Policy on Storing RAM and Inactivated RAM Permits

Long-term storage by a radioactive materials (RAM) permit holder (i.e. storage, but non-use of radioactive materials for 24 months or longer) can have serious implications for compliance with decommissioning timeliness rules when no active user remains in the building. In order to limit compliance liability, long-term storage is not permitted. Furthermore, to comply with training frequency rules, inactive status of a RAM permit seven or more years from the initial inactive date is not permitted unless all required training and experience is maintained.

• RAM permit holders are required to notify EHS in writing (including via email) when they plan to place stock material in long-term storage.
• After 24 months, RAM in storage must be diposed properly through EHS waste streams, transferred to another RAM permit holder, or used in experiments.
• RAM permit holders with no RAM in use or storage must apply for inactive status.
• Renewal as inactive will be allowed for seven years past the initial inactivation date or date of most recent completion of all required training (including experience documentation), whichever is newer.
• Permits no longer eligible for inactive status will be terminated.
• If there are no major changes to the authorization, requests to reactivate while in inactive status only require administrative review. If there are major changes to the authorization and reactivation is desired during the seven year window, review and approval of the application by the Radiation Safety Committee (RSC) is required.
• Compliance with training and experience frequency rules includes completing radiation safety refresher training every three years at a minimum. EHS will not send notifications for delinquent training. If the training frequency has lapsed during the inactivation period, the user must complete Introduction to Radiation Safety Part 1 and Part 2 prior to reactivation. You may register for Part 2 by logging into our database EHS Assistant. 
• If the Authorized User chooses to renew his/her authorization at the end of the seven year period of inactivation, a complete renewal application will be required. The completion of training and experience will be verified by MU EHS staff, and the RSC will review the renewal application. The RSC will consider whether or not the protocols are still current when ocmpared against standard practice.
• Requests to reactivate terminated permits require a new application including RSC approval.

Instructions to either inactivate or reactivate your authorization may be found on the AU Applications page.

Approved by the Radiation Safety Committee on August 16, 2018

Page last updated on November 1, 2019.