Re: Internal Licensing

[partye@rockvax.rockefeller.edu (Esmeralda Party)]

HHMI prepared a document "Consensus Radiation Protection Practices for 
Academic Research Institutions," to address among other points the one on 
authorization procedures.  The goals were to maintain safe practices, meet 
regulatory requirements and streamline the approval process reducing 
paperwork.  The guideline reads as follows:

"Authotization by the RSC for an individual to be responsible for the use of 
radioactive materials depends critically upon the training and experience of 
the individual.  There is no particular requirement or need to impose 
arbitrary limits on the quantity of radioactive materials that  may be 
possessed or ordered at one time, provided the quantity is not inconsistent 
with the nature of the authorized use and does not exceed the institution's 
license limits.  The evaluation of an application to become a Reponsible 
User includes:

1. The types and proposed uses of all radiation sources must be identified 
and reviewed.  This procedure may be initiated by the applicant completing a 
form similar to Attachment A - Radioactive Material Use Application (not 
included here).  In addition, the applicant must agree to abide by all 
policies and procedures for acquisition, use, storage and disposal of 
radioisotopes.  It is the Responsible User's responsibility to notify the 
RSC or RSO about any changes in types or uses of radiation sources.  
Possession limits do not necessarily need to be considered if active systems 
are used to ensure there are appropriate controls and training in the 
laboratory for the radioactive material being purchased.

2. The applicant must be a Qualified User, have the appropriate education, 
training, and practical experience commensurate with the radiation sources 
to be used.  If the applicant does not meet these requirements, the 
Responsible User may, with the approval of the RSC, delegate responsiblity 
for all uses of radiation under the aurthorization to a Qualified User under 
his or her supervision.

3. At some point prior to usage of radioisotopes, the applicant should be 
interviewed in person by the RSO to review the above information and to 
discuss the specific institutional procedures in the radiation safety program."

Anybody interested in the full text of this document can send me a fax 
number to my email address below.

Here at Rockefeller, we have been following the same HHMI philosophy for 
many years.  In our case our unit is the laboratory not the PI, there may be 
several PIs in each lab.  A new lab completes an application which consists 
of a series of forms that describe the research that will be done indicating 
the hazardous materials to be used (biologicals, chemicals and radioactive) 
and the experience of the head of the lab.  The application is reviewed by 
the Laboratory Safety Committe (LSC).  Prior to the LSC review of the 
application, the RSO meets with the lab head to discuss all relevant aspects 
of the work to be done in the lab and determine the radioisotopes and amount 
to be ordered on a regular basis.  The laboratory space and requirements are 
also reviewed by the RSO.   

The radioisotope orders are handled through a computerized system that links 
the inventigator, the Safety group and Purchasing.  Based on the information 
provided by the head of the lab at the time of the application a list of 
radioisotopes and amount per order is created against which the computer 
automatically checks every order placed by an investigator.  If the order 
either exceeds the amount or includes a radioisotope not in the list it is 
left aside in a separate file that the RSO checks daily.  At that point the 
RSO can evaluate the request, find out if this is a one time occurrence or a 
change in laboratory needs and can decide to approve it or not.  If there is 
any question on this change of work, it would be brought to the attention of 
the LSC.

Yearly the RSO reviews the radiosotopes ordered by each laboratory and based 
on that information decides on frequency of checks, dosimeter needs, etc.

This has proven a user-friendly system that allows for quick action to take 
care of researchers needs and good control of materials.

  Esmeralda Party                                                     
  Assistant Director,                                                  
Phone: (212) 327-8324 
  Laboratory Safety & Environmental Health              Fax:    (212) 
327-8340         
  The Rockefeller University                                      
  1230 York Ave                                                      e-mail: 
partye@rockvax.rockefeller.edu
  New York, NY 10021