Rules and Mode of Functioning of the
Tufts University School of Medicine
Radiation Hazards Control Group
Revised 12/03
Table of Contents
I. Purpose
II. Organization of the Tufts Radiation Hazards Control Group
III. Delegation of Authority
IV. Radiation Safety Officer, Associate Radiation Safety Officer, & Health Physics
Section
V. Commonwealth of Massachusetts Broad-Scope License
VI. 137-Cesium Irradiator License
VII. Individual Licensees – Examination Requirement
VIII. Sponsors
IX. Responsibility of Licensees
X. Application for Permission to Use Radioactive Material (Protocol)
XI. Amendments to Established Radioactive Material Use
XII. Radiation Safety Training
XIII. Procurement and Inventory
Ordering
Receiving
Transfer (Interdepartmental)
Possession Limits
XIV. Storage & Security Policy
XV. Monitoring
XVI. Waste Disposal
XVII. Control of Radiation Exposure
XVIII. Transportation of Radioactive Material
XIX. Cautions Signs and Labels
XX. General Radiation Protection Requirements and Precautions
XXI. Minors in the Laboratory
XXII. Emergency Procedures
Attachments:
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A. Application for Radioactive Materials Licensure Training and Experience
Form
B. Sponsorship Form
C. TUSM Application for Permission to Use Radioactive Material (Protocol
Form)
D. Blanket Order Notification Form
E. Radioactive Materials Package Inventory Sheet
F. Radioactive Materials Inter - Lab Transfer Notification Form
G. Radioactive Spill Response Checklist
H. GM - Radiation Survey Record
I. Wipe Test - Radiation Survey Record
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Rules and Mode of Functioning of the Tufts University School of Medicine
Radiation Hazards Control Group
I. Purpose
The rules and regulations contained in this document have been established for the
following purposes:
A. To provide for the protection of university personnel and of the general
public against radiation hazards associated with the possession, use,
transportation and disposal of radioactive material at Tufts University
School of Medicine; Tufts University School of Veterinary Medicine, and
Tufts University School of Dental Medicine.
B. To provide for compliance with applicable conditions of all licenses issued
by the Commonwealth of Massachusetts Radiation Control Program.
C. To provide for compliance with applicable regulations of state, federal, and
local agencies.
II. Organization of the Tufts Radiation Hazards Control Group
The authority of the Tufts Radiation Hazards Control Group includes Tufts
University School of Medicine; Tufts University School of Dental Medicine; and
Tufts University School of Veterinary Medicine in Grafton.
The Control Group is presently composed of the following members:
Lewis Shuster, Ph.D., Pharmacology, Chairman
Francis X. Masse, CHP, CMP, Radiation Safety Officer
Thomas McMahon, Associate Radiation Safety Officer
David Dolins, Executive Administrative Dean
Brian Schaffhausen, Ph.D., Biochemistry
Ananda Roy, Ph.D.; Pathology
Stephen Nasson, Building & Grounds
Yvonne Glendon, Safety
Nicolas Magliano, Safety
Gary Sahagian, Ph.D., Physiology
Dmitry Nurminsky, Ph.D., Anatomy
F. Rob Jackson; Ph.D., Neuroscience
Lawrence Kleine, D.V.M., Grafton
Giovanni Widmer, Ph.D., Grafton
Ralph Isberg, Ph.D., Molecular Biology
Aruna Ramesh, DDS, Dental School
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III. Delegation of Authority
The Radiation Hazards Control Group receives its authority from the Dean of Tufts
University School of Medicine. It is charged with the following responsibilities:
1. The establishment and continuing review of an adequate radiation protection
program at TUSM and its affiliated institutions.
2. The compliance with radiation protection regulations of state agencies.
3. The administration of the TUSM Broad-Scope License and the 137-Cesium
Irradiator License issued by the Commonwealth of Massachusetts Radiation
Control Program under which all work with radioactive materials are
conducted.
In carrying out these responsibilities, the Control Group conducts a program of
licensing, review and evaluation of proposals for use of radioactive materials with a
view to maintaining standards of safe handling practice.
IV. Radiation Safety Officer, Associate Radiation Safety Officer, and the Health
Physics Section
The Radiation Safety Officer operates under the authority of the Control Group. This
individual oversees all radiation safety aspects of the Health Physics Section and
reports directly to the Executive Administrative Dean.
The Health Physics Section is comprised of the Tufts-NEMC Health Physics Section
Head (who also holds the title of Associate Radiation Safety Officer) and a staff of
Radiation Safety Specialists and Technologists. It is responsible for the following:
1. Registration and training of workers who will be involved in the handling of
radioactive materials.
2. Providing personnel monitoring (luxel badges) for documentation of radiation
exposure, as necessary.
3. Laboratory inspection, surveys and area monitoring, as necessary.
4. Radioactive waste collection, storage-for-decay, and disposal. Shipment
offsite of all long-lived waste.
5. Determining that adequate radiation protection instruments are available and
properly calibrated.
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6. Leak testing of sealed radioactive sources, as necessary.
7. Interaction with the TUSM Purchasing Department to establish parameters to
be followed for the ordering of radioactive materials.
8. Monitoring all shipments of radioactive materials as they are received.
9. Supervision of corrective action following radiation incidents and supervision
of special decontamination operations.
10. Maintenance of required radiation protection records.
11. Training for all radiation workers and those individuals affiliated with such
work.
In addition, Health Physics is available for consultation on laboratory design,
shielding design, and other radiation exposure control methods. In general, the
Radiation Safety Officer and the Health Physics Section are responsible for the
implementation of the entire radiation safety program.
V. Commonwealth of Massachusetts Broad-Scope License
Tufts University School of Medicine has been issued a Type B Broad-Scope License
by the Commonwealth of Massachusetts Radiation Control Program. It covers all
uses of radioactive materials, giving full responsibility for control and proper use of
such materials to the Radiation Hazards Control Group. This license imposes certain
limitations with respect to radionuclide, chemical compound, and quantity. It states
that radioactive materials shall be used by, or under the supervision of individuals
designated by the Radiation Hazards Control Group. It also specifies a list of
conditions of approval, all of which must be continually satisfied in the conduct of
work involving these materials.
All work must be performed in such a way that the rules and regulations detailed in
105 CMR Part 120 are satisfied. Compliance with these conditions and regulations is
included in the responsibilities of the Radiation Hazards Control Group.
VI. 137-Cesium Irradiator License
A specific license governing the conditions for the possession and use of a 137-Cs
Irradiator has been issued to Tufts University School of Medicine. Specific training is
required for authorization to use this device. Health Physics should be contacted for
more information.
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VII. Individual Licensees - Examination Requirement
Only persons authorized by the Radiation Hazards Control Group may be considered
"Licensed Principal Investigators".
Licensee candidates must be recommended by their department heads and must
submit to a written examination. Those who qualify with regard to experience and
who have successfully completed the examination will be licensed to use radioactive
materials on their own responsibility. Persons who pass the examination may be
authorized by the RSO to exercise the privileges of a licensee pending Radiation
Hazards Control Group ratification at the next meeting.
Examinations taken at other institutions do not fulfill this requirement. An
exemption from this examination is granted under only two circumstances: (1) the
investigator is board certified in either Nuclear Medicine or Radiation Oncology, or
(2) the investigator is individually named in an institutional license granted by the
NRC or an Agreement State. A copy of this license or certification must be
submitted to Health Physics for verification.
Health Physics can be contacted for study material and to set up a date for the exam.
Each new Principal Investigator must complete an “Application for Radioactive
Materials Licensure Training and Experience Form” (Attachment A) and submit it to
Health Physics.
VIII. Sponsors
Investigators with plans to work with radioactive materials but who are not licensed
may apply to work under the supervision of a licensed Principal Investigator from
another project serving as a "sponsor". That "sponsor" must become thoroughly
familiar with the proposed use and assume full responsibility for that work
during his/her sponsorship. The Radiation Hazards Control Group voted to limit
the time during which a project could be sponsored in this way to six months. If the
investigator has not satisfied the requirements for licensure within that period, the
sponsored work with radioactive materials must terminate. (See Attachment B for a
copy of the “Sponsor Obligation Form”.)
IX. Responsibility of Licensees
Each licensee under whom work with radioactive materials is being conducted is
responsible for the following:
1. Providing Health Physics with up-to-date data as necessary relative to the
rooms or areas in which radioactive materials are stored or handled.
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2. Notifying Health Physics of any changes in the listing of personnel who may
be handling radioactive materials or who may be exposed to ionizing
radiation during the course of their work.
3. Only licensees are authorized to requisition radioactive materials. Each such
licensee is directly responsible for the safe use of the material and for the
qualifications of those who use the material under his/her supervision.
4. Maintaining a comprehensive inventory of the amount of radioactive material
under his/her control at any one time, and establishing an adequate system to
insure that he/she does not possess more than that quantity of material for
which he/she is licensed to possess.
5. Insuring that radioactive materials are disposed of only by authorized means.
6. Using the radioactive material for which he/she is licensed only for those uses
specifically authorized. Any changes in use would require the submission of a
new protocol.
7. Informing Health Physics of changes in procedure which may increase the
probability of radiation exposure or laboratory contamination.
8. Insuring that personnel to whom radiation dosimetry badges are issued wear
badges during periods of possible exposure.
9. Establishing appropriate procedures to insure that radioactive materials are
properly labeled in accordance with applicable regulations.
10. Strictly conforming to the policy regarding security of radioactive materials.
(i.e.: that radioactive materials are properly controlled within the laboratory
and that they are properly stored under lock and key when not in use.)
11. Equipping the laboratory with adequate survey and/or monitoring equipment
to aid in the safe handling of radioactive material.
X. Application for Permission to Use Radioactive Materials (Protocol)
Each proposed use of radioactive materials must be applied for through the Radiation
Hazards Control Group. This is accomplished by completing an application
(protocol) for permission to use radioactive materials for each radionuclide
requested. (See Attachment C for a copy of this application.)
Hard copies can also be obtained from Health Physics. The completed application
can be submitted to Health Physics for initial review and conditional approval by the
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Radiation Safety Officer or the Associate Radiation Safety Officer. At the next
quarterly meeting of the Radiation Hazards Control Group, the application will be
reviewed and appropriate action taken to permit the proposed use. Each approved
project is valid for a period of five years. A renewal application must be submitted in
the prescribed timeframe and frequency.
XI. Amendments to Established Use
Application for amendment to an approved application should be made in writing to
the Control Group for any change in responsible personnel, use, or procedure
mentioned in the original application. Applications involving major changes require
the completion of a new application form. Minor changes involving only personnel
or minor procedural changes may be requested by letter. Any amendment, regardless
of its magnitude, must be requested in writing.
Health Physics should be informed in writing of any change in the personnel
who work with radioactive materials.
XII. Radiation Safety Training
New individuals who work in a designated radioactive materials use area must attend
the next monthly training session given by Health Physics. These training sessions are
held at 9:30 AM on the third Tuesday of each month. Contact Health Physics (6-
6168) for location.
Annual retraining of all workers by the Radiation Safety Officer is also required by
the conditions of the Broad-Scope License and by state law. Health Physics is
available for specific group instruction, as needed.
XIII. Procurement, Receipt and Inventory
A. Ordering
Only investigators licensed by the Radiation Hazards Control Group may order radio-
active materials for an approved use by filling out and signing the special three-part
radioisotope requisition form (See illustration below) and submitting it to Tufts
Purchasing. Contact Health Physics for these forms.
Health Physics supplies a list of approved possession limits of each licensed
investigator to Purchasing. Purchasing checks the requisition for compliance with
these possession limits and places the order with the supplier by telephone. All of the
requested informationmust be filled out or the order will not be placed.
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TUFTS UNIVERSITY SCHOOL of MEDICINE REG'N NO. TM 0000
RADIOISOTOPE REQUISITION
For F.X. Masse, R.S.O. Health Physics DATE__________20______
PLEASE PRINT All Items must be filled out!
ITEM QUANTITY SPECIFICATIONS (ISOTOPE, FORM, SUPPLIER, CAT.NO.) UNIT PRICE DO NOT WRITE IN THIS SPACE
IN (Quotation #'s, etc.)
MILLICURIES
ORDER DATE
1 P.O. __________
Amt. on Hand____________ milliCuries DUE DATE
ORDER DATE
2 P.O. __________
Amt. on Hand __________ milliCuries DUE DATE
Account # ________________________________
Department _______________________________ All orders should be shipped to
the following address ONLY!
Location __________________________________
Tufts-New England Medical
Center
Extension _________________________________ Proger Receiving Area
25 Harvard St.
Licensee _________________________________ Boston, MA 02111
(Print) Attn: FX Masse
Licensee _________________________________
(Signature)
Blanket Orders
Blanket orders may also be established with vendors by a licensed PI. These blanket
orders may be set up through Tufts Purchasing with the pre-approval of Health
Physics. Strict ordering limits are established based upon the assigned possession
limit for each radionuclide that has been approved by the Control Group.
Only trained radiation workers may arrange a delivery against a blanket order.
A notification that a blanket order delivery has been arranged must be
immediately faxed to Health Physics at 617-636-7777. (See Attachment D for a
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copy of this form.) The material will be held by Health Physics unless this
notification has been received. Failure to comply with this notification process
may result in the revocation of the blanket order.
Radioactive materials for the Tufts University School of Veterinary Medicine in
Grafton are ordered through normal purchasing channels at Grafton. Regular
visits to Grafton by a representative of the RSO keeps track of all such purchases
and compliance with possession limits at Grafton
B. Receiving
All TUSM and Tufts Dental radioactive material shipments are addressed to the
attention of the Radiation Safety Officer and delivered to the receiving dock at 25
Harvard St. These shipments are checked in by Health Physics and monitored for
contamination. The materials are delivered to the laboratories in the afternoon of
the day that they are received. Only individuals trained by Health Physics are
allowed to accept these items. These materials cannot be picked up at the Health
Physics office.
The individual who receives the order is required to:
(1) Print his/her name legibly on the receipt slip and also indicate the number
of stock vials contained in the package.
(2) Carefully check the packing slip to ensure that the material that is
detailed on the packing slip matches the material in the delivery box.
(3) Immediately store the material in an approved location under lock and
key.
(4) Log the receipt of the material in the inventory logbook of the laboratory.
The original shipping box is always removed by Health Physics on completion of
the delivery.
Shipments to Tufts Veterinary School are received in the Nuclear Medicine
Department, where they are appropriately monitored and their receipt recorded for
inventory control.
Inventory
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An accurate inventory of radioactive materials must be kept at all times. A
“Radioactive Package Inventory Sheet” is supplied by Health Physics for each
delivery of radioactive materials. (See attachment E.). This form is to be used to
document all use of all activity.
C. Transfer (Interdepartmental)
The transfer of radioactive materials from one licensed group to another requires
a completed “Transfer of Radioactive Materials” form to be submitted to Health
Physics. (See Attachment F). This form can be faxed to Health Physics at 617-
636-7777.
NOTE: Regulatory agencies have criticized reported transfer of materials
between projects without the required Health Physics approval. Evidence of
this type of unauthorized transfer in the future will result in suspension of
authorization for both projects involved.
D. Possession Limits
Each approved application includes a possession limit for each radionuclide
requested in the application. This limit is the maximum which may be
possessed by the licensee in his/her laboratory (including waste) for this
proposed use. It is not an ordering limit.
Control Group processing of the application includes comparison of the
possession limit requested plus that previously assigned to other licensees within
TUSM with the possession limit for that radionuclide which is listed on the
institutional license. Observance of such assigned possession limits by all
licensees is essential to insure compliance with the over-all institutional limit. As
a reminder of the need for possession limit compliance, the special radionuclide
requisition form and blanket order notification form provides a space in which the
licensee must state that quantity of the requested radionuclide which his/her
project has on hand. Inventory records maintained within the project should
readily yield this information.
XIV.
Security & Storage Policy
This policy is necessary to comply with the Massachusetts Radiation Control
Program’s Title 105 CMR Part 120.235 “Security and Control of Licensed and
Registered Sources of Radiation”. Compliance will ensure the continued
uninterrupted use of radioactive materials.
Each project authorized to work with licensed material must establish a positive
means of locking all stored radioactive materials. Examples are lockable
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refrigerator/freezers, secured-lockable container within a refrigerator/freezer, or
lockable fume hood. Access to this storage must be restricted to authorized users. (It
may be useful to consolidate radioactive samples stored in various locations to
minimize the number of freezers, etc. that must be constantly locked)
The storage container must remain locked at all times except when material is
being removed from or returned to storage.
Health Physics must be given a copy of the key or the combination to the lock.
An up-to-date inventory of storage and withdrawal must be maintained at the storage
container location.
Registered radiation laboratories must be locked when not occupied by a radiation
worker, unless all radioactive material has been secured against unauthorized
removal. (This standard has been applied to each room in a laboratory complex.)
When a radiation worker’s presence in an unlocked laboratory is the means of
security for in-use material, the worker must challenge strangers who enter the
laboratory.
Health Physics will enforce these requirements as follows:
Health Physics will inspect at varying hours on an unannounced basis checking
for:
(1) Security of radioactive materials;
(2) Maintenance of inventory record on stock; &
(3) Lockup of unoccupied room, or surveillance by registered user, or
complete lockup of all material
Action on violations:
Health Physics will notify the Investigator on the spot and will follow-up this
notification with a written warning. This violation will be reported to the
Associate Radiation Safety Officer who will bring this to the Control Group’s
attention at the next meeting.
After any repeat violations, future deliveries of radioactive materials will be
stopped until the Licensed Investigator has submitted a proposed corrective
action plan to Health Physics. This plan must also be signed by all registered
users. If this is considered adequate, radioactive material use will be renewed.
If further problems with same offender occurs, all use of radioactive material will
be stopped. The remaining radioactive material will be confiscated by Health
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Physics. The PI will have to reapply to the Radiation Hazards Control Group,
outlining corrective actions and explaining past failures.
XV. Monitoring
Radioactive material users must pay special attention to the necessary monitoring
of lab areas in which these materials are used. State regulations require that
each licensee make or cause to be made such surveys as may be necessary to
satisfy the requirement that radioactive materials are being handled and
stored properly and that contamination levels are within acceptable limits.
Institutional rules further require that each licensee be appropriately equipped to
conduct such surveys and that they be conducted at the frequency that is
commensurate with the level of activity being handled in the laboratory. Such
surveys are supplemented by the routine surveys that are taken at longer intervals
by the Health Physics staff. The following is a detailed outline of what is expected
in this regard:
A. Laboratories in which milliCurie (mCi.) amounts of gamma-emitting or
high-energy beta-emitting radionuclides are used.
1. On Days of Use - Close-out surveys of the laboratory shall be
made by a responsible individual. Survey will include a check to
be sure that that areas in which these materials are handled are
contamination free by use of GM survey meter measurements; that
radioactive materials are properly secured after use; and that major
equipment necessary for the handling of such material (hood, etc.)
is functioning correctly.
Each such survey shall be documented. Any unusual findings
shall also be noted (See Attachment H for survey form to be used.
Health Physics must approve any deviations from this form.)
2. Weekly - Weekly surveys of these same laboratories shall be a
more thorough version of A l above, and shall include wipe tests of
bench areas on which radioactive materials are handled. The
logging of these weekly surveys shall include radiation
measurements and wipe test results superimposed on a diagram of
the room.
B. Laboratories in which tritium (3H) or lesser amounts of gamma or hard
beta emitting radionuclides are routinely handled.
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1. Daily close-out surveys shall be made to determine that
radionuclides are properly identified and secured against
unauthorized personnel.
2. Weekly surveys of these same laboratories shall include the B1
procedure above, plus wipe tests of bench areas on which
radionuclides are handled. The results of these wipe tests shall be
recorded on a diagram of the laboratory, which shall become part
of the weekly survey log.
C. Additional surveys shall be made following any unusual procedure or
incident in the laboratory which may have resulted in unusual external
radiation or contamination levels. Excessive contamination levels (more
than 200 dpm/100cm2) shall be brought to the attention of the Health
Physics Section and the area in question shall be decontaminated and
resurveyed. (See Attachment I for recommended wipe test form to be used.
Health Physics must approve any deviations from this form.)
The log book containing the on-going data for each of these surveys shall
be available for review by Health Physics on their routine surveys through
the laboratories, and for review by State compliance inspectors during
their annual inspection. Principal Investigators and laboratory supervisors
shall ascertain that the necessary survey equipment is available to perform
the required procedures and that a specific individual is assigned the tasks.
Health Physics personnel are available to assist in setting up an appropriate
survey program if such help is needed.
Action Levels
GM Survey - Twice Background
Wipe Test Survey - 200 dpm/100cm2
Although a particular lab may not have worked with radioactive materials
anywhere within the lab during a particular week, the lab is still required to
record the weekly date and state that no materials were utilized. The
Commonwealth of Massachusetts Radiation Control Program does not tolerate
gaps between wipe tests. This will not be required if a project involving the use of
radioactive material is stopped for an extended period of time and an entry is made in
the logbook with the notation that wipe tests and/or GM surveys will be performed
when work with activity is started up again. Health Physics must be formally notified of
such suspended use periods.
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Survey Meter Registration and Calibration
Health Physics is available for recommendations on the appropriate survey meters
which should be used for any given project. All newly purchased survey meters must
be registered with Health Physics prior to use. Health Physics is required to calibrate
all survey meters on an annual basis. Please check the date on the label attached to the
survey meter to ensure that it has been calibrated within the required timeframe.
Batteries will also be supplied, as necessary. A check source will be attached to each
meter by Health Physics.
XVI. Waste Disposal
1. Radioactive Waste Containers
Radioactive laboratory waste is to be stored in containers which have been
approved by Health Physics, and are specifically labeled, “Caution Radioactive
Waste”. These containers have been distributed throughout the institution for the
purpose of temporary radioactive waste storage. There are several types that may
be used:
18 and 22-gal. Rubbermaid Storage-for-Decay containers - Dry/Solid
Plexiglas boxes - Dry/Solid 32-P waste.
Red “Sharps” boxes - sharps/hypodermic needles/syringe waste.
55-gal. yellow regulated drums - regulated LSV waste.
2. Color Coding System
All radioactive waste will be separated into half-live categories. Each container
will be labeled with colored stickers indicating the isotopes that may be disposed
into it.
Pink half-lives 15 days
Yellow half-lives 15 days 120 days
Purple half-lives 120 days
3. Disposal of Waste in the Laboratory
Dry/Solid:
Dry/Solid waste is to be placed in clear plastic bag liners in an appropriate
radioactive waste container.
All radiation symbols must be defaced.
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Each waste container must have an external inventory card containing the
following information about its contents: activity, user’s initials, &
disposal date.
Waste will not be picked up if improperly prepared.
Only approved forms of Dry/Solid waste are allowed in the containers.
Approved forms of Dry/Solid waste:
Papers
Plastics
Rubber / Gloves
Eppendorf tubes (containing minute amounts of liquid)
Unacceptable forms of Dry/Solid waste:
Glass
Lead
Liquids of any kind
LS vials (containing liquid)
Hypodermic syringes/needles
Radiation symbols (unless defaced)
Animal carcasses/parts/bedding
Biohazardous material
Liquid Scintillation Vials (containing scintillation fluid):
This form of waste is to be disposed of in separate containers labeled for
scintillation vials. Scintillation vials containing fluids cannot be placed in
Dry/Solid containers. Scintillation vial waste falls into two categories:
H-3 and C-14 scintillation vials (averaging less than 0.05 Ci/g over the
entire drum) are to be placed in black deregulated vial drums.
Scintillation vials containing all other isotopes should be placed in
containers provided by the Health Physics office, specifically intended for
scintillation vial use, with an accompanying inventory card.
Dry/Solid waste cannot be placed in these containers.
Inorganic/Organic Liquids (water soluble/dispersible):
This form of waste may be disposed of in “Approved Disposal Sinks” (contact
Health Physics to have a sink designated for this type of disposal) provided that
several guidelines are strictly followed:
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1. The sink must approved and labeled as such, with a dilution chart and
disposal log.
2. A maximum of 2.0 mCi in one day and an average of no more than 0.5
mCi per day in one week may be disposed.
3. Contact Health Physics if larger quantities require disposal. Health Physics
is responsible for coordinating all such disposal to comply with applicable
regulations.
Insoluble Liquids:
This form of waste is not to be disposed of by lab personnel. Please contact Heath
Physics before you start your project if your research will produce such waste.
Biohazardous Material:
Radioactive waste resulting from work done with a biological hazard must be
treated to neutralize the hazard. Contact Health Physics for information on
approved neutralization methods. There is a specific method that has been
approved by the Control Group to inactivate HIV-related waste. Contact Health
Physics for further information. Active biohazards cannot be placed in the
radioactive waste containers.
Animal Carcasses/Parts/Bedding:
Contact Health Physics if you have any animal carcasses/parts/bedding
contaminated with radioactive material to dispose of.
Glass:
Contact Health Physics if you have glass contaminated with radioactive material
to dispose of that cannot be readily decontaminated.
Hypodermic Syringes/Needles (all “sharps”, scalpels, razors, etc.):
All “sharps” contaminated with radioactive material are to be placed in approved
red sharps boxes which are provided by Health Physics.
Lead:
Contact Health Physics if you have contaminated lead. Health Physics will also
collect all clean lead isotope containers for recycling. It should be noted that
improper disposal of lead violates EPA waste guidelines and under no
circumstances should lead be disposed of as regular waste.
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4. Laboratory Waste Removal
Waste containers within the lab are emptied by Health Physics in accordance with
the following conditions:
The Health Physics office is notified that a radioactive waste container is
3/4 or more filled and needs to be emptied. Waste will be removed within
two working days of notification. (ext. 6168)
Arrangements have been made with the Health Physics staff such that the
container is to be emptied on a scheduled basis (i.e. daily, weekly, etc.).
These arrangements are made on an individual basis.
A member of the Health Physics staff will bring a transport vessel
(typically a wheeled waste cart) to the lab for this pickup. A visual
inspection of the waste will be made to assure that the waste has been
properly prepared. If the waste meets the set disposal criteria, it is placed
in the waste cart along with the attached inventory card, and removed to
the appropriate waste processing area. A new inventory card is then
placed on the waste container.
Conditions for waste pick-up denial:
Improperly filled out or blank inventory card.
Unacceptable items present in the waste
Inaccessibility to waste (i.e. locked lab).
Mixing of waste types (i.e. filled LSV in Dry/Solid waste)
Undefaced radioactive labels in the waste.
5. Waste Handling
Waste obtained from a laboratory and brought to a Waste Processing Area is
handled in one of the following manners:
Dry/Solid waste characterized as Storage-for-Decay waste:
This waste is segregated by isotope and placed in an appropriately labeled drum to
be held for decay.
Dry/Solid waste falling outside the category of Storage-for-Decay waste:
This material is packaged for eventual off-site disposal
Animal Carcasses/Parts/Bedding:
This is placed in the facility’s storage freezer for decay. Long half-lived waste
(greater than 120 days) are shipped offsite for disposal.
Liquid Scintillation Vial Wastes:
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These are brought to that facility’s LSV processing area and placed in a 55-gallon
LSV drum for eventual off-site disposal.
Inorganic (water soluble) or Organic (non-water soluble) Liquid Waste:
These materials are brought to the facility’s liquid waste storage area.
Organic (water soluble) Liquid Waste:
This material is disposed of in approved laboratory sinks.
Lead:
All lead is collected and scanned. Clean lead is defaced and recycled, and
contaminated lead is placed into storage.
XVII. Control of Radiation Exposure
Under all circumstances exposure to ionizing radiation shall be kept at the lowest
practical level. The external and internal total exposure from sources of radiation
shall be controlled in such a way as to assure that no individual receives a total dose
in excess of the following values:
A. Maximum permissible doses for persons who are registered as radiation workers:
Except as provided in paragraph (B), radiation doses (combination of internal and
external) shall not exceed the following:
mRems per Year
1. Whole body; head and trunk; active
blood-forming organs; & gonads 5,000
2. Lens of the Eye 15,000
3. Extremities 50,000
4. Skin of whole body 50,000
B. Maximum permissible doses for minors (including those persons under 18 years
of age who are working in radioisotope laboratories) are one-tenth of the values
listed in A above.
C. Maximum permissible doses to a “declared pregnant worker” with respect to the
fetus shall be no more than 500 mRem per gestation period. Contact Health
Physic for further information regarding the guidelines involving a voluntary
declaration of pregnancy.
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D. The above values in B and C are in addition to natural background radiation
exposure and to radiation administered for medical reasons.
ALARA Program
Occupational radiation exposures to radiation workers are maintained “As Low As
Reasonably Achievable (ALARA)”. Exposures in excess of 10 % of the established
annual limits shall be investigated by the RSO and reported to the Radiation Hazards
Control Group.
Personnel Dosimetry
Changes in the departmental personnel dosimetry listing should be requested of
Health Physics in writing as soon as possible in order to insure that each person
receives adequate monitoring promptly. Spare luxel badges can be assigned, as
necessary. These badges can be picked up at the Health Physics office located on the
3rd floor of the Holmes building.
Internal Exposure Control
Internal exposure is controlled by minimizing airborne release of radioactive
materials through the proper utilization of hoods, closed reaction systems,
temperature control, mechanical pipetting devices and/or any such appropriate
mechanism. Monitoring for adequacy of such control procedures may be
summarized as follows:
All work with radioiodine (NaI) compounds above 0.1 mCi must be conducted in an
approved fume hood. Contact Health Physics for the location of the nearest approved
fume hood. A mini-hood is required to be used for all procedures utilizing more than
one-milliCurie of NaI. Thyroid counts are performed on personnel between one &
two working days after procedures involving more than 1 milliCurie of radioiodine.
Once the adequacy of control precautions is established, a monthly monitoring
schedule for those persons routinely handling milliCurie quantities is observed.
Urinalysis is performed on a monthly basis on all persons routinely handling more
than 10 milliCuries of 3H-labeled compounds at any one time; and on a weekly basis
when the quantity handled exceeds 100 milliCuries.
Results that indicate the presence of 10% or more of a permissible body or organ
burden would lead to a thorough investigation by Health Physics and the adoption of
additional procedural restrictions as indicated.
XVIII. Transportation of Radioactive Material
18
The Broad-Scope License includes no provision for the transportation of radioactive
material outside of the university premises by the licensed investigators. Under no
circumstances should any user pick up radioactive material from a supplier,
return an improper shipment to the supplier, borrow radioactive material from
another institution in the area, or in any way transport radioactive materials in
his/her own private vehicle. Such transportation of material must be by authorized
transportation agencies and in compliance with Department of Transportation
regulations. Should such transportation become necessary, contact Health Physics for
assistance.
The transportation of radioactive materials within the institution (hand-carrying from
laboratory to laboratory) shall be done in such a manner as to assure a minimum
chance of contamination. All material must be doubly contained, properly labeled,
and must never be left unattended. Under no circumstances should the dose rate on
the surface of the container being carried exceed 100 mRem/hour, nor should the
dose rate one meter from the surface of the carrying container exceed 10 mRem/hour.
Health Physics must be notified of all such transfers before they occur.
(See Radioactive Materials Inter-Lab Transfer Notification Form – Attachment F)
XIX. Caution Signs and Labels
Each laboratory storing or using radioactive materials shall be posted with
appropriate signs, in conformity with 105 CMR 120.000. These signs shall be
installed or removed only by Health Physics. These signs also contain contact
numbers for research staff to contact Health Physics personnel. Additionally, the
licensee in each department should post each laboratory with sufficient emergency
notification information so that a knowledgeable laboratory person could be
contacted in the event of a laboratory emergency during non-working hours.
Each container in which radioactive material is to be stored for a period of time must
be labeled in conformance with appropriate regulations. Specifically, the label must
contain the words "Caution, Radioactive Material" along with information
regarding the quantity and kind of radioactive material in the container and with the
date of assay. Appropriate label blanks are available from commercial suppliers.
Small quantities may be obtained from Health Physics. Labeling is not required for
laboratory containers such as beakers, flasks, and test tubes used transiently in the
laboratory in the presence of the user.
XX. General Radiation Protection Requirements and Precautions
19
Following are the general requirements and precautions applicable to work with
radioactive material:
A. There shall be no smoking, eating, storage of food or use of cosmetics where
radioactive materials are being used, transferred or stored.
B. There shall be no mouth-pipetting of radioactive solutions.
C. Prior to the performance of a procedure involving radioactive material, radiation
levels must be measured. Handling tongs, or a suitable remote handling device
must be used for handling a source or container which emits a dose rate, at
contact, in excess of 100 mRem per hour, unless otherwise specially authorized
by the Control Group.
D. When performing procedures that might produce airborne contamination
(i.e., evaporations, transfers of unsealed powdered or volatile radioactive
material), an approved exhaust ventilation hood shall be used.
E. When hand or clothing contamination is possible, protective gloves and a lab coat
shall be worn.
F. After handling unsealed radioactive material, hands shall be washed before
leaving the laboratory. Exposed hair, skin and clothing shall also be surveyed for
contamination. Health Physics shall be notified immediately if, after
decontamination, residual contamination of skin, hair or personal clothing is
detected.
G. Objects and equipment that may have been contaminated with radioactive
materials shall be surveyed for exterior surface contamination prior to their
removal from the laboratory. If surface contamination is detected, the
contaminated objects shall not be removed from the laboratory without the
authorization of Health Physics.
H. Health Physics shall be notified immediately if any of the following
circumstances in known or suspected to have occurred:
1. Exposure to external radiation in excess of the maximum permissible
exposure values stated above.
2. Exposure to inhalation, ingestion or accidental injection of radioactive
material.
3. Accidental release of radioactive material into laboratory atmosphere, drains
or ventilation systems or onto surfaces (i.e.: spills).
20
XXI. Minors In the Laboratories
The Radiation Hazards Control Group has formalized a policy which states that;
“Minors are not allowed to be present in laboratories in which radioactive
materials are used unless they are in an organized work or training program
which has the prior approval of the University Safety Office and Health
Physics.”
The Commonwealth of Massachusetts’ regulations define a minor as an individual
less than 18 years of age. 105 CMR 120.217 states that “ The annual occupational
dose limits for minors are 10% of the annual occupational dose limits specified for
adult workers.”
The exposure to a minor who is employed at Tufts would have to be controlled so
that the annual occupational total effective dose equivalent received would have to be
less than 500 mRem/year. Any Principal Investigator who plans to have minors
present in his/her laboratory must notify Health Physics to review work activities of
the minor and potential exposure levels prior to the start of such work.
XXII. Emergency Procedures
A member of the Health Physics Staff is on call to help in any emergency involving
radioactive material. The federal and state regulations governing the use of
byproduct material includes strict reporting requirements with regard to emergencies.
In order for us to comply with these regulations, it is important that all spills,
accidental ingestions, or misplacement or loss of radioactive material be
reported immediately to Health Physics.
Radioactive Spill Procedures
Minor Spills of Liquids and Solids
1. Notify persons in the area that a spill has occurred.
2. Prevent the spread of contamination by covering the spill with absorbent
paper.
3. Clean up the spill using disposable gloves and absorbent paper. Carefully
fold the absorbent paper with the clean side out and place in a plastic bag
or transfer to a radioactive waste container. Also put contaminated gloves
and any other contaminated disposable material in the bag.
21
4. Survey the area with a radiation detector survey meter set on the lowest
range. Check the area around the spill. Also check your hands, clothing
and shoes for contamination.
5. Report the incident to the Health Physics.
6. Health Physics will follow-up on the cleanup of the spill.
7. A Radioactive Spill Report (Attachment G) must be completed, signed by
the Principal Investigator, and forwarded to Health Physics.
Major Spills of Liquids and Solids
1. Clear the area. Notify all persons not involved in the spill to vacate the
room.
2. Prevent the spread of contamination by covering the spill with absorbent
paper, but do not attempt to clean it up. To prevent the spread of
contamination, limit the movement of all personnel who may be
contaminated.
3. Shield the source if possible. This should be done only if it can be done
without further contamination or a significant increase in radiation
exposure.
4. Close the room and lock or otherwise secure the area to prevent entry.
5. Notify Health Physics immediately.
6. Decontaminate personnel by removing contaminated clothing and flushing
contaminated skin with lukewarm water and then washing with mild soap.
If contamination remains, induce perspiration by covering the area with
plastic. Then wash the affected area again to remove any contamination
that was released by the perspiration.
7. Health Physics will supervise cleanup of the spill.
8. A Radioactive Spill Report (Attachment G) must be completed, signed by
the Principal Investigator, and forwarded to Health Physics.
22
EMERGENCY NUMBERS
Health Physics office number 636 - 6168
(8:00 AM - 4:30 PM Monday-Friday)
Emergency page number Page # 2413
(All hours)
Tufts-NEMC Communications
(to access page # 2413) 636 – 5111 or 5114
Health Physics mailbox Tufts-NEMC # 787
23
Application for Radioactive Materials Licensure Attachment A
Training and Experience Form
Name: ____________________________________ Department:_______________________________
Location: __________________________________ Phone Number: ____________________________
Type of Training Institution Duration On the Job Formal
of Training of Training Training
Training
Principles and practices of YES NO YES NO
radiation protection
Radiation monitoring YES NO YES NO
techniques & instrumentation
Mathematics and calculations YES NO YES NO
basic to the use and
measurement of radioactivity
Biological effects of radiation YES NO YES NO
Please list all of your previous experience with radioactive materials below:
Isotopes Maximum Institution(s) Duration of Type of Human or
Used Amount where Experience Studies Non-Human
Used Experience was Study?
Gained
I hereby authorize any or all of the above information to be disclosed to pertinent and required personnel
for the purpose of fulfilling the partial requirements of radioactive materials licensure at:
TUSM: _______________ USDA-HNRC: _______________ Tufts-NEMC: _______________
Signature of Applicant : ___________________________________ Date: _______________
Attachment B
24
Tufts University School of Medicine
Application for Radioactive Materials Licensure
Acknowledgment of Obligation and Sponsorship
As part of the conditions of Tufts University School of Medicine's Broad Scope License issued by the
Commonwealth of Massachusetts, a principal investigator who wishes to work with radioactive
materials must be licensed by the Tufts Radiation Hazards Control Group. This licensee must be
recommended by his/her Department Head and must also submit to a written examination. Those who
'successfully complete this examination will be licensed by the Radiation Safety Officer (RSO) pending
ratification by the Radiation Hazards Control Group to use radioisotopes on their own responsibility.
Each licensee will be responsible for ensuring that all uses of radioactive material in his/her laboratories
are in compliance with all regulations.
Examinations taken at other institutions do not fulfill this requirement. An exemption from this
examination is granted under only two circumstances: (1) the investigator is board certified in either
Nuclear Medicine, or Radiation Oncology or (2) the investigator is individually named in an institutional
license granted by the NRC or an Agreement State. A copy of this license or certification must be
submitted to the RSO for verification.
The Control Group has allowed for a sponsorship period whereby a licensee from the same department
may serve as a sponsor for a new researcher. The sponsor assumes full responsibility for that researcher's
work with radioisotopes for a period not to exceed six months. The sponsor must also sign all
requisitions for radioactive materials. If the researcher has not satisfied the requirements for licensure
within this time frame then all work with radioactive materials must terminate.
I have read the above statement and am familiar with my obligation to successfully complete a written
examination within six months.
Signature: ____________________________________ Date: _____________________
Sponsor Signature: _____________________________ Date: _____________________
Dept. Head Signature: __________________________ Date: _____________________
Associate RSO Signature: _______________________ Date: _____________________
RSO Signature: _______________________________ Date: _____________________
Tufts University School of Medicine
25
Radiation Hazards Control Group
Application for Authorization to Use Radioisotopes
Date Received:
Applicant: Department:
Position: Phone:
I. Specific Materials, Purpose, Procedures
A.
Radioactive Material(s) Chemical and/or Physical Form Maximum Amount Needed on hand Maximum Amount used in any Procedure
(Isotope) (Possession Limit)
Comments:
B Brief Description of Purpose and Nature of Project:
C. Procedures Followed, Number of Persons Involved, Frequency of Use, Locations of Use and Special Arrangements
to be Made (if necessary):
D. Are any animals involved in the procedure? Has approval been given by Lab Animal Medicine? If so,
please include a copy of the form submitted to Lab Animal Medicine along with form HP # 1 “Tufts-NEMC
/ TUSM Protocol Form for the Use of Radioisotopes in Animals” .
26
II. Storage of Radioactive Material
Regulations require that radioactive materials be secured at all times when not in use, and that Health
Physics has a copy of the key to the lock. Please acknowledge that you and all the members of your lab are aware
and understand this policy by initialing below. If you need a copy of the Security Policy, contact the Health Physics
Office.
Initial:
Material will be stored: (building, room, refrigerator or container type):
III. Disposal of Radioactive Material
The Commonwealth of Massachusetts and EPA do not allow the treatment of mixed waste (any combination of
biohazardous, chemically hazardous, and radioactive material defined as waste)! Therefore procedural steps must be
taken to ensure that the end product of your work are in approved disposal forms before becoming waste requiring
disposal. Contact Health Physics for a copy of the Radioactive Waste Management Guidelines.
A. Biologically Hazardous Material
Does this research involve or result in any biohazards (such as infectious agents)? If so, detail the steps that
will be taken to inactivate the hazard. For information on approved inactivation techniques, contact the Tufts
Biosafety Officer (extension 7615).
B. Chemically Hazardous Material
27
Does this research involve or result in any chemically hazardous material (hazardous as defined: reactive,
corrosive, flammable or toxic)? If so, detail the steps that will be taken to neutralize the chemical hazard. For
questions contact Tufts Chemical Safety Officer (extension 7615).
C. Radioactive Waste Disposal/Accumulation: (List Building and Room Number)
i. Low level Liquid Waste Sink:
ii. Solid Waste Containers:
iii. Scintillation Vials (regulated and deregulated):
iv. Animals:
v. Other (liquids, chemicals, etc.):
V. Surveillance and Safety
A. Survey instruments, shielding and protective equipment to be used. List the room location for the liquid
scintillation counter that will be used for the weekly wipe tests.
B. Lab surveillance and monitoring to be done: (i.e. weekly wipe tests and daily GM survey)
C. Regulations state that all individuals who have unescorted access in areas where radioactive materials are
used be trained initially and annually in radiation safety principles by Heath Physics.
List of radiation workers associated with program Working with which isotopes? Film badge required? Trained in last year?
D. rDNA Research Registration:
All research utilizing recombinant DNA must be registered with the Tufts Safety Office. If you are not
registered with the Tufts Safety Office for this, please call them to arrange registration (extension 7615).
28
Does this research utilize rDNA techniques, (Yes/No) . If yes, please give registration number,
title and approval date.
Registration Number:
Approval Date:
Title:
VI. Required Signatures (signatures 1-3 must be obtained before submission to Health Physics).
i.
Signature of Applicant Date
ii.
Signature of Sponsor (if applicable) Date
iii.
Signature of Department Head Date
Application approved subject to ratification of full committee at the next quarterly meeting.
iv.
Signature of Associate Radiation Safety Officer Date
___________________________________________ ______________________
Signature of Radiation Safety Officer Date
Comments:
(Revision Date 11/20/03 – TMc)
TUSM BOSTON CAMPUS Attachment D
BLANKET ORDER NOTIFICATION
FOR
RADIOACTIVE MATERIALS
29
Please complete the following form and fax it to the Health Physics office (617-636-7777) as soon as you have requested a
shipment under a blanket order. Radioactive packages will not be delivered to areas that fail to notify Health Physics of
their request for shipment under blanket orders.
Today’s Date (Date ordered): _________________________
Purchase Order Number: _____________________________
Principal Investigator: _______________________________
(Authorized Licensee only)
Deliver to: ___________________ Extension: ____________
(Building/room #)
Name of person placing the order: ____________________________
Package Due Date: __________________________________
Company: ___________________________________________
(NEN, ICN, Amersham, etc…)
Item Catalog Quantity Total Amount of Isotope Chemical Amount on
Number (#of Vials activity ordered Form hand
or # of kits) (uCi/mCi) (uCi/mCi)
1
2
3
All radioactive packages must be shipped to the following address ONLY!
Tufts - New England Medical Center
Proger Receiving Area
25 Harvard Street, Boston, MA 02111
Attention: F. X. Masse’
When ordering radioactive materials, please do not have the name of the Principal Investigator or the laboratory
location printed on the attention line. Thank You!
RADIOACTIVE MATERIALS Attachment E
PACKAGE INVENTORY SHEET
Institution: ___________________________
30
Principal Investigator: ___________________________________________
Room where material will be stored: ________
Company: ______________________ PO Number: ______________________
(Example: NEN, ICN, Amersham) ( Example: A0234, H123456, P123456)
Isotope: ________________________ Amount: ____________________
(Example: P-32, S-35…) (Example: 1.0mCi, 250uCi)
Chemical Form: __________________ Lot Number: _________________
(Example: dATP, TTP, methionine …)
Date Received: ___________________
Use ONE inventory sheet per stock vial. Please fill in the date the isotope was used, the amount used in (uCi), the amount remaining, the
room where you will use the material, and your initials each time activity is removed from the stock vial.
Amount Used Amount Room where Initials
Date (uCi) Remaining (uCi) material will be
used
Date of Stock Vial Disposal: _____________________
Radioactive Materials Inter-Lab Transfer Notification Form Attachment F
This is to notify you that the following radioactive materials have been transferred out of our lab’s inventory and into another
lab’s inventory.
31
Note: “The transportation of radioactive material within the institution (hand-carrying from laboratory to laboratory) shall
be done in such a manner as to assure a minimum chance of contamination. All such material must be double contained, and
must never be left unattended. Under no circumstances shall the dose rate on the surface of the container being carried
exceed 100 milliRem/hour, nor shall the dose rate one meter from the surface of the carrying container exceed 10
milliRem/hour.”
Transferring Laboratory
Transferring Laboratory: _____________________________________
Date of Transfer: _____________________
Isotope: _____________________ Chemical Form: ________________________________
Amount of Activity (uCi): ________________________________
Volume of Material transferred (ml): ________________________________
Lot Number of Stock Solution: ________________________________
Receiving Laboratory
Receiving Laboratory: _______________________________________
Amount of Maximum
Material On Hand (mCi): _______________________ Possession Limit (mCi): __________________________
Name of Person
Transferring Material (Print Clearly): ___________________________________________ Initials: _______
Name of Person
Receiving Material (Print Clearly): ___________________________________________ Initials: _______
Prior to Transfer
Fax Completed Form To: Health Physics Section
Tufts-New England Medical Center
Fax: (617) 636-7777
Phone: (617) 636-6168
Please retain a copy for your records
Radioactive Spill Response Checklist Attachment G
Date __________ Time______________ Location _______________
Radioisotope ______________ Estimated Activity _________ mCi.
32
Highest Contact Reading _________ mRem/hr.
Highest Reading @ 1 meter _____________ mRem/hr
Names of Individuals Involved in the Spill _________________________________________
_________________________________________
_________________________________________
_________________________________________
[ ] Persons in the area were notified that a spill had occurred.
[ ] Absorbent paper was used to prevent the spread of contamination.
[ ] A survey of the person involved in the spill was performed with the survey meter set on the lowest range. Hands,
clothing and shoes were checked for contamination.
[ ] Health Physics was notified immediately (ext. 6168).
[ ] The area was secured (roped off) to prevent the spread of contamination.
[ ] Identified contaminated personnel were decontaminated by removing any contaminated clothing , flushing
contaminated skin with lukewarm water, and washing with mild soap. [ ] Not applicable.
[ ] The spill was cleaned, using the spill response kit available, by cleaning from the area of least contamination inward
to the area of greatest concentration.
[ ] Final wipes for removable contamination taken of all affected areas were less than 200 dpm/100 cm2.
[ ] The licensed Principal Investigator was notified.
Brief Description of Event:______________________________________________________________________________
____________________________________________________________________________________________________
____________________________________________________________________________________________________
____________________________________________________________________________________________________
____________________________________________________________________________________________________
Completed by ________________________________________________ Date ________________
Principal Investigator Signature ___________________________________ Date ________________
[To be submitted to Health Physics along with Attachments H & I (GM survey sheets and wipe tests specific to this
incident). One copy should be kept with your records.]
GM - RADIATION SURVEY RECORD Attachment H
Department:_______________________ Location:________________ Licensee:________________________
Unless otherwise specified, all measurements are in mRem/hr, and are made with an end-window Geiger counter. A
check mark in the box indicates that a background reading was present. All readings above background are to be
33
documented. If radioactive materials have not been used during a given week, then a notation to this effect must be
entered.
A - Bench
B - Bench
C - Bench
D - Sink Area
E - Bench
F - Bench MAP AREA
G - Bench (draw map of your lab space and label each area)
H - Hood
I - Phone
J - Floor
K - Refrigerator
L-R for additional locations
Date
Initials
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
34
WIPE TEST - RADIATION SURVEY RECORD Attachment I
Licensee:________________________ Location:_________________
Department:_________________________ Location of Liquid Scintillation Counter __________________
A check mark placed in each box represents that each wiped area was found to be less than 200dpm/100cm 2. If the
wipe area is found to be greater than 200dpm/100cm2 , that number will be documented, and the area will be
decontaminated to the appropriate level. If radioactive materials have not been used during a given week, then a
notation to this effect must be entered.
A - Bench
B - Bench
C - Bench
D - Sink Area
E - Bench
F - Bench MAP AREA
G - Bench (draw map of your lab space and label each area)
H - Hood
I - Phone
J - Floor
K - Refrigerator
L-R for additional locations
Date
Initials
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
35
36