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Volume 4.1 For the University of Maryland Campus March 2002
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| Procedures and Policies Governing Radiation Safety at the University of Maryland |
As the new year rolls along the season of audits starts fresh and anew. The Maryland Department of the Environment's (MDE) Radiological Health Section routinely audits the University's Radiation Safety Program. This year should be no different than any of the past years. Well, actually we hope that this year's audit will be better because we are always looking to improve. MDE typically sends 2-3 inspectors to check on the Program. In many ways this audit is no different than the audit conducted by our staff of your laboratory.
The inspectors arrive unannounced at our door and then proceed to announce that they have arrived for the annual inspection of our license. The University has a license to Possess and Use Radioactive Material in various forms and shapes and sizes. Your Authorization to Possess and Use Radioactive Material is a simpler and smaller version of the campus license. In a way the Radiation Safety Officer is the Principal Investigator for the University's license. When an inspector finds a non-compliance issue or violation in your lab during an inspection, you receive a notice and must respond with corrective action. In the same way the University receives a notice and follow-up letter with non-compliance issues and violations from MDE, which must be responded to in writing within 20 days. The Notice of Violation, received from MDE, and a corrective actions letter from the University, must be posted at all locations where violations to the University license were found.
In 1997 the University was cited for 11 violations, 7 in 1998, 7 in 1999, and 8 in April of 2001. Typical violations have involved "not surveying or wipe testing packages received by our office, not being able to locate training records, having survey meters out of calibration, not having proper postings in the laboratories authorized for use of radioactive material, evidence of food and or beverages in the labs, missing wipe test records in the lab, and not wearing proper dosimetry while using radioactive material." As you can see the responsibility for these violations rest with both the individual user, whether they are a Principal Investigator, or Authorized User and the Radiation Safety Officer. A failure to respond in the required time frame to MDE can have several impacts; a modification, revocation or suspension of the University license, an issuance of Departmental Order under the Maryland Regulations, and or financial penalties of up to $1,000 per violation, per day. Section 6 of the Campus' Radiation Safety Manual requires that "Principal Investigators act to be compliance as soon as possible and that the RSO will assist the user if necessary or requested." The RSO is also charged with recommending suspension of activities where "there is a disregard for compliance with appropriate regulations..." In the event that a suspension occurs the user has the right to appeal to the Radiation Safety Committee. The Radiation Safety Committee has the authority to terminate an authorization under the University license.
So in many ways having an Authorization to Possess and Use Radioactive Materials is just like having a License to Possess and Use Radioactive Materials; we each must comply with the regulations, policies and procedures set down in the Radiation Protection Program, submit to audits, reply to audits if necessary and continue to work towards a safe and healthy work place. Together, I believe we can.
If you would like to reply to the Newsletter please forward your comments or questions to the editor.
For direct assistance contact the RSO at (301) 314-8336.
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