A shared radioactive laboratory is defined as a room in which two or more Principal Investigators (PIs) hold RAM permits and are designated as equal, primary users of the space. In such cases, each PI shares full responsibility for ensuring compliance with the University of Missouri’s Radiation Safety Program (RSP). While sharing a RAM laboratory is generally discouraged, certain situations may require special approval by the Radiation Safety Committee (RSC). For example, some laboratory spaces are designed as open concept facilities that limit the ability to secure RAM in isolated, PI-specific areas. In these cases, a single centralized “hot lab” may serve an entire floor and must be shared by multiple PIs. Shared laboratory spaces present increased risks for compliance violations and conflicts. Therefore, to obtain approval for a shared radioactive laboratory, PIs must meet additional RSP requirements. This special designation does not exempt PIs from compliance with all other aspects of the RSP. Failure to meet the requirements outlined in this policy may result in revocation of the shared space designation.

1. What spaces can be designated as shared radioactive labs?
   1. A shared radioactive lab will be approved if the space can be locked and secured behind a door. Spaces that are completely open concept, especially where doors to the labs are always left open to unrestricted hallways, will not be approved as shared spaces.
   2. The open concept labs described in the previous statement are more suited for designation as a “Transitory Use Only” area.
2. Waste management
   1. Waste must be segregated by PI.
   2. Waste containers must be labeled with the PI’s name and other required information for Hazardous Waste Labels-Radioactive (HWL-Rs).
   3. Shared waste containers are prohibited unless specifically approved by the Radiation Safety Officer (RSO).
3. Surveys
   1. All PIs must perform documented swipes and surveys at their designated frequency and in their designated locations, even if the swipes and surveys overlap with other PIs. Failure of one PI to perform their documented surveys will not impact the compliance of the other PI(s) unless there are extenuating circumstances.
   2. Documented surveys must be performed daily by the PI or their Radiation Workers (RWs) when RAM is in use. If multiple PIs and their RWs use RAM on the same day in the shared space, both PIs are responsible for performing documented surveys independent of each other. This will help ensure that removable contamination is quickly identified.
   3. If a PI in a shared space does not use RAM frequently, they must, at minimum, continue to perform documented surveys and swipes monthly.
   4. If contamination is identified in either restricted or unrestricted areas and the Radiation Safety Staff (RSS) cannot determine who caused the contamination, both PIs will be held accountable.
4. Security and worker access
   1. Unless concrete evidence is provided to identify a root cause tied to a single PI, then all security violations will be the responsibility of all PIs. If retraining is required as a corrective action, all PIs and RWs will participate in the retraining.
   2. All workers entering the lab must be RWs. No Ancillary Workers will be allowed to work in the lab with the exception of Campus Facilities for maintenance or similar instances.
5. Segregation of activities including posting and labeling
   1. Physical or administrative controls such as bench space boundaries, signage, colored tape, etc. must be used to demarcate each PI’s work area. If this is not possible, then signage must be posted to indicate and identify shared spaces.
   2. No RAM may remain in designated shared work zones within a shared lab at the end of the workday unless labeled properly to indicate the PI.
   3. The PI’s name must be on all containers of RAM. Even if a container is ‘exempt’ from labeling per 10 CFR 20, it must still have the PI’s name on the container. Otherwise, it will become the responsibility of both PIs.
   4. Storage of RAM must be segregated within reason. This could mean designated shelves for a PI within a fridge or individual shelves/cabinets that are labeled with the PI’s name.
6. Close-outs – including permit terminations and inactivations
   1. In the event one of the PIs needs to terminate or close-out their portion of the lab space, they are responsible for removing all of their RAM and any contaminated or potentially contaminated equipment/items. They must also submit a pickup request for their RAM waste.
   2. Prior to final approval, all PIs must perform a walk-through of the lab to confirm all items have been resolved. They must then submit a written notification to the RSO and their supervisor(s) confirming this has happened and everyone is in agreement.
   3. If for any reason a PI must leave suddenly and ultimately abandon their responsibilities for a close-out, then the responsibility of coordinating the lab close-out requirement will default to that PI’s supervisor.
7. Administrative
   1. This designation will be indicated in the PI’s special conditions on the RAM permit(s).
   2. All PIs’ supervisor(s) must provide approval before a “shared” lab space can be finalized.
   3. If one PI requests an amendment that will impact the operation of the other PI(s), then the RSO will exercise discretion in notifying the other PI(s) in the shared space as well as the supervisor(s) and implement additional restrictions.
   4. If PIs requesting a shared space are from different departments or have different direct supervisors, then all the direct supervisors must review and approve their respective PI’s use of the shared space. In this scenario, the ultimate responsibility for the shared space will fall onto the direct supervisor that physically oversees the shared space.
8. Inspections/audits and violations
   1. The RSS will perform inspections of the lab space simultaneously for all PIs.
   2. If for any reason the RSS cannot reasonably identify the responsible PI for a violation, then all PIs will receive the violation. In this instance, the supervisor(s) will be made aware of the violations and allow the PIs to resolve the violation internally.
   3. Any violations must have reasonable corrective action responses. If corrective actions are not submitted by the PIs in EHSA per the Radiation Safety Manual requirements, then the issue will be presented to the RSC for further disciplinary action.
   4. Repeat violations or unresolved compliance failures may result in suspension of individual PI access to shared spaces.
9. Responsibilities and conflict resolution
   1. Any conflicts that arise related to compliance with the RSP and the shared laboratory must be resolved internally with the PIs’ supervisor(s).
   2. The RSO and RSS are not meant to be mediators for issues and will defer to the supervisor(s) for this role. If the cause of a violation cannot be strongly tied to a single PI, then all PIs will receive the same violation and will be required to submit corrective actions.
   3. Any violations identified related to shared spaces will be discussed during RSC meetings.
   4. Per the NRC Radioactive Materials License, the RSO is empowered by the RSC and ultimately the Curators of the University of Missouri to authorize the use of RAM in the name of the RSC and restrict or suspend the use and/or possession of RAM whenever a significant deviation from established guidelines and procedures has occurred.
   5. Per the NRC Radioactive Materials License, any issues that cannot be resolved with the supervisor(s) may be brought to the RSC. The RSC may exercise discretion on corrective actions including suspension or termination of RAM use in the shared space.

Approved by the Radiation Safety Committee on July 31, 2025.