Re: Internal Licensing

[fegallag@uci.edu (Frank E. Gallagher, III)]

Sue Dupre wrote, in part:
>I'm interested in hearing about alternatives to this approach.

Our internal licensing program is a bit complex in organization, but is very
user friendly and simple in most cases.  We call our internal license a
Radiation Use Authorization (RUA).

A new faculty member submits an application to the Radiation Safety
Committee (RSC) through the RSO.  Most PI's have one RUA, but we would issue
separate RUA's for human use and nonhuman use, and for radioactive materials
and machines, so a person could have as many as 3 or 4 RUA's, but that would
be rare.  We list authorized chemical forms for each radionuclide and also
issue limits on purchase--per order and throughput per fiscal year.

We have a number of approval categories, based on a hazard calculation
system, but nearly all new RUA's can be approved by two members of the RSC
(usually Chair & RSO).  The RSO (and usually another HP) visits the new
applicant for an orientation meeting  and lab tour of about 90 minutes, then
the application forms are printed and signed.  This can only take a few days
after the meeting if the applicant decides to hand carry the form to get the
signatures of the RSC Chair and Dept. Chair.  The PI can then order rad.
materials.  The application is reviewed by the RSC at its next meeting and
approved, even though not required in 99% of the cases.

RUA's are issued for 2 years or 1 year, based on the hazard calculation (we
have a table of max. quantities for containers and experiments for 2 year
approvals, and only need to do the calculations for those above the table
values.  [An example--doing iodinations with I-125 would be a 1 year
approval].  Prior to expiration, a form is sent to the PI asking if he/she
wishes to renew and it has space for listing changes.  Once we receive the
renewal form back, the RUA is considered to be in "timely renewal". 

An HP then visits the PI to do a review (discussion plus tour/inspection of
the labs). This usually takes 30-60 minutes.  The review is documented and a
revised RUA form is printed.  For 99% of the renewals, only the RSO's
signature is needed, so it can be quickly approved and sent out.  The
renewed RUA is approved by consent at the next RSC meeting, although this is
not required. 

We handle amendments to RUA's very smoothly.  Only an HP's signature is
needed.  The PI can request an amendment by fax, normal mail or e-mail, and
the amendment is sent by e-mail.  The RSO or other HP prints a copy for
signature, which then goes in the file. An e-mail copy goes to Purchasing,
which gets a copy of all RUA's (they actually approve the P.O. and watch the
limits).  A formal copy of the revised RUA is printed, signed by the RSO and
distributed by normal mail a few days later.

Some amendments can be handled by a phone call to the RSO or an HP followed
by e-mail approval--minor changes in limits or chemical forms.  Adding a new
radionuclide or greatly increasing the quantities to a new hazard category
does require a written (e-mail) request.  The PI's really like the quick
response time we can give for changes (one of them even used the word
"fantastic" in her e-mail request to me).

We also use the hazard category to determine how ofter we survey the labs,
although we do throw in a factor based on how often the group uses the stuff
(this takes care of the semi-retired types who really don't do much work and
don't have any staff.

Hope this helps.
    


*******************************************************************
Frank E. Gallagher, III, CHP            
Manager, Radiation Protection           
  and Radiation Safety Officer
Environmental Health & Safety Office    Phone:  (714) 824-6904
University of California                Fax:    (714) 824-8539
Irvine, CA   92717-2725                 E-mail: fegallag@uci.edu
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