Direct Receipt of RAM Policy
The University has a program for the procedures involving the acquisition and receipt of radioactive materials. As a standard practice, the ordering of radioactive materials is approved by EHS. This practice helps ensure that only AUs may obtain RAM and that proper records can be maintained by EHS.
Radioactive Material patient/subject unit doses for Human and Veterinary use may be directly delivered to those facilities due to their short half-lives. Recipients of directly delivered RAM will also have appropriate Department of Transportation (DOT) training and forms to check in the radiopharmaceuticals. Note: RAM for use at the University (i.e. not hospital) are to be delivered directly to EHS unless specifically approved by the RSC.
Not all direct receipt requests will need to be reviewed by the RSC. The policy for direct receipt approval states:
- If an AU has never been approved for direct receipt, regardless of isotope, their request must be presented to the RSC; this request consitutes a major change in the authorization's use of RAM.
- If an AU has been approved previously for direct receipt of any isotope and is requesting to directly receive another isotope which is already on their authorization, the change does not need to be presented to the RSC; this request will be considered a minor change with the highest level review being the RSCR.
- This scenario is only applicable for couriers local to Columbia, MO such as Essential Isotopes, Mid-America Isotopes, STI, etc. because they have a well-established relationship with the University.
- Even though this change is considered minor, at any point during the review process, a reviewer may wish to elevate the level of review to the RSC.
- The RSC has empowered the RSO to evaluate vendors and couriers indepedently of the RSC for their feasibility in directly delivering to locations on campus.
- If an AU is requesting direct receipt of an isotope which is not currently listed on their authorization, then the change is considered major and must be reviewed by the RSC. Per the Authorization Application Policies, all requests for a new isotope are considered major changes to be reviewed by the RSC.
- The RSS will continue to limit direct receipt of isotopes to local or established couriers as previously discussed. If a request involves using FedEx as a courier for direct receipt, the amendment will be considered major and reviewed by the RSC.
- Typically, FedEx cannot be approved as a courier for directly delivering RAM to locations other than EHS facilities. However, exceptions may be necessary and are evaluated for each circumstance. For instance, if the AU knows that a package will be labeled as a Yellow-III, then it may be approved for direct delivery to the AU's lab. EHS does not have the ability to transport Yellow-III packages due to DOT requirements.
- All additional requests that do not fit into the above scenarios will be evaluated on a case by case basis.
The RSS ensures that AUs and their RWs are in compliance with both NRC and DOT regulations for package receipt by:
- Reviewing all shipping and transportation documents during inspections,
- Citing authorizations for violations and ensuring corrective actions are implemented,
- Performing follow-up inspections to evaluate effectiveness of corrective actions, and
- Revoking direct receipt privileges if authorizations continue to receive violations
Approved by the Radiation Safety Committee on December 10, 2020.
Last updated on December 15, 2020.