[N.B. This training enforcement policy is independent of the "Radiation Safety Program Enforcement Policy".]
(This policy became effective on November 8, 2000 on which date it was approved by the Radiation Safety Committee. It will not be retroactive in terms of previously identified training delinquencies.)
Purpose
Our license agreement with the Ohio Department of Health requires initial and annual refresher training for all personnel working with radioactive material.
Since the new policy of continual, year-to-year Internet retraining has been implemented, fulfilling the retraining requirement is reduced to an exceedingly small effort by any staff member having access to the Internet.
Applicability
There are four categories of personnel for whom training is required. The categories of Ancillary Radiation Laboratory Worker and Non-Rad Lab Worker were recently added to relax the training burden. These categories are defined below
Authorized Users (AUs) Radworkers Ancillary Radiation Laboratory Workers. Non-Rad Lab Workers
Authorized Users (AUs) - Research personnel who have explicitly received authorization from the Radiation Safety Committee to use radioactive material. These personnel must initially train by attending the new lab worker rad safety class before ordering radioactive material, and retrain by attending a radworker retraining classroom session or by using the rad worker retraining material on the Internet
Radworkers — Personnel who work directly with radioactive material and who are listed as radworkers under an Authorized User. These personnel must initially train by attending the new lab worker rad safety class before starting work in the laboratory, and retrain by attending a radworker retraining classroom session or by using the rad worker retraining material on the Internet
Ancillary Radiation Laboratory Workers - Personnel listed under an Authorized User and who work in RAM laboratories but have only minor, incidental contact with radioactive material, such as dish washers.
Initial training can be the three hour initial radworker training, Right-to-Know training, or initial ancillary worker training. The initial training must be completed and verified by a record or statement of completion in the possession of the RSOF within 30 days of beginning work. Annual retraining is required.
These personnel are subject to the same retraining requirements as Radworkers. Retraining will be tracked in Helix and the workers designated as "A-R", (Ancillary — Required) in the Helix database.
Non-Rad Lab Workers — Personnel who though listed as workers under an Authorized User but who have no direct contact with radioactive material. These personnel will not be tracked in Helix and as a minimal training requirement must take the Right-to-Know training within 30 days of starting work, which will be tracked on the Safety Services database. No retraining is required.
Authorized User's, Radworker’s and Ancillary Radiation Laboratory Worker’s training compliance will fall under the "Authorized User and Rad Labworker Training Enforcement Policy" and will directly affect the Authorized User.
It is the responsibility of the Authorized User to inform the RSOF of the category of each person working in their laboratory by written memo or e-mail, and to update this list when changes occur.
Pre-notification Every worker will be informed of the expiration of his or her training and the consequences of expiration at least 30 days before expiration occurs. AUs will also be informed simultaneously of the impending training expiration and training policy enforcement resulting from this delinquency for any of their laboratory workers. Policy AUs will be responsible for assuring that the training of their Radworkers and Ancillary Radiation Laboratory Workers is not delinquent. Actions at 30 days overdue If AU’s training is 30 days delinquent: Written notice to the AU, to their department chair and department administrator Isotope ordering privileges suspended until resolved If an AU’s Radworker’s or Ancillary Radiation Laboratory Worker’s training is 30 days delinquent: Written notice to the worker and AU Worker not permitted to work with RAM Isotope ordering privileges of the AU suspended until resolved Actions at 60 days overdue will be taken in the following order: If AU Written notice sent to AU AU’s department chair and department administrator informed of action to be taken RSC chair notified to hold an executive Radiation Safety Committee (RSC) meeting to approve securing or removal of radioactive material from the AU’s laboratory If Radworker or Ancillary Radiation Laboratory Worker Written notice including explanation of training policy enforcement to worker and AU AU’s department chair and department administrator informed of action to be taken RSC chair notified to hold an executive Radiation Safety Committee (RSC) meeting to approve securing or removal of radioactive material from the AU’s laboratory Appeal Process
