Radiation Safety Officer Training

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P. Situ & J. Goodrich (2022) Contact PeterSitu@4statesRSO.com for certification details

This course is designed as a question based, interactive guided study under the supervision of a Preceptor Radiation Safety Officer.

The trainee will:

-Keep a journal of the requested activities and calculations,

-Participate in all facility radiation safety committee meetings, and

-Review all Materials' License records for the facility.

Upon successful completion of the comprehensive examination, the preceptor RSO will have sufficient material to request authorization of the trainee as an Associate RSO or RSO for a clinical or hospital-based program, as described in 10 CFR 35.50(b)(1)(i-ii).

Links of Interest

Health Physics Society: FIND AN ANSWER

10 CFR 19: NOTICES, INSTRUCTIONS AND REPORTS TO WORKERS: INSPECTION AND INVESTIGATIONS

10 CFR 20: STANDARDS FOR PROTECTION AGAINST RADIATION

10 CFR 30: RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING OF BYPRODUCT MATERIAL

10 CFR 35: MEDICAL USE OF BYPRODUCT MATERIAL

RSO Handbook [Vincelli..., AIHA 2009]

About the Instructors

Peter Situ, PhD DABR - Radiation Safety Officer

Jeff Goodrich, MS DABR - Associate Radiation Safety Officer

Shaun Caraway, MHP DABSNM - Nuclear Medicine Physicist

0. Your job as a Radiation Safety Officer [P. Situ]

a) What does it take to become a radiation safety officer?

b) Who is required on a radiation safety committee?

c) NUREG-1556, Volume 9, Revision 3 [Guidance on materials licenses]

d) 10 CFR 20- Standards for Protection Against Radiation [Protecting workers and the public]

e) 10 CFR 35- Medical Use of Byproduct Material [Oversight and authorization on medical uses]

WEEK 1-2 Journal Activities: Obtain a copy of your Material's License. Locate all radioactive materials in your facilities: list isotopes and quantities used.

1. Radioactivity & Radionuclides [J. Goodrich]

a) Describe Atomic Structure and Radioactive Decay

b) What are the mechanisms of transformation kinetics?

c) Radioactive Transformations with Safety Notes [see attached information from the video]

WEEK 3 Journal Activity: From the 313A-RSO document, find the section NUREGs designed to guide the licensee. What areas are you already familiar with? What is the meaning of Agreement vs non-Agreement states; which are your license(s)?

WEEK 4 Journal Activity: List the isotopes at your facility(ies) by mode of radioactive decay, including parent/daughter relationships and equilibria. What makes them diagnostic or therapeutic? Calculate the decay in any 24 hrs for your isotopes.

2. Inverse Square Law, ALARA, Time, Distance, Shielding [J. Goodrich]

a) ALARA

b) NRC Occupational Dose Limits

c) ALARA Levels 1 and 2 (Form 5)

d) Time in external radiation protection

e) Distance in external radiation protection

f) Shielding in external radiation protection

Weeks 5-6 Journal Activities: Explain [by calculation] how a doubling of time, distance OR shielding affects exposure to an occupationally exposed worker.

3. History of the Use of Radiation in Medicine [External sources]

a) US Atomic Energy Commission (Seaborg) Radioisotopes in Medicine

b) Why are there "Medical physicists" in hospitals?

c) History and mechanisms of radioactive tracers in; Applications of Radioisotopes in (Nuclear) Medicine

d) Radiotherapy, contrasting external and internal sources

Weeks 7-8 Journal Activities: List all of the sources of ionizing radiation in your hospital- including radiation therapy modalities. What safety guidelines are there for the general public and occupationally exposed workers/

4. Biological Effects of Ionizing Radiation [Radiological Training Services]

a) What potential health risks are there for high levels / acute radiation exposure?

b) What potential health risks are there for low level / chronic / stochastic radiation exposure?

c) Contrast Early Effects and Delayed Effects.

d) What is a "teratogenic effect"?

Weeks 9-10 Journal Activities: With regard to cancer risk, list the risk factors and prevalence for the natural population (regardless of radiation exposure history). Describe the LNT model for Dose Response Curve.

5. Radiation Dose, limits to the general public & occupational limits [Rock the Registry]

a) Define the standards' organizations

b) Define the US regulatory organizations

c) Review the goals of radiation protection standards

d) Discuss various scenarios related to radiation dose limits

Weeks 11-12 Journal Activities: For a given work area/laboratory/clinic- note the layout, shielding, restricted and non-restricted areas and limits associated... Add a drawing/diagram to demonstrate distances and which barriers are shielded.

6. Shielding for NucMed and Diagnostic X-Ray facilities

a) Purpose of shielding

b) Factors to consider in shielding NM or diagnostic

c) Shielding design and goals

d) NCRP, WUT based calculations and Example PET facility Appendix T

Weeks 13-14 Journal Activities: Find the architectural report with shielding calculation for a room at your clinic. Using an ionization chamber meter, perform a survey during routine use. Write your findings.

7. Radiation Emitting Devices: Diagnostic Energies

a) How is the X-Ray tube shielded to protect the patient from out of field dose?

b) How does a diagnostic energy X-Ray tube produce X-Rays?

c) Would an X-Ray tube work if the vacuum seal was broken- allowing room air to enter the tube?

d) How does a diagnostic x-ray tube spectrum (at 140 kVp) look different than Technetium-99m?

Weeks 15-16 Journal Activities: there are two major circuits in a diagnostic energy X-Ray tube. Find diagrams and explain what each of these two circuits does to aid in the production of X-Rays. In addition to radiation safety concerns, what other safety considerations need to be taken [materials, electrical, OSHA etc...]?

8. Megavoltage Accelerators and Irradiators (USC, OpenLearn)

a) What section of regulations would a Cs-137 blood irradiator fall under (10CFR35.xxx)?

b) Relative Biological Effect- what is it a measure of?

c) Electronic MegaVoltage accelerators ARE NOT covered under NRC materials guidance [no by product material], but ARE covered in a radiation safety committee's responsibilities

d) Medical Physicists are routinely involved in accelerators and irradiators.

Weeks 17-18 Journal Activities: Find the Medical Physicist's last annual report for your accelerator or irradiator, as required by state regulations. Review and describe the major topics covered.

9. Safety Culture (the NRC Policy June 2011)

a) NRC Safety Culture Policy the NRC recognizes that it is important for all organizations performing or overseeing regulated activities to establish and maintain a positive safety culture commensurate with the safety and security significance of their activities and the nature and complexity of their organizations and functions.

b) IAEA Radiation Safety Culture Trait Talks

c) Video History of the Nuclear Regulatory Commission

Weeks 19-20 Journal Activities: Identify members of admin team involved with safety. Review hospital's training relevant to the culture of accountability.

10. Radioactive Waste (Spills Management)

a) When a spill happens: NOTIFY, Restrict access, Soak Up excess, protect (Shoe Covers / Gloves), clean, decay in storage. Shield and label as needed

b) NRC Decay-in-Storage

c) Removable contamination check - wipes

d) Radiation Safety Surveys at medical facilities - Daily for unsealed sources. Bioassays may be warranted for those exposed to Iodine products

Weeks 21-22 Journal Activities: Find the facility documentation meeting the NuREG 1556 V9 R3 8.10.5 guidelines for Spill/Contamination Procedures and satisfying 10CFR20.1101. Find the logs for decay in storage. Compare your procedures to Appendix N- noting any changes made.

11. Emergency Planning for Medical Licensees

a) The overall responsibility of handling radiation emergencies is the Radiation Safety Officer

b) Types of Radiation Emergencies:

1) NRC Medical Events (Previously called Misadministration)

2) Spills of Radioactive materials

3) Incidental Releases

4) Vomiting of Radiopharmaceutical

5) Death of Patient with radioactive materials administered

6) Fire at radiation facility

7) Loss / Theft / Natural Disaster involving radioactive materials

c) How to respond to an NRC Medical Event

d) Major spills first responder

Weeks 23-24 Journal Activities: Find the facility's documentation on NRC Medical Events, and compare the document to 10CFR35.3045 (or agreement state equivalent). Review and discuss the NRC Literature How Can I Prepare for a Radiological Emergency?

12. Internal Dose Calculations [P. Situ]

a) What terms are used specifically in internal dosimetry for Radiation Protection?

b) What are the dose units and occupational limits for internal dosimetry?

c) What is the definition of CDE, CEDE, TODE, TEDE, ALI, DAC and DAC-hr?

d) Are there additional sign posting requirements for areas where internal dosimetry may be elevated?

Weeks 25-26 Journal Activities: List common in-vitro and in-vivo bioassay methods. What types does your facility use?

13. Brachytherapy

a) Who can become an Authorized User?

b) What additional radiation safety concerns are there beyond a diagnostic/therapeutic nuclear medicine based license?

c) Who can become an Authorized Medical Physicist?

d) What are the requirements for Authorized Users and Authorized Medical Physicists in the performance of a brachytherapy treatment?

e) Discuss the shielding & planning needed for the brachytherapy suite.

f) Discuss the shielding needs for long term LDR inpatient visits.

g) Describe the process of a patient treatment for HDR.

Weeks 27-28 Journal Activities: Keep documentation of an annual HDR emergency training for the remote afterloader and observe a daily check out. Which members of the team are required at an HDR treatment fraction?

14. Radiation Detection Instruments in Radiation Safety

a) Which instrument is used to determine low level contamination? How frequently should be nuclear medicine departments be surveyed?

b) Which instrument is suitable for measuring radiation exposure rate at high radiation intensities?

c) What is an advantage of using film as your personnel monitoring system?

d) How frequently do your survey meters need to be calibrated?

Weeks 29-30 Journal Activities: Review the personnel monitoring records for the facility, including ALARA I & II actions taken (Form 5). Review all the survey meters, dose calibrators and other required measurement device's calibration dates and review/create a master calendar.

15. NRC Regulations (Medical Licenses) [P. Situ]

a) Interactive map for all 50 states Radiation Control Programs

b) Regulations, Guidance, and Communications of Medical, Industrial, Academic Uses of Nuclear Materials

c) The Written Directive

d) The Radiation Safety Officer Regulatory Road Map

Weeks 31-32 Journal Activities: List the subsection of 10 CFR 35 for all the licensed use at the facility. Find the shielding reports for all departments and review the goals of the calculation in comparison to 10 CFR 19 and 10 CFR 20- citing regulations.

16. Sealed Source and Device Registration [P. Situ]

a) The Sealed Source and Device Toolkit from the NRC

b) Registry entries for the VariSource seed (2000 and 2001)

c) Example entry for Cobalt-57 FL series Flood Sources

Weeks 33-34 Journal Activities: Identify all sealed sources in your facilities and find their Sealed Source registrations with the NRC (or applicable state agency). How does one dispose of a sealed source after its useful lifespan- or in the case of major damage?

17. US FDA, OSHA and DOT regulations [S. Caraway]

a) List the entities concerned with radiation safety and radiation protection besides the NRC

b) According to NCRP Report 160 - how many mREM per year are from medical procedures?

c) Which Chapter of 10CFR are OSHA guidelines found?

Weeks 35-36 Journal Activities: The radiation safety program responds to multiple regulatory guidelines simultaneously. Audit your clinical policies and procedures regarding radiation safety to assure they match current standards.

18. Licensing specifics [ADAMS and NRC]

a) The tool kit for Medical Use

b) Initial application - Follow NUREG 1556, starting in Chapter 8 [includes checklists, will be re-used when required to reapply]

c) Types:

1) The NRC issues specific medical licenses of limited scope to private or group medical practices and to medical institutions.

2) Medical institutions that provide patient care and conduct research programs that use radionuclides for in vitro, animal, and medical procedures may request a specific license of broad scope

d) Reapplication and Amendment follow 10CFR35.12 guidelines

Weeks 37-38 Journal Activities: Find the most recent license amendment/renewal request, and highlight the steps of submission in your journal. Follow through NUREG 1556 V9R3 for topic specific guidance.

19. Increased Controls in Medical Facilities / Transportation

a) NRC Increased Controls were implemented in cases where quantities of radioactive material exceed the minimum values of Table 1 from "Radionuclides of Concern".

b) Medical licensees could see this in Cobalt-60 radiation therapy machines and Cesium-137 irradiators- Therapeutic levels of activity.

c) In 2013- there was an update and replacement- codified as 10CFR37... For licensees considering activities, here is detailed discussion from NRC

Weeks 39-40 Journal Activities: 1) Give the regulatory definitions of Restricted and Unrestricted. With your previous diagrams, pick a department and draw the boundaries. Correlate the shielding design goals. 2) For Category 1 and Category 2 quantities of materials, summarize the physical protection in transit in the journal.

20. Inspection Processes

INSPECTION PROTOCOLS

NM Programs https://www.nrc.gov/docs/ML2206/ML22063A454.pdf

NM Programs with Written Directive https://www.nrc.gov/docs/ML1116/ML111610509.pdf

Brachytherapy Programs https://www.nrc.gov/docs/ML1434/ML14346A208.pdf

Medical Boad Scope Licensees https://www.nrc.gov/docs/ML1116/ML111610518.pdf

Radiation Protection https://www.nrc.gov/docs/ML2201/ML22010A147.pdf

Weeks 41-42 Journal Activities: Find the last NRC inspection report for medical license; review and make sure to look at any follow up. Go through and perform a 'mock' inspection via the appropriate inspection protocol above, noting all findings in your journal.

21. Risk Communication to Occupational Workers and General Public

a) Radiation workers are generally well-trained on the matter of risk associated with ionizing radiation; the general public doesn't have the same frame of reference. LNT models of cancers per 100,000 people are common discussion points.

b) Natural radioisotopes and man-made sources accrue more dose than background- this requires a discussion of risk communication

c) Review this piece from Image Wisely describing CT risks vs benefits to patients

Weeks 43-44 Journal Activities: The EPA Workbook on Risk Communication in Action (2007) cited in the linked text c) gives guidance on clarifying and calming communication. Using the model guidelines, create a script to describe the risk associated with a CT scan or nuclear medicine procedure- highlighting the Table 13 principles.

22. Decommissioning (Lessons from Nuclear Power-NRC)

a) Decommissioning is the removal of sources and decontamination of environment no longer in use (largely by power reactors).

b) Medical sealed sources not decayed for 10 half-lives must be decayed in storage, or transported to a facility where they can be decayed in storage- fees to transport and store sealed radioactive sources are not trivial.

c) Details for recipients of decommissioned sources for Cobalt-60 teletherapy/stereotactic machines and Cesium-137 blood/research irradiators are given here (Sample in 2008 dollars)

Weeks 45-46 Journal Activities: Nuclear power decommissioning can be a decades long commitment. In medical facilities- the radioactivity levels are lower by comparison; from your inventory created in weeks 1-2, list the isotopes and quantities you would have to consider decommissioning. What if your clinic closed and you had to move the sources?

23. EPA Regulations (and radiation)

a) The EPA heads the The National Radon Action Plan (2025)

b) The EPA regulations for safe water and air pollutants mirror those guidelines already presented from Title 10 CFR presented before on limits to the general public

c) Medical Licensees need to assure their holding and control of materials remains below the limits set forth in the EPA's Risk Management Program [mostly chemical materials that would not be exceeded in a community clinic].

d) Several instances of radioactive waste contamination into the environment- and EPA management - are available in the media.

Weeks 47-48 Journal Activities: Being the recipient of negative sensationalism in journalism is an unfortunate part of working as a radiation safety professional. Provide factual resources for yourself and your team on the effects of ionizing radiation-- Get a copy of your hospital/clinic's generic radiation safety training and revise with substantiation of medical benefits.

24. Additional needs for 10CFR35.400, 10CFR35.600 (HDR) in radiation therapy facilities

a) The medical physicist and radiation safety officer work together in the addition of brachytherapy to an established program

b) Machine, instrumentation, source design and isotope selection

c) Site preparation and shielding calculation / verification

d) Acceptance and commissioning

e) Daily, monthly and quarterly checks

Weeks 49-51 Journal Activities: Put together a one-page action list with an Authorized Medical Physicist or qualified Radiation Safety Officer highlighting the additional needs of a sealed source radionuclide therapy program.

25. Summary

With the journal entries, exercises and form 313A-RSO complete, you should be ready to take on the challenge of managing a radiation safety program for Nuclear Medicine and Radiation Oncology medical applications! Take time to compile your journal for submission and prepare to take the comprehensive exam. The questions will be closely related to the lettered items from each 2 week block.

Additional materials not required for NRC training:

Laser Safety (2014),

American Industrial Hygiene Association (AIHA)

"Medical Professionals as RSO" from ACR/AAPM

ORAU Museum of Radiation and Radioactivity

SPECIAL TOPICS: Brachytherapy (Manual and remote afterloading)