Radiation Safety Compliance

POINT SYSTEM FOR NON-COMPLIANCES

Justification
To ensure that the University complies with the State Bureau of Radiation Control Regulations regarding the use of radioactive materials, all authorized users are required to comply with the University’s radiation protection program.

On December 9, 2004, the FIU Radiation Control Committee (RCC) approved a point system which was accepted by the Florida Bureau of Radiation Control as the comprehensive mechanism the University will use to regulate itself under the conditions of the Radioactive Material Broad Scope License. According to the Point System the authorized users accumulate points for non-compliances with the Radiation Program. Table 1(Radiation  Safety Manual) gives points that an authorized user will accumulate for various non-compliances.

Consequence of the Points Accumulated:

  • When an authorized user accumulates 5 points he/she will be notified of the points accumulated with a copy to the department chair. The authorized should post notice of violations in a visible location. Not posting notice of violation will be considered as violation.
  • The authorized user will be given an opportunity to remove points by undergoing additional training.
  • A maximum of 5 points accrued can be removed over a 3 year period from additional training. The remaining points stay on for 3 years. To remove any point written appeal must be submitted to the Vice President for Research (see section reinstating an authorized user). 
  • If an authorized user accumulates 10 points or more over an academic year (July 1 to June 30) and/or 20 points over 3 consecutive academic years his/her privilege to work with radioactive materials will be withdrawn within a week, via a memorandum with a copy to Department Chair, Director EH&S, and Chairperson, Radiation Control Committee.  

Reinstating an Authorized User
An authorized user whose privileges to work with radioactive materials were withdrawn should:

  • Acknowledge the receipt of notice from the Committee/ RSO on behalf of the Committee within 10 days of receipt.
  • Post copy of the notice at a visible location in his/her laboratory.
  • Suspend work with radioactive materials within the time specified in the notice.
  • May request Director of Environmental Health & Safety to extend the date of suspension of work with radioactive materials to enable him/her to complete the work in progress. 
  • Submit written Appeal to the Vice President for Research with copy to the Director EH&S and the RSO stating the corrective measures he/she plans to implement to prevent recurrence of non-compliances and request for removing the points.
  • The Vice President of Research in consultation with Director EH&S, decides whether to remove the points, if so how many for which years and responds to the authorized user with copy to the Director EH&S and the RSO.

Custody of Radioactive Materials 
If privileges to work with radioactive materials of an authorized user are withdrawn and an appeal to reinstate is rejected by the Vice President, the RSO does the following:

  • Informs the authorized user, the department chair and the department Representative to the Committee of the decision.
  • The department chair and Representative and the RSO will discuss appointment of an alternate authorized user in the department who will take custody of the radioactive materials. The Representative and the RSO work together to assure expedited training or authorization for the alternate user, if required.
  • The alternate user takes control of all radioactive materials and complies with approved procedures.