This question and answer set is provided to help you better understand the requirements for security of radioactive material at the University of Virginia.
Background
Security of radioactive material is a regulatory requirement. The following sections of the Virginia Radiation Protection Regulations pertain to security. These are:
12VAC5-481-840. Security and control of licensed or registered sources of radiation.
- The licensee shall:
- Secure radioactive material from unauthorized removal or access when stored in controlled or unrestricted areas.
- Control and maintain constant surveillance and use devices or administrative procedures to prevent unauthorized use of radioactive material that is in a controlled or unrestricted area and that is not in storage.
Compliance with the regulations
The test for compliance is straightforward: Can someone remove radioactive material from your laboratory without you, or another person in your lab, knowing it? If the answer is yes, then the security in the lab is not satisfactory. EHS will use that test to evaluate the effectiveness of the laboratory’s security plan. It is also the test that will be used when EHS personnel make random security checks of radioactive material-use rooms and areas.
Questions
FAQ 1-13 : What needs to be secured?
1. What forms of radioactive material must be secured?
2. If a room is posted "Caution Radioactive Material," do I have to lock the door even if there is no radioactive material is present in the room?
3. Can an area be locked instead of individual rooms?
4. Can a radioactive material workroom across the hall from where I am working be left open if I am moving back and forth between the rooms?
5. If I am in an office or other room inside my lab, can I leave the main lab unlocked?
6. Can I leave the door to the lab unlocked or open if all radioactive material (including waste) is locked in a cabinet or refrigerator?
7. May I leave the door to my lab open and not under my surveillance if I install an entry alarm system?
8. Does equipment that contains radioactive material (e.g. freezers and LSC) stored in hallways need to be locked?
9. My radioactive material cold room cannot be locked. Can I leave radioactive material in this area unsecured?
10. All my radioactive material is secured properly and I have empty waste containers in the lab. Do I have to lock the room?
11. I have a liquid scintillation counter that has a radioactive sealed source as an integral part of it. Do I have to secure it?
12. Are there activity limits below which security rules do not apply?
13. How can I make changes to my security plan?
FAQ 14-19: Security problems which occur as a result of others
14. What should I do if I notice an unlocked, unoccupied radioactive room or area that is not under my control?
15. How can I ensure that personnel who work in my lab, but do not use radioactive material, do not violate the security requirements?
16. How can I prevent people who do not work in my lab from violating the security rule?
17. A Housekeeping staff member opens my radioactive material-use room after working hours and does not lock it when they leave. What should I do?
18. My lab was broken into during the night. What should I do?
19. I always lock my radioactive material-use rooms. However, renovators came in during the weekend, worked, and left the door open while they were on their lunch break. Am I responsible and how can I prevent this from happening?
FAQ 20: Consequences of failure to secure
20. What are the consequences if I fail to secure a radioactive material room, area or piece of equipment?
Answers
1. What forms of radioactive material must be secured?
- The following radioactive material must be secured at all times. There are no exempt quantities:
- Stock vials and other containers of radioactive material
- Calibration sources in liquid scintillation vials
- Radioactive material contained in waste
- Sealed sources
2. If a room is posted "Caution Radioactive Material," do I have to lock the door even if there is no radioactive material is present in the room?
- A qualified No. However, during a past inspection, an inspector pointed out that this practice could complicate the lab security issue. If use of material is infrequent, and communications are poor, not all individuals working in the lab may be cognizant of all use by other lab members. It is always best to establish a habit of locking a room that is posted for radioactive material use.
3. Can an area be locked instead of individual rooms?
- A qualified Yes. If you have a small suite of rooms with limited access and you are able to secure areas such as hallways, suites, and building sections, the rooms within this area may be left unlocked or open. However, the entrances to the secured perimeter must be locked at all times.
4. Can a radioactive material workroom across the hall from where I am working be left open if I am moving back and forth between the rooms?
- No. Unless you can control and maintain constant surveillance over the lab that contains radioactive material, this is not permitted. The test is whether you can ensure that no unauthorized individual can enter and remove radioactive material without being challenged.
5. If I am in an office or other room inside my lab, can I leave the main lab unlocked?
- No. Unless you can control and maintain constant surveillance over the lab that contains radioactive material, this is not permitted. The test is whether you can ensure that no unauthorized individual can enter and remove radioactive material without being challenged.
6. Can I leave the door to the lab unlocked or open if all radioactive material (including waste) is locked in a cabinet or refrigerator?
7. May I leave the door to my lab open and not under my surveillance if I install an entry alarm system?
- Yes. This is permitted if you can hear the alarm when someone enters the room, and you respond to the alarm by investigating each entry.
8. Does equipment that contains radioactive material (e.g. freezers and LSC) stored in hallways need to be locked?
9. My radioactive material cold room cannot be locked. Can I leave radioactive material in this area unsecured?
- No. The acceptable alternatives are:
- Find a cold room that can be locked. Amend your authorization as required
- Place the radioactive material in a locked cabinet within the cold room
- Have a lock installed on the cold room door
- Prior to installing any lock on any door (cold room, lab door or hallway door) you must contact FP&C to ensure that the lock is an approved type and design. If you install a lock that has not been approved, you will bear the expense of replacing it with a proper type.
10. All my radioactive material is secured properly and I have empty waste containers in the lab. Do I have to lock the room?
11. I have a liquid scintillation counter that has a radioactive sealed source as an integral part of it. Do I have to secure it?
- No. However, the calibration vials and the sample vials must be secured. If you have samples in the LSC, you must either lock the room, lock the unit, or otherwise maintain immediate control while the material is in the counter.
12. Are there activity limits below which security rules do not apply?
13. How can I make changes to my security plan?
- The Security Plan you have filed with EHS must be adhered to at all times. You must submit your change in writing, prior to proceeding with any changes to security practices in your areas.
14. What should I do if I notice an unlocked, unoccupied radioactive room or area that is not under my control?
- Notify EHS. We also suggest that you immediately notify the responsible PI about the room that was found unsecured.
15. How can I ensure that personnel who work in my lab, but do not use radioactive material, do not violate the security requirements?
- The security requirements apply to the material, not the people. Therefore, all personnel in your lab must be trained and cognizant of the security requirements for the material in the lab they are working in.
16. How can I prevent people who do not work in my lab from violating the security rule?
- University employees and students: Although these individuals should have received some level of radiation safety training, you should remind them not to leave your room(s) unsecured.
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- Non-UVA personnel: These individuals most likely have not received training. You must supervise their activities while they are in your lab or instruct them on security requirements. You are responsible for the actions taken by non-UVA personnel while they are in your lab.
17. A Housekeeping staff member opens my radioactive material-use room after working hours and does not lock it when they leave. What should I do?
- Contact EHS when this happens. All Environmental Services and Facilities Management housekeeping personnel should have received a short course in radiation safety. In addition, you should communicate with the housekeeping staff about safety in your labs.
18. My lab was broken into during the night. What should I do?
- Immediately call both the UVA Police and EHS to report the break-in.
19. I always lock my radioactive material-use rooms. However, renovators came in during the weekend, worked, and left the door open while they were on their lunch break. Am I responsible and how can I prevent this from happening?
- Supervision of UVA Facilities Management personnel and outside contractors is the responsibility of UVA Facilities Planning and Construction (FP&C). Their managers have received training regarding the requirements for calling the appropriate EHS group for assistance and approvals prior to working in radioactive material-use rooms. However, do not assume that EHS has been notified about work in your radioactive material-use rooms. If you have advance knowledge of renovations or maintenance work, please call EHS and give us the scheduled times and dates. We will assist FP&C in developing a plan that includes security of your radioactive material-use rooms.
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- If lab personnel will not be present during renovation work, instructions should be given to renovators or maintenance personnel to lock the door whenever workers leave the area.
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- In any case, if you discover that renovators or maintenance personnel have not followed instructions, call EHS so we can contact FP&C and take corrective action.
20. What are the consequences if I fail to secure a radioactive material room, area or piece of equipment?
- This depends on the circumstances and the past security compliance history for the lab. A report must be filed with EHS and further actions will be determined by the Radiation Safety Committee. Willful violation of the UVA radioactive material security program may lead to suspension or revocation of the authorization to use radioactive material.
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