1. Warning Signs

    All cages housing animals containing radioactive materials shall be labeled with a "Caution, Radioactive Materials" label.

    A "Caution, Radioactive Materials" sign must be posted on the cage. The sign must remain on the cage until the animal has been removed and the cage has been decontaminated.

  2. Collections and Disposal of Radioactive Excreta

    Any excreta or litter that is radioactive must be disposed in the same manner as biological radioactive waste.

  3. Ventilation

    Adequate ventilation must be provided for animals administered radioactive materials that may be volatized.

O. Use of Division of Animal Care Facilities

Principal Investigators desiring to use these facilities must submit a written request to the Division of Animal Care. Use of these facilities does not relieve the investigator of the responsibilities for the use of the radioactive materials. Radioactive animals should be isolated from other animals. The investigator is responsible for changing and collecting radioactive litter and for providing all necessary monitoring. The cage must be decontaminated before being returned to Animal Care.

Radioactive animals should not be petted or groomed.

If radioactive materials are expired from the animal or are excreted in a volatile form, adequate ventilation must be provided.

Appropriate disposable gloves and a lab coat must be worn when changing litter or cleaning the cages. Any excreta or litter that is radioactive must be treated as biological waste.

All cages must be monitored for radioactive contamination after the animals are removed and decontaminated to below the criteria stated in section 4 of this manual.

All locations where radioactive animals were injected, housed, or sacrificed must be monitored for contamination. Be sure to monitor yourself after any work with radioactive animals.

Precautions should be taken to minimize dust production.

Experimental animals administered radioactive materials should not be used for human or animal consumption.

P. General Radiation Safety Enforcement Policy

For serious or flagrant radiation safety violations, the Principal Investigator's (PI) authorization to use radioactive material will be immediately suspended. Following a suspension, the PI must appear before the RSC and present an acceptable plan for corrective actions before authorization can be reinstated. For less serious violations, or a pattern that indicates an overall laxity in their radiation safety program, the PI will be given one written warning before a suspension is imposed.

Serious incidents or flagrant radiation safety violations can include, but are not limited to:

  1. Activities that result in radioactive contamination in public areas
  2. Radiation exposure to a member of the general public in excess of the legal limits
  3. Overexposure of an individual to radiation
  4. Releases of radioactive material to the environment in excess of legal limits
  5. Leaving radioactive material unsecured in a public access area
  6. Allowing an individual to work with radiation sources without meeting radiation safety training requirements

Violations for which a single written notice will be dispensed can include, but are not limited to:

  1. Food and/or beverage in inappropriate locations
  2. Failure to perform required surveys
  3. Failing to provide and require the use of radiation monitoring badges when required
  4. Failure to promptly decontaminate when radioactive contamination is detected

Q. Radioactive Material Security

Radioactive material must be secured against unauthorized access or removal. Unattended radioactive material may be secured by the following methods:

  1. Storage of stock solutions with greater than 500 times the value listed under column #6, "Container Posting Level", in Appendix B entitled "Table of Radionuclides" must be secured by both the following methods:
    1. Stock solutions must be stored in a room that can be locked when unattended and
    2. within the room, the stock solution must be stored in an interior locked room or in a locked non-portable storage unit such as a locked refrigerator, freezer, or cabinet.
  2. Radioactive material in use or storage of stock solution with less than 500 times the "Container Posting Level":
    1. The laboratory must be locked when unattended, or
    2. If the material is in an unlocked lab, corridor or common equipment area that cannot be locked, then it must be in a locked non-portable storage unit, such as a locked refrigerator, freezer, or cabinet.

      Note:

      1. Paragraph "A" above applies to all activities conducted under applications and amendments submitted after June 12, 2002 by a PI in which their authorized possession limit for a radionuclide exceeds 500 times the "Container Posting Level" for that radionuclide.
      2. Paragraph "A" above does not apply to radioactive material used in areas or devices for the preparation or administration of radioactive material to humans for medical diagnosis or treatment.

R. Enforcement Policy for Security of Radioactive Material

Security of radioactive material must depend on the diligence and awareness of individual users and is a reflection of the safety culture of an institution. The following action will be taken if radioactive material is observed to be unsecured in a laboratory or shared departmental facility:

  1. On the first violation, the Radiation Safety Officer will immediately suspend radioactive material ordering privileges for the responsible PI(s) until receipt of a written acknowledgement of the violation and what action will be taken to ensure radioactive material is secured against unauthorized removal.
  2. On subsequent violations, the PI(s) ordering privileges will be immediately suspended. In order to be reinstated, the PI will be required to submit a plan to correct the security problem to the Radiation Safety Committee. The RSC will then meet to consider reinstatement.
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