Roles and Responsibilities of RAM Users

There are various stakeholders in Radiation Safety. Select your role to find out more about what you are required to do:

Remember that all Permitted Individuals (PIs) and Authorized Users (AUs) must also be Radiation Workers (RWs). So be sure to review all the applicable content for your role.

 

MANAGEMENT RESPONSIBILITIES IN RADIATION SAFETY

 

The responsibility for the governance of the University (MU) is vested in the Curators of the University of Missouri. Executive responsibility and authority for administrating the University is assigned to the President. The President delegates responsibilities and authority to conduct operations on and by the University Campuses through the Assistant Vice President for Management Services to the Director of Environmental Health & Safety and to the Radiation Safety Committee (RSC).

 

DELEGATION OF RESPONSIBILITY

Implementation of the policies established by the RSC are the responsibility of the Radiation Safety Officer (RSO), who was appointed by the Director of Environmental Health & Safety. The RSC advises the President through the Provost on all matters relating to the safe use of radiation.

 

RADIATION SAFETY COMMITTEE RESPONSIBILITIES

 

Members of the RSC and its subcommittees, including the chairperson, are appointed by the Office of Research, Innovation, and Impact. The RSC will consist of a representative from university management and persons knowledgeable in the application and uses of radioactive materials. The RSO will be an ex-officio, non-voting member of the RSC. An alternate Chairperson for the RSC may be designated from within the RSC for special purposes upon a proper motion and vote by the RSC. Management refers to individuals who have the authority and necessary resources to achieve regulatory compliance and to administer MU license activities.

Members of the RSC are assigned as RSC Reviewers (RSCRs) to each RAM permit. RSCR responsibilities include reviewing RAM permit and AU applications for technical and safety issues, reporting any concerns or comments to the RSC during review, and approving minor amendments. The RSCR has the authority to elevate the review level of an application if they deem it necessary for the RSC to review the application.

 

DUTIES OF THE RSC
  • Review and approve or deny the uses of radioactive materials by MU personnel.
  • Advise the campus administrators on matters relating to radiation safety.
  • Review the performance of the RSO, the RSP and the RSS to assure maintenance and adequate control of radiation risks.  
  • Oversee an annual program audit and make recommendations to management on continued maintenance of the operational RSP.  This annual program audit will be used to identify areas of noncompliance within the program.  These areas of noncompliance will then be analyzed, corrected and then actions will be instituted to prevent recurrence.
  • Develop and direct implementation by the RSO of the University policies for proper uses of radioactive materials and review all general guidelines and/or procedures issued by the RSO.
  • Create subcommittees within the RSC to approve PI's RAM permits and medical AUs and to generally oversee and review various disciplines.  Such subcommittees could include but are not limited to areas such as medicine and human use, biological and physical science, engineering and veterinary science.
  • Develop safety manuals as necessary to ensure proper program implementation and good health physics practices.
  • Establish methods for maintaining records of the RSC’s proceedings.
  • Review and approve all new requests for ram permits and AUs and requests for significant changes in existing ram permits and AUs.
  • Empower the RSO to issue interim permits, including changes to existing permits, and amendments of a non-signification nature, e.g., minor increases in quantities, use of isotopes in the same or lower toxicity group as currently authorized, and movement to a laboratory of equal or improved design.
  • All interim authorizations issued by the RSO must be reviewed and approved at the next RSC/subcommittee meeting.
  • Review compliance issues with ram permits and oversee corrective action as appropriate.

Find a current list of members on the Radiation Safety Committee page. 

MEETINGS OF THE RSC AND SUBCOMMITTEES

A general quorum shall always include individuals representing the following positions: Chair of the RSC or approved delegate, the RSO or ARSO, at least one member of management, at least one individual knowledgeable in the area of radiation currently being discussed, at least a simple majority of the Committee membership, and any other individuals required by applicable federal regulations. It may be necessary to implement a digital ballot to resolve matters when it is inconvenient to have a meeting. Decisions made via digital ballot shall be discussed and ratified during the next regular meeting. These decisions do not constitute a meeting.

Responsibilities of the subcommittee include:
  • Subcommittees shall be created by the RSC for the purpose of overseeing and reviewing various disciplines within the radiation safety program. A subcommittee shall always include individuals representing the following positions: Subcommittee Chair (who shall be appointed and approved by a simple majority vote of the Subcommittee), RSO or ARSO, at least one person knowledgeable in the area of specialty of the subcommittee, a voting member of the RSC, and any other individuals required by federal regulations or deemed appropriate by the RSC.
  • After a subcommittee reviews and approves an application for use by an individual user, it shall notify the RSC at the next meeting. Such information would include the name of the applicant, a general summary of the applicant’s experience and nature of the proposed use.
  • The RSC shall have power to overrule any or all authority of a subcommittee which reports to the RSC. After the subcommittee report during an RSC meeting, members will review and approve actions taken by the subcommittee.
MEDICAL USE SUBCOMMITTEE

The Medical Use Subcommittee will consist of an Authorized User of each type permitted by the license, the RSO or ARSO, a representative of the nursing service or delegate, and a representative from University management who is neither an AU nor RSO. The RSO will be an ex-officio, non-voting member of the Medical Use Subcommittee. This subcommittee of the RSC is responsible for the radiation safety review of all human use applications within the University and for oversight of MUHC’s radiation program for licensed radioactive materials. This subcommittee functions as the hospital RSC as required by NRC regulation 10 CFR 35. The subcommittee membership, including the Subcommittee Chair, shall be appointed by the Associate Vice Chancellor for Research Compliance and Integrity. A general quorum shall always include individuals representing the following positions: Subcommittee Chair or delegate, the RSO or ARSO, at least one member of management, at least one individual knowledgeable in the area of radiation currently being discussed, a simple majority of the subcommittee membership, and any other individuals required by applicable federal regulations. It may be necessary to implement a digital ballot to resolve matters when it is inconvenient to have a meeting. Decisions made via digital ballot shall be discussed and ratified during the next regular meeting. These decisions do not constitute a meeting.

The duties of the Medical Use Subcommittee consist of three primary functions:
  • Review all applications for radiation safety compliance when materials are used in humans.
  • Serve as RSC for MUHC as defined in 10 CFR 35.
  • Provide consultation to the Institutional Review Board and the Associate Vice Chancellor for Research.
THE PROCEDURES FOR CONDUCT OF BUSINESS FOR ALL SUBCOMMITTEES:
  • The RSC and all subcommittees shall meet as needed to conduct the business of the University.
  • A simple majority shall be used to approve motions for the subcommittees.
  • All Subcommittees should conduct business in the following order:
    • Approval of minutes of the previous meeting
    • Announcements
    • Unfinished Business
    • New Business
  • The RSC should follow the above procedure; however, they shall also have a representative from each subcommittee summarize recent actions and then review subcommittee approved minutes.
  • All items discussed by the RSC and the subcommittees shall be documented.

 

RADIATION SAFETY OFFICER AND ASSOCIATE RSO RESPONSIBILITIES

 

The RSO directs the Radiation Safety Staff, which is part of the Environmental Health & Safety Department. The RSO reports through the Director of EHS. The RSO qualifications shall meet the applicable NRC requirement. Associate Radiation Safety Officers (ARSOs) may be appointed by the Office of Research, Innovation, and Impact. The ARSOs would be responsible for assuring continued compliance with the NRC requirements during short absences of the RSO. The ARSOs would be delegated authority to sign records and reports in the absence of the RSO. The ARSOs would be directly responsible to the RSO.

 

RESPONSIBILITIES AND DUTIES
  • Implement the policies of the RSC.
  • Review all applications for uses of radiation to ensure compatibility with appropriate license conditions.
  • Issue and authorize the use of radioactive materials.
  • Approve and/or coordinate transfer of radioactive material.
  • Restrict or suspend use and/or possession of radioactive materials whenever a significant deviation from established guidelines and procedures has occurred.  Such deviation of use shall include any threat to health or property.
  • Provide liaison to the NRC in negotiations for licenses through the Director of EHS.
  • Provide consultation on radiation safety problems to PIs, AUs, the RSS, and to others having a need for the information.
  • Provide staff assistance to the RSC as required.
  • Design, arrange for the printing, and maintain a supply for distribution of all required forms.
  • Write and publish guidelines and/or procedures for radiation safety.
  • Report incidents, as required to the applicable regulatory agency. Descriptions of these incidents shall be provided to the RSC and to Campus Administration.
  • Regularly inspect laboratory facilities of each PI to use radiation sources by the methods and frequency developed in collaboration with the RSC.
  • Define the procedures for response to emergency situations in order to provide prompt and positive corrective action. These procedures are to be reviewed annually.
  • Supervise all ordering, receipt, survey, monitoring and delivery of all shipments of radioactive material arriving at MU.
  • Conduct and coordinate all training programs of MU personnel in the proper procedures for the use of radioactive material.
  • Supervise and coordinate the radioactive waste disposal program.
  • Oversee the storage of radioactive material, including radioactive waste.
  • Maintain inventory of all radioisotopes.
  • Supervise decontamination and recovery operations.
  • Perform or arrange for leak tests on all sealed sources and calibration of radiation survey instruments.
  • Issue/Monitor dosimetry.
  • Maintain all appropriate records including minutes of all RSC meetings.

 

ADMINISTRATOR RESPONSIBILITIES IN SUPPORT OF THE AUTHORIZED USERS

 

SUPPORT OF PERMITTED INDIVIDUAL AND AUTHORIZED USER

The types of support provided by an Administrator to an AU/PI includes the use of facilities (rooms, labs, equipment, etc.) and the use of the departmental resources such as clerical, purchasing, maintenance, security, etc. The Administrator who directly supervises the AU/PI is actively involved in the permitting process by signing the Authority Page for each application made by the PI. There are situations when an Administrator provides support to a PI who is not supervised by that Administrator, but is allowed use of facilities that the Administrator supervises. In this case, the Administrator shows their support by signing the Authority Page under the “Supervisor Support for Other Areas” (See Application for RAM Permit).During the ram permit application process, administrators review the applications for use of RAM. By signing the application, they demonstrate support of the PI/AU’s training and experience, the proposed use and facilities, and specific procedures. The Administrator also sets expectations and supports the PI/AU’s efforts in performing self-assessment activities, and implementing corrective actions.

 

INSPECTION AND AUDIT FOLLOW UP

RAM permits are periodically inspected. If repeat violations or other significant issues occur, the issue will be discussed by the RSC who will determine corrective actions as necessary. Afterwards, the Administrator may be notified of the issues. The Administrator should follow up with the PI to ensure that actions are being taken to identify the root cause(s) and that corrective actions are initiated to prevent reoccurrence. Administrators should identify any improvement opportunities if necessary.

 
REMOVAL OF APPROVAL

The Administrator may remove partial or total support from the AU. That removal of support should be made in writing to the RSC with copies to the PI/AU and the RSO.

 

PERIODIC REVIEW

The Administrator may request at any time an update on the compliance of any PI they oversee by contacting the RSO.

 

SECURITY

The Administrator is involved in security of radioactive materials by controlling the issuance of keys for restricted areas and by keeping the PI appraised of who has keys issued for their restricted areas. The PI can then implement additional controls if needed and ensure that ancillary training is given to individuals with access to the restricted areas. All individuals with key access to the restricted area are responsible for security of radioactive material within the area or lab.

 

TRAINING AND PERFORMANCE BASED EVALUATIONS

Administrators should communicate to employees, students, visitors and guests that the health, safety, and concern for the environment are top priorities on the MU campus, and that everyone shares the obligation to perform work in a safe, healthful, environmentally protective manner. They also ensure radiation safety obligations are met in the departments or units under their control.

 

MATERIAL CONTROL

By setting expectations for and supporting the PI’s efforts of establishing permit-specific procedures, the administrator ensures that PIs, AUs, and RWs utilize the “As Low As Reasonably Achievable” (ALARA) principles.

 

PERMITTED INDIVIDUAL AND AUTHORIZED USER RESPONSIBILITIES

 

GENERAL REQUIREMENTS

Permitted Individuals are those who have applied and been approved by the RSC for a RAM permit. Once a RAM permit is given, the PI is responsible for following all Radiation Safety Program requirements as well as requirements laid forth in the RAM permit's special conditions. PIs receive period inspections of their laboratory spaces and are responsible for maintaining a safe work environment for all RWs they oversee. PIs are required to renew their RAM permit a maximum of once every three years. During renewal, PIs must provide updated training and experience and demonstrate that they have completed at least two hours of radiation safety equivalent training since their last renewal. Transient employees may not be considered for possessing a RAM permit.

Conversely, Authorized Users are defined in 10 CFR 35 as either a physician, dentist, or podiatrist who meets the regulatory requirements laid forth in 10 CFR 35. AUs are only applicable for medical applications of RAM use and do not have their own RAM permit; they should not be confused with PIs who do hold an approved RAM permit. AUs will be listed in the special conditions of a RAM permit along with each 10 CFR 35 medical use type for which they are approved. AUs who are designated as the Primary AU will be given charge of a RAM permit to "supervise" all operations of their 10 CFR 35 medical use type including supervising RWs and other AUs who are not primarily responsible for the RAM permit. See the Co-Authorized User section for additional information on CO-AUs. Since AUs do not receive a RAM permit, they are not required to submit a renewal every three years; instead, their AU status will be reviewed under the RAM permit(s) for which they are listed on in the special conditions.

PERMITTED INDIVIDUAL REQUIREMENTS

Individuals requesting permission to direct studies utilizing uncontained radioactive materials exceeding the quantities listed in 10 CFR 20 Appendix C must meet the following criteria:

  • A bachelor level college degree or equivalent of training and experience in physical or biological sciences,
  • At least 20 classroom hours of training, or equivalent training and experience in the safe handling of radioactive materials, characteristics of limiting radiation exposure, units of radiation dose and quantities, radiation detection, instrumentation and biological hazards of exposure to radiation.

Refresher training is required periodically. Additional information on training can be found on the Becoming a Radiation Worker page. 

 

Individuals requesting permission to direct studies utilizing sealed sources, contained sources, foils, vendor prepared assay kits, or other uncontained radioactive materials less than the quantities listed in 10 CFR 20 Appendix C must meet the following criteria:

  • An associate level degree or equivalent training and experience in technical, medical, physical, or biological areas,
  • At least 8 hours of training and experience, including 4 hours of formal classroom/laboratory instruction with 4 hours of supervised experience, concerning the understanding of radiation units, radiation detection, regulations, emergency procedures and specific instruction appropriate to the type and form of byproduct materials to be used.

Refresher training is required periodically. Additional information on training can be found on the Becoming a Radiation Worker page. 

 

AUTHORIZED USER REQUIREMENTS

Individuals applying to become an Authorized User must complete the AU Application by submitting all required documentation of training and experience outlined in 10 CFR 35.

Refresher training is required periodically. Additional information on training can be found on the Becoming a Radiation Worker page. 

 

TRAINING AND PERFORMANCE BASED EVALUATION RESPONSIBILITIES

The Permitted Individual/Authorized User shall:

  • Communicate to colleagues, staff, students and visitors that the health, safety, and concern for a safe workplace are top priorities at MU. Everyone shares the obligation to perform work in a safe, healthy, environmentally protective manner.
  • Ensure that radiation safety policies and procedures are communicated to employees, students and visitors appropriate for their situation.
  • Ensure that individuals handling radioactive materials are trained in and understand the proper radiation safety procedures. The PI/AU is responsible for the actions of all workers who handle radioactive materials under the specific RAM permit. 
  • Fulfill training requirements to become a PI/AU, and update training as required to maintain and renew the RAM permit.
  • Review the ram permit with each RW, and define RWs’ specific responsibilities under the ram permit.
  • Determine by performance-based evaluations that RWs can properly perform the permit specific radiation safety procedures.
  • Register each individual who is allowed to work with radioactive material without direct supervision as a RW.
  • Ensure that work requiring training is performed only by persons who have received the proper training i.e. no one can work with radioactivity until they have been trained.
  • Review the corrective actions with RW’s as necessary. 
  • Document all permit-specific training and know where training records are kept.

 

MATERIAL CONTROL

The Permitted Individual/Authorized User shall:

  • Ensure every individual's exposure from radioactive materials and radiation is ALARA.
  • Establish and implement permit-specific procedures to be in compliance with MU Radiation Safety Program. 
  • Ensure that individuals working under the permit have the proper safety equipment and laboratory apparel to perform their work safely. 
  • Develop and periodically review the radiological work procedures to ensure that radiation hazards are controlled or eliminated. The PI may adopt the MU program procedures or adapt other procedures, while ensuring that the other procedures meet the intent of all the requirements of the permit-specific procedures.
  • Verify the following information provided in the semi-annual inventory verification:
    • Any new radioactive material receipts,
    • any transfers,
    • any waste pickups,
    • any changes in RW status,
    • any changes in sealed sources
    • any changes in permit specific instrumentation, and
    • current on-hand inventory.  

 

SELF ASSESSMENT AND CORRECTIVE ACTIONS

The Permitted Individual/Authorized User shall:

  • Ensure that radiation safety responsibilities are being carried out by all individuals working under the ram permit. 
  • Encourage an atmosphere where there is the prompt reporting of health and safety concerns.
  • Curtail or stop work that is being carried out under the permit if continuation of the work is believed to pose an imminent danger to health or safety. Immediately notify RSS when work is curtailed or stopped for this reason. 
  • Establish, review, implement, and document completion of acceptable corrective actions to prevent reoccurrence of radiation events.
  • Perform periodic documented surveys to ensure that routine handling surveys performed by the RW’s are effective. 
  • Review the documented surveys to determine trends and any need for corrective actions (e.g., change in procedure, work area, equipment, personnel training, personnel accountability, shielding, ALARA techniques, etc.). 
  • Review and follow up on inspections performed by the RSS or the NRC, and correct any permit-specific procedures that led to any deficiencies or as necessary.
  • Interact with the assigned RSC Reviewer (RSCR) concerning any suggested changes or corrective actions needed.

To begin the process of becoming a Permitted Individual or an Authorized User, review the content on the RAM Permit Applications page. 

 

CO-AUTHORIZED USERS RESPONSIBILITIES

 

A Co-Authorized User is an Authorized User who is not primarily in charge of a specific use type at MU. The Co-AU will work underneath the Primary AU and be listed in the special conditions of the RAM permit overseen by the Primary AU. Co-AUs may also be referred to as Secondary Co-AUs. These individuals must have the support of the Primary AU and the Primary AU's Administrator to be listed on a RAM permit. The Primary AU may request removal of Secondary Co-AUs from the RAM permit by submitting this request in writing to the RSS. A Co-AU does not have to be authorized for all use types on a RAM permit; they can be approved for individual 10 CFR 35 medical use types under the RAM permit. Co-AUs must still meet the regulatory requirements to become an AU and must submit an AU application. All inventories for a specific use type will be maintained under the RAM permit for which the Primary AU is responsible. Co-AUs are still responsible for overseeing any procedures for which they are authorized and can provide "supervision" to RWs where supervision is defined in 10 CFR 35.27.

 

RADIATION WORKER RESPONSIBILITIES

 

TRAINING AND PERFORMANCE-BASED EVALUATIONS
  • Participate in radiation safety training appropriate for your work situation. 
  • Learn about potential hazards of radiation and radioactive material associated with your work and work area; know where information on the radioactive material is kept for your review; and use this information when needed. 
  • Seek help from the PI or the RSS if you are unable to fulfill your responsibilities due to lack of training or understanding.
  • Understand and follow permit-specific procedures and established ALARA levels. 
  • Learn safe operating and emergency procedures appropriate for the work being performed. 
  • Follow procedures and observe precautions for the use of radioactive materials, as detailed in the approved authorization and in the Radiation Safety Manual. 
  • Periodically update radiation safety training based on the worker function through MU EHS.
  • Attend formal training through the MU Radiation Safety Training Program prior to being registered as a RW. 

 

MATERIAL CONTROL
  • Ensure exposure to all individuals from radioactive materials and radiation is As Low As Reasonably Achievable (ALARA). 
  • Use engineering controls (e.g., fume hoods, shielding, etc.) and personal protective equipment appropriate for the work being performed. 
  • Maintain security of radioactive materials from access by unauthorized individuals.
  • Ensure inventory and related records are maintained appropriately.
  • Survey yourself each time before you leave your work area or touch areas not allowed to be contaminated. 
  • Survey yourself and surrounding areas after you finish working with radioactive material. 
  • Return stock to proper storage and record activity (or volume and activity conversion) removed. 
  • Record estimated activities (or volume and activity conversion) going to samples, liquid waste, and solid waste to document location of radioactive material at any time. 
  • Be able to determine activity in stock, samples, liquid waste, and solid waste at any time (this is necessary when waste is prepared for pickup). 

 

ASSESSMENT AND CORRECTION
  • Notify other authorized personnel of unusual circumstances.  
  • Stop work if you reasonably believe continuation of the work poses an imminent danger to the health and safety of the lab personnel or public, and immediately notify your supervising RW or PI.
  • Report all unsafe conditions to the supervising RW, PI, Administrator, RSS, RSC, or the NRC.
  • Participate in the required Review and Assessment and the Corrective Action Program as established in the permit-specific procedures and implement corrective actions to prevent reoccurrence.
  • Document any contamination found upon surveying, actions taken, and final dose rates or levels of contamination following the decontamination efforts. 
  • Alert, notify or warn co-workers about defective equipment and radiation hazards. 
  • Periodically review corrective actions and ensure implementation.

To become a Radiation Worker, review the content on the Becoming a Radiation Worker page. 

 

ANCILLARY WORKER RESPONSIBILITIES

 

ACCESS AND SECURITY

Ancillary Workers (AWs) have access to radioactive materials or radioactive work areas, but are not allowed to handle radioactive materials except under the direct supervision of a RW.

They are responsible for ensuring security of radioactive materials from unauthorized access or removal. This means

  • If someone unfamiliar enters the restricted area containing radioactive materials, ask them to identify themselves and not let them have access to the material. 
  • If an individual comes in to do work in a restricted area, direct them to the PI, AU, or RW responsible for the area, or be completely briefed by the PI, AU, or RW as to what the individual is allowed to do and not to do. 
  • If someone is delivering radioactive materials, they are not allowed to accept the material. They must find the PI, AU, or a RW to accept the delivered radioactive material.
  • If AWs are the last person to leave the restricted area, then they are responsible for locking the area. 
  • AWs are responsible for reporting any unusual circumstance with regard to work place safety to the PI, AU, or RW responsible for the restricted area. 

 

TRAINING AND PERFORMANCE-BASED EVALUATIONS

AWs must receive training to understand the specific requirements for the particular restricted areas to which they have access. This training may be provided by the PI, AU, or RW.

MU’s Campus Facilities (custodians, maintenance, construction, energy management, etc.) receive ancillary training from the RSS or from the University of Missouri Research Reactor (MURR). Hospital Support Staff (housekeeping, plant engineering, etc.) receive ancillary training from the RSS. All these individuals are encouraged to discuss specific requirements with the people responsible for any restricted areas that they must enter.

Seek instruction from the authorized personnel in understanding responsibilities for access to restricted areas.

Be acquainted with and understand responsibilities toward providing colleagues, staff, students, and visitors with a safe work environment. 

 

MATERIAL CONTROL

Observe related signs, posters, warning signals and directions. Assist in maintaining security and control of radioactive materials when you have access to restricted areas that contain them. 

 

ASSESSMENT AND CORRECTION

Notify authorized personnel of any unusual circumstances observed regarding work place safety. 

 

Steps to become an Ancillary Worker can be found on the Radiation Ancillary Workers page. 

 

Page last updated on December 14, 2023.