Chapter 3 - Authorization
3. Authorization To Use Radioactive Materials (Top)
The possession and use of radioactive materials at Cornell is authorized by a radioactive materials license issued by the NYSDOH. As required by the license, the use of radioactive material is restricted to specific individuals and locations authorized by the University RSC. This requirement applies to all radioactive material, including generally licensed and exempt quantity material.
All possession and use of licensed, unsealed radioactive material at Cornell requires a formal written authorization issued by the RSC called a permit.
The RSC is responsible for ensuring that radioactive materials are used safely and in compliance with ALARA. This is accomplished, in part, by formal review of a written permit application for the proposed radioisotope use. The application describes the isotope(s), amount(s), facilities, experimental procedures, hazards, precautions and the qualifications of the applicant.
In order to qualify for a permit, an applicant must be a member of the Cornell faculty or qualified staff approved by the unit leader. Other individuals wishing to utilize radioisotopes must work under the supervision of a permit holder.
The training and experience required to be granted a permit depend on the type and amount of radioactive material to be used, and on the manner in which it will be used. In general a permit applicant will be expected to demonstrate adequate knowledge of:
3.1.1 The principles and practices of radiation safety.
3.1.2 Radiation measurements, standardization, monitoring techniques, and instrumentation.
3.1.3 Good laboratory practices in the handling, storing, and disposal of radioactive materials.
3.1.4 Mathematics and calculation techniques basic to the use of radioactivity.
3.1.5 The biological effects of radiation.
3.1.6 Emergency procedures.
This knowledge is obtained through required radiation safety training provided by the RSO and from training and/or experience received prior to Cornell.
If a faculty member or senior research associate does not have adequate qualifications to be granted a permit, additional experience can be gained by working under the supervision of a more experienced colleague who is a permit holder. When the experience gained is sufficient to work independently, the application will be considered.
To become a permit holder, an individual contacts the RSO and indicates a need to use radioactive materials. The RSO meets with the individual to discuss the Cornell radiation safety program, the duties and responsibilities of a permit holder, and the application form and process. When completed, the permit application is submitted to the RSO who reviews it for completeness and then is submitted to the RSC. A subcommittee of the RSC reviews the application and visits the laboratory or other use location to discuss the application with the applicant and to review the adequacy of the facilities. The subcommittee will either approve the application or return it to the applicant for revision.
When an application is approved, the applicant will receive a written copy of the permit. On occasion, the RSC may impose restrictions on the use of the radioactive materials, if warranted, for radiation safety and ALARA reasons. These will be stated in the permit.
Permits are issued for a period of two years. Permit holders will be notified in advance of the expiration date that the permit is due for renewal. The permit holder may choose to terminate the permit or submit a request for renewal. The renewal request should specify any needed changes.
Between renewals, the permit holder may submit to the RSO written requests for amendments to the permit. The RSO will assist the permit holder as needed to provide the appropriate information. The chair of the RSC will review the request and may at his/her discretion approve it or forward it first to a subcommittee for review.
Depending on the needs of the lab, permits may be in one of the following three states:
Radioactive stocks, samples, or waste are used or stored in the facility. The facilities are subject to radiation safety requirements and oversight by EHS and the Radiation Safety Committee. Monthly surveys are required, inventory records must be kept up to date, and retraining is required annually.
Labs that dispose of all radioactive stocks,
samples, and waste can notify EHS that they have no inventory. EHS will inspect
to confirm, and provide a memo certifying the permit status is “Inactive”, at which point monthly surveys are not required. The memo is filed with monthly survey forms to explain the gap in the monthly survey records. "Inactive" permits are still inspected every six months, with emphasis on housekeeping and permitted workers staying up-to-date on refresher training.
When new inventory is received, EHS provides another memo documenting the permit status is "Active" and monthly surveys are again required.
Permits that are inactive for more than five years may be terminated.
Terminated permits are not subject to Radiation Safety Committee oversight.
EHS retains the application and documentation for a terminated permit. The permit may be reactivated relatively quickly if the protocols and facilities have not changed. Significant changes to protocols or facilities may require Radiation Safety Committee review similar to a new permit application. Personnel will be required to complete initial and/or refresher training to become authorized on a reactivated permit.
When a permit holder is expected to be away for up to six (6) weeks, the pre named Alternate Contact (AC) will be in charge of the laboratory on behalf of the permit holder. The AC will be contacted for permit related issues and will perform most of the permit holder responsibilities and functions including minor requests for permit amendments such as adding/deleting users or rooms. The permit holder will, upon return, countersign all those items which required signatures during the absence. When the permit holder and the AC are expected to be away at the same time, the permit holder must advise the RSO so that an alternate arrangement can be made.
When a permit holder is expected to be away from Cornell for six (6) weeks or more, the RSO is to be notified in writing. A substitute permit holder must be named and agree in writing to accept the responsibility for the permit for the duration of the leave. Approval of the arrangement will be made by the RSO. A permit amendment is issued to reflect the change. The substitute permit holder must hold a currently active permit.
When a permit is expected to be terminated, the permit holder must notify the RSO as far in advance as possible. This is particularly important when the termination is due to the permit holder's leaving the University. The permit holder will assist the RSO to ensure that:
3.4.1 All radioactive materials still in the possession of the permit holder are properly transferred, or disposed of.
3.4.2 Personnel’s monitoring is discontinued, where applicable.
3.4.3 The laboratory area is free of radioactive contamination and radiation signs and labels from inside the lab. DO NOT remove entryway or emergency response postings and labels, EH&S will remove these when the lab is verified free of contamination. (see Special Procedure #8, Release Criteria for Facilities and Equipment Involved with the Use of Radioactive Materials).