Radioactive Materials - Compliance and Monitoring Activities
In order to ensure the University is in compliance with all CNSC requirements the ORM has been mandated to establish and monitor the Radiation Safety Program. ORM reports their findings to the Radiations Safety Committee and those individual directly involved. In recognition of the primary role of the principal investigator to conduct research, ORM has designed its monitoring activities to minimize the number of interruptions into the research (and academic) laboratory. To limit these intrusions, ORM uses a variety of tools to assess compliance which include: program element review, documentation review, inspections, and investigations.
Program Element Review
To ensure that each program elements meets a specific goal without becoming a unnecessary burden to the research community; each element is assessed in terms of regulatory requirements, effectiveness, efficiency, necessity and burden on all parties. Program elements include issues such as permits, inventory, security, dosimetry, training, transportation, waste etc. This review may engage an assessment of the faculty/department support, as well as other services involved.
Documentation Review
By reviewing the completeness and accuracy of records sent to ORM, trends and possible oversights can be detected. The adherence of the ALARA principle can be assessed by reviewing dosimetry records. Inventory and disposal records are used not only to address laboratory performance, but to ensure CNSC licence conditions are adhered to. As well this documentation is used in the preparations of the annual report which is subsequently submitted to CNSC.
Inspections
Inspections are a tool where by a picture of a laboratories performance can be assessed. The way the radiations safety program is implemented in a lab may vary; some labs identifying specific individuals who are delegated the task to monitor and ensure compliance, others labs the responsibility is shared. Each system has strengths and weakness, which must be assessed. It also must be recognized that one visit to a lab may not accurately reflect the performance of the lab. For this reason the University has adopted a performance rating scale. This system is used to assess performance over time (file review) and a specific inspection, and is both objective and subjective in nature. The sole purpose is to identify labs having the greatest difficulty reaching and maintaining a state of compliance, and provide the necessary support to help then identify root causes and the necessary remedial action. One influencing factor is the performance rating system used by CNSC. Hence the rating scale (low, medium or high risk) addresses the risk of action by CNSC. It is important to note that High risk labs are brought to the attention of the Dean.
• In-house Inspection Check List
Investigations
Periodically there is a need to investigate a specific incident be it a spill, dose, etc.; these opportunities are also used to address the root causes and other influencing factors. As a result laboratory performance may be examined in greater detail or even a full radiation safety program element i.e., training.