A copy of this example is available in the appendices of the Training Manual.

Your portable nuclear gauge license requires a solid commitment from the company’s senior management in overseeing the radiation safety program. In fact, it is frequently determined that the reason for safety and compliance violations is ineffective senior management.

Senior management is required to be involved and sign the original license application. Although senior management assigns a Radiation Safety Officer (RSO) to run and oversee the gauge safety program, it is senior management that is ultimately responsible for violations of the program. Senior management should not take this commitment lightly. They are responsible for:

• Radiation safety, security and control of radioactive materials and compliance with the regulations.
• Completeness and accuracy of the radiation safety records and all information provided to the regulatory agency.
• Knowledge about the contents of the license and its conditions.
• The need to commit adequate money and resources, including space, equipment, personnel, time, training, and, if necessary, contractors, to the radiation safety program to ensure that public and worker safety is protected from radiation hazards and that compliance with regulations is maintained.
• Selecting and assigning a qualified individual to serve as the RSO for their licensed duties. This person is to be given the necessary authority to manage and train gauge workers and, if necessary, shut down any questionable activities.

Senior management should ensure that the RSO receives proper training and refresher training as well as initial and refresher training for gauge workers.

Many companies opt to have an assistant RSO on staff. If allowable, this individual should also be listed on the license. This individual can assist the RSO and be in position to assume the RSO role in the event the current RSO departs.

Let the regulatory agency know as soon as possible of any change in RSO personnel.

Senior management should take initial gauge safety and RSO training, even if they are not involved in gauge operation. They should also work with and oversee the RSO during the annual audit.

The Radiation Safety Officer (RSO)

Your license requires that senior management designate an individual as Radiation Safety Officer (RSO). This individual will establish, maintain, enforce and control the company gauge radiation safety program and act as the contact person for the regulatory agency. When the company is contacted or inspected by the regulatory agency they will want to speak with the RSO.

Senior management is required to supply the RSO with the necessary means, including training, to carry out the position of RSO and should work with the RSO to make sure that all conditions and compliance of the license are met.

The RSO will maintain complete, accurate and organized records. The RSO is responsible for making necessary amendments and notifying the regulatory agency of these amendments. The RSO will keep the safety program updated as to any changes in the regulations.

When a new RSO is designated the licensee must immediately notify the regulatory agency. If allowable, the company should also designate an assistant RSO. This person should be readily trained and authorized to speak for the company as well as carry out all RSO responsibilities.

The ALARA Philosophy and Commitment

Regulations establish standards for protection against radiation hazards. Procedures and engineering controls are based upon sound radiation protection principles that seek to achieve occupational and public doses that are as low as reasonably achievable (ALARA).  Management, the radiation safety officer (RSO) and all authorized gauge users must participate in the establishment, implementation and operation of a radiation protection program that applies the ALARA philosophy of minimizing exposures to radiation.

The primary concept of the ALARA philosophy is that unnecessary exposure to radiation should be avoided, even though current occupational exposure limits provide a very low risk of harm.  The objective is to reduce occupational exposures (both individual and collective) as far below regulatory limits as is reasonably achievable by means of good radiation protection planning and practice.

MANAGEMENT COMMITMENT

A.    Management is committed to the ALARA philosophy of maintaining occupational and public radiation doses as low as reasonably achievable.  It is a management priority for all personnel using radioactive materials to be aware of our commitment to the ALARA philosophy and for them to be instructed in the procedures used to keep their exposures as low as possible.

B.    Management has delegated authority to our RSO to ensure adherence to ALARA principles.  Management will support the RSO in instances where this authority must be asserted.

C.    Management will make all reasonable modifications to procedures, equipment and facilities to reduce exposures, unless the cost is considered to be unjustified.  We will be prepared to describe the reasons for not implementing modifications that have been recommended.

WORKER COMMITMENT

All personnel working with portable gauging devices will adhere strictly to policies and procedures applicable to activities involving ionizing radiation sources, and will apply ALARA principles and good work practices to minimize their occupational radiation exposures.  Time, distance and shielding will be used to keep exposures ALARA.  When working with sources of radiation, minimize the time spent near the source, maximize the distance from the source, and make use of available radiation shielding.  Workers must report to the RSO any conditions in the workplace that have the potential for causing unnecessary exposures.

RADIATION SAFETY OFFICER RESPONSIBILITIES

A.    The RSO will emphasize the ALARA philosophy to workers, instruct personnel on current procedures and provide guidance on relevant changes to reduce exposures.

B.    The RSO will review dosimetry reports for all monitored personnel to determine if unnecessary exposures are being received.  The RSO will investigate within 30 days the cause of any dose considered to be excessive.  If warranted, the RSO will take corrective actions to prevent recurrence.  A report of each investigation and the actions taken, if any, will be recorded and maintained for inspection purposes.

C.    At least annually, the RSO will conduct a formal review of the radiation protection program’s content and implementation. The review will include an evaluation of equipment, procedures, dosimetry records, inspection findings, and incidents.  The RSO will assess trends in occupational exposures as an index of the program’s success and determine if any modifications to the program are needed.  A summary of the results of each annual review, including a description of actions proposed and taken (if any) will be documented by the RSO, discussed with management, and signed and dated by both.  A report on each audit will be maintained on file for 3 years from the date of the review.

D.    The RSO will provide written notifications of annual radiation exposures to all monitored personnel and will be available to respond to any questions regarding the exposure reports.