Annual Laboratory Radiation Worker Refresher Training 2015
Refresher training for this year is designed to re-emphasize a number of basic laboratory safety regulations that are critical to all laboratories. The Laboratory Radiation Worker Refresher Training for 2015 focuses on issues and developments that were highlighted over the past two years. These include sections on radioactive package check-in and personal protective equipment. Please refer to the Radiation Safety section of the EHS website for all of the forms and manuals you will need for your laboratory. Radioactive waste forms are not available online since they are in duplicate ('carbon copy'). If you are running short of any waste supplies, call 368-2906 or simply note in the margin of the submitted waste form the supplies you need and they will be delivered when waste is picked up.
All Radiation Safety materials are available through our website. Access training records (see if you are due) by going to the web module. Access to other online EHS safety records will follow in the near future.
Radiation Training for Lab Personnel
All employees that work for an authorized user of radioactive materials are required to attend one of two radiation safety trainings. Those who work with radioactive materials are required to complete radiation safety training annually. Those who do not work with radioactive materials are required to complete ancillary radiation safety training annually.
NORM (Naturally Occuring Radioactive Material) Uranyl Compounds
All uranium-containing compounds are picked up and disposed of by Chemical Safety. This includes liquid, dry/solid waste, and uranyl acetate/nitrate in powder form. Fill out the Hazardous Waste Disposal Form and mail or walk it to EHS chemical safety. Bag and tag as you would for dry/solid or liquid waste.
Personal Protective Equipment
In general, the use of PPE is meant to prevent direct skin contamination and minimize the risk of internal contamination. Laboratory coats, gloves, and eye protection are the primary form of PPE recommended to protect you from being contaminated with radioactive material. The authorized user must provide all necessary equipment for workers in each laboratory.
Eye protection is required if there is risk of splash or splatter in the laboratory and where radioactive material is stored and/or handled. Wearing contact lenses is prohibited while working in the laboratory unless non-vented goggles are worn. Where there is danger of splashing or flying particles, safety goggles are the minimum protection required. If extra safety protection is necessary, combine safety goggles with a face shield.
Laboratory coats are required to be worn in all Case laboratories. Laboratory coats should be fastened completely to provide adequate protection. OSHA regulations prohibit employees from taking laboratory coats home to be laundered. Laboratory coats must not be laundered at community laundromats. To facilitate laundering of laboratory clothing, arrangements have been made with Merchants Linen Services for the laundering of laboratory coats. Before using the service, you must contact the Merchants Linen representative for Case to set up an account (216-961-3310). Laboratory coats should be taken to the Merchants Linen drop off area in a clear plastic bag (Service Building dock or the Wolstein Research Building dock). All laboratory coats must be checked for radioactive contamination and decontaminated before they are dropped off. If a laboratory coat cannot be decontaminated, it must be brought to the RSOF for proper handling. DO NOT wear laboratory coats in public areas.
Please consult the glove charts to identify the safest gloves to wear, since one glove material cannot protect you from all chemicals. Remove and change your gloves if they are torn, ripped, or punctured. Contaminated gloves must not be reused. DO NOT wear gloves outside the laboratory.
It is the policy of the Case EHS that all laboratory materials be transported using double containment. The material to be transported must be in a leak-proof container that is then placed in an outer container. The surface of the secondary container must be sufficiently free of radioactive materials to be handled without the use of PPE.
Shorts, open-toed shoes or sandals, shoes with holes (crocs), sleeveless shirts, pants with holes, or other dangling clothing should not be worn while conducting experiments in the laboratory.
FYI - EHS Radioactive Waste Pickup Cart Awareness
You may have noticed our waste cart being pushed about on campus. EHS personnel are careful to protect the campus community while waste is transported from laboratories to our waste facility. Our personnel try to use service elevators when ever possible. When EHS must use public elevators, we will notify elevator users that may enter that there is waste in the cart. If the elevator already has passengers we will more than likely just wait for the next car, unless we are invited into the elevator. We will push the cart without wearing laboratory coats or gloves because waste is doubly contained within the cart, just as any lab samples are when transported.
Lab Practice Emphasis
In response to Radiation Safety Program violations, the RSOF follows a General Enforcement Policy which is approved by the Radiation Safety Committee. Please also review the Violation Enforcement Policy for use of radioactive material at the University.
Radioactive material usage requires strict adherence to OSHA rules and regulations pertaining to eating/drinking in the laboratory. Eating, drinking, chewing gum, applying cosmetics, taking medications, or similar activities in laboratories may result in the accidental ingestion of hazardous materials (chemical, radiological, biological); therefore these activities are strictly prohibited from all Case Western Reserve University laboratory spaces. Such activities are permitted in an area (defined as a room with floor to ceiling walls and a closed door) separated from the laboratory space. A separate section of an open laboratory denoted by a line on the floor and/or signs is not adequate and is not allowed. If a separate area for eating can only be accessed by going through the laboratory, then all food or beverage items must be covered when carried through the laboratory. These requirements help to prevent the ingestion of hazardous materials, which can occur by touching one's mouth with contaminated hands, eating from a container that is contaminated, or eating food that has come into contact with hazardous materials. In addition, food containers must NEVER be discarded in the laboratory trash containers. Further, food containers must not be washed in laboratory sinks. This practice would obviously risk contamination of the containers with laboratory materials.
In order to reduce the likelihood of ingestion of hazardous materials the Occupational Safety and Health Administration (OSHA) and Centers for Disease Control and Prevention (CDC) have incorporated No Food or Drink language into various regulations and safety manuals.
Please note: For additional information and regulatory references, check the Food in the Laboratory on the EHS website.
Inactive vs. Storage Mode
The Radiation Safety Office (RSOF) has a classification of Inactive for laboratories that do not need to possess or use radioactive material in the foreseeable future. If you wish to become inactive the following items must be completed:
- Send a letter of intent to the RSOF. This can be either a fax or an email.
- You will be contacted by the RSOF indicating the steps that must be taken to make your laboratory inactive.
If you wish to reactivate the laboratory for radioactive use, the following steps must be followed:
- Send a letter to the RSOF requesting reactivation. This can be either a fax (216-368-2236) or an email (firstname.lastname@example.org) to the Assistant RSO.
- Send updated room maps with survey locations, as well as an updated protocol.
- Verify that survey meters are within annual calibration.
- Verify that radiation workers, ancillary radiation workers, and the AU were retrained within the past year.
- Obtain required personnel dosimeter for all radiation workers.
- After the steps outlined above have been completed and reviewed by the Radiation Safety Committee, the RSOF will activate your rooms for radioactive material use.
Storage mode is for an Authorized User (AU) who wishes to remain active with or without radioactive material inventory for a period greater than 6 calendar months. Storage mode means that the AU has chosen to maintain their laboratory in immediate readiness for isotope usage, even if they have no active inventory (short lived isotope users). Therefore, survey meters must be kept in calibration, training for all involved personnel must be kept up to date, and protocols need to be reviewed/updated every 5 years. The RSOF will continue surveying the laboratory. The laboratory will no longer need to perform surveys while in storage mode. You can drop the use of dosimetry until use starts again (unless you use equipment that requires it). Turn in your badges to the RSOF with a note to discontinue use.
At 6 month intervals AUs must also send a notification to the RSOF that states:
- No isotope use has occurred in the lab.
- The AU has checked all isotope stocks to ensure that no loss of radioactive material has occurred
If you wish to place your laboratory into this status, send an email to the Assistant RSO (email@example.com) stating that you wish to go into Storage mode. Resumption of isotope use shall not occur until and unless an email requesting active status is sent to the Assistant RSO (firstname.lastname@example.org). Stop by EHS to obtain new badges if you are required to do so by your protocol. The laboratory will then be required to perform contamination surveys as outlined in their protocol.
Laboratories are welcome to go into storage mode if they are sure they will not use radioactive material for 6 months or more. Such laboratories must be thoroughly surveyed by the AU before entering and after leaving storage mode (Pre-storage Mode Survey and Post-storage Mode Survey) regardless of whether there are isotopes in the laboratory. The Post-storage Mode Survey ensures a clean baseline to show no unauthorized RAM use has occured in your posted area.
Security of Radioactive Materials
Security checks by the RSOF are frequently conducted before or after normal working hours and on weekends to ensure that areas where radioactive materials are present are properly secured. Normal working hours are between 8:30 am-5 pm.
All radioactive materials, including stock solutions as well as stock vials, must be secured against unauthorized access. Radioactive waste does not need to be secured but must be kept in a designated waste area of the laboratory and its activity sensibly minimized. Even if you are in another part of the laboratory, the radioactive material must be in your line of sight. If it is not, it is not considered secured. If you have a stock vial on the bench and are leaving your laboratory even for a few minutes and there is no one else present, the laboratory must be locked or the radioactive material must be placed in a locked refrigerator or in a lockbox that is secured inside the refrigerator. Just placing the container in the refrigerator does not provide adequate security. Locking acrylic shielding containers with Container Restrainers are available from Research Products International (800-323-9814). If you have one of these containers, please contact the Radiation Safety Office at 368-2906 to obtain a label for your refrigerator indicating that there is a secure lock-box inside.
If you have a refrigerator labeled for radioactive material that is currently not being used for radioactive material storage, the refrigerator must be locked or decommissioned.
During routine security checks by our staff, it was also noted that some researchers are keeping empty stock vial lead pigs labeled radioactive on their laboratory benches. These pigs are still considered as unsecured radioactive material unless the label has been defaced. The Radiation Safety Office will pick up empty lead pigs for recycling. The laboratory must survey the stock vial pigs and deface the labels prior to disposal. Contact the RSOF to facilitate disposal of lead pigs. It is helpful if the lead liner is removed from the stock vial pigs.
How do I know if it is a major or minor spill and how do I make this determination?
- Isotope emission characteristics
- Radioactive material (RAM) volatility
- Quantity of radioactive material (RAM) involved
- Size of contaminated area
- Potential for spreading contamination
- Potential dose—external and internal
Also a "small spill". A spill that remains contained, that can easily and effectively be cleaned up without assistance from the RSOF, and that does not involve personnel contamination.
What if I determine that it is a minor spill?
- Survey clothing, hands and shoes for potential personnel contamination.
- Notify others in the area of a minor radiological spill.
- Remove contaminated bench paper and/or gloves, and dispose of as radioactive waste.
- Decontaminate the work area and survey to verify all contamination has been removed.
- Document incident, attach decontamination results, and place report in the laboratory's radiation recordkeeping binder for future RSOF compliance reviews.
A spill that involves contamination of personnel or results in contamination outside of the intended work area, and that cannot be promptly cleaned up.
What if I determine that it is a major spill?
- Survey clothing, hands and shoes for potential personnel contamination.
- Notify others in the area of a major radiological spill.
- During business hours (weekdays 8:30 a.m. - 5:00 p.m.) call the RSOF at 368-2906.
- After hours (weekdays 5:00 p.m. - 8:30 a.m., weekends and holidays) call Security at 368-3333 and indicate there is "A Radiation Spill".
- Give Safety or Security your name, the AUs name, location, and telephone number.
- Establish a secure boundary to prevent spreading of contamination.
- Do not leave the area (unless in immediate danger) until initial investigations by Safety have been completed.
Shipping Hazardous Materials
All hazardous material shipping (including radioactive materials) must comply with US DOT regulations. Civil fines of up to $55,500 can be assessed per violation and criminal fines can be assessed of up to $500,000 and 5 years imprisonment. Training from EHS is required and includes general hazard materials shipping guidelines, security awareness, hazard communications, competency exam, and site-specific shipping training (lATA and DOT). Please note that dry ice is a DOT regulated hazardous material. EHS staff is always available to help with shipping problems.
Radioactive Waste Containing Biohazardous Material
Radiation safety does not handle biohazardous material and will not pick up waste in orange and purple bags.
Biohazardous material is anything containing a potential biological pathogen (i.e. virus, bacteria, parasite, fungus, prion or toxin created by a biological organism) which has the ability to infect and cause harm to any plant, animal, human or other biological organism.
If your laboratory will be working with biohazards together/mixed with radioisotopes, please contact the RSOF at 368-2906. When necessary, specific training will be provided on how to handle this type of waste.
In general, investigators generating infectious radioactive waste are required to store this waste in purple bags in their labs until the waste is properly decontaminated or decayed to avoid the possibility of accidental submittal of infectious waste for radioactive disposal.
The waste from a purple bag must be appropriately bio-decontaminated by the lab and disposed as yellow bag radioactive waste OR the waste must be allowed to decay to background and then be disposed as red bag biohazardous waste.
Checking in a Radioactive Package
When a package of radioactive material is received in Shipping and Receiving, the Radiation Safety Office (RSOF) is notified. A dated inspection label is also attached to the package indicating that it was inspected by the RSOF. If this sticker or the Case RAM Package Receipt Form is missing, the RSOF must be informed immediately. If the laboratory orders greater than 1 mCi of radioiodine (125I) or greater than 10 mCi of volatile tritium (3H), a label informing them of bioassay requirements also is attached to the package. Packages are either hand delivered by Shipping and Receiving or approved laboratory personnel may pick up the package at Shipping and Receiving. The packing slip, as well as the Case RAM Package Receipt Form will be attached to the package when it is delivered to the laboratory. If directly picked up from Shipping and Receiving, the laboratory worker must sign for the package and hand-deliver it to their laboratory.
Package Receipt Procedure: RSOF
The RSOF surveys packages at Shipping and Receiving. A specialist from the Radiation Safety Office checks the packages for any surface contamination on the outside of the box, as well as measure dose rates on the packaging surface and at one meter (3.3 feet) from the package. If surface contamination exceeds 220 dpm/100cm2 or exceeds 200 mrem/hour at any point on the external surface of the package, the package will be held by the RSOF and the laboratory will be contacted. The packing slip attached to the package will also be checked to ensure that the correct isotope and activity has been ordered. A complete signature and the time and date that the package was checked are filled in on the packing slip which also must document, the purchase order number, and the date of receipt. The Radiation Safety Office is required to survey the package within 3 hours of receipt in Shipping and Receiving.
Package Receipt Procedure: Lab
The individual receiving the package in the laboratory must complete the package receipt form. The package also MUST be surveyed by the laboratory on the same day that the package is received. Survey includes probe readings, as well as wipe tests of the exterior and interior of the box, and of the inside of the Styrofoam container containing the stock vial. Probe readings are not to be taken when the vial is in the box. If the shipment contains 3H, only a wipe test is performed. A wipe test must also be performed on the outside of the stock vial in order to ensure the vial is not leaking. There is no need to probe the vial. If the vial is leaking, the laboratory should contact the vendor. The activity of wipes must be determined with an appropriate counting device. Wipes from packages containing 22Na, 36Cl, 86Rb, or 32P can be checked using a survey meter. Wipes from packages containing low energy isotopes must be checked using the Liquid Scintillation Counter. Activity must be corrected for efficiency and recorded as dpm/100cm2. Note all survey meter information on the form. Finally, the surveyor must complete the form by signing their complete name, recording the date and time that the package was surveyed, and placing this form in a notebook for future RSOF compliance reviews.
Radioactive Waste Procedure
Radioactive waste generated in a laboratory needs to be separated by isotope and waste type. The exception is for H3 and C14 because they are are long lived isotopes. Isotopes short half lives are decayable and need to be kept separate. Waste types include: Dry/solid (including sharps), liquid, polyacrylamide gels, liquid scintillation vials, beta plate mats and animal carcasses. Wolstein labs can arrange for radioactive animal pick up using regular waste form. All other labs must deliver carcasses to the ARC post mortem room chest freezer and FILL OUT THE LOG. The log has to match what is noted on the bag's waste tag. NO infected animals (biohazard) are allowed in the RAM animal freezer (red/orange or purple bag).
Acknowledgements: The Assistant RSO would like to thank the Radiation Safety Staff for providing the pictures as well as valuable input for this presentation.