Outline –

The Australian National University comes under the Australian Radiation and Protection and Nuclear Safety Act and associated regulations.  These are administered by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA, http://www.arpansa.gov.au/Regulation/index.cfm ).  The ANU is licensed (S0027, 9 August 2002, F0074, 14 April 2003) to conduct various ionizing and non-ionizing radiation dealings.  In addition, some ACT laws apply (eg. for the disposal of radioactive material).

This document is an evolving collection of guidelines and procedures, aimed at ensuring the ANU achieves and maintains best practice with all its radiation endeavours and associated compliance with the ARPANSA regulations and licence conditions.  These guidelines summarise processes associated with all forms of radiation – ionizing (isotopes and machine generated) and non-ionizing, including lasers, radiofrequencies, microwaves, ultraviolet light, visible light and infrared.

Where no ANU guideline or procedure exists, those of the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), National Health and Medical Research Council (NHMRC), National Occupational Health and Safety Commission (NOHSC), Standards Australia (SA) or the International Atomic Energy Agency (IAEA) may be applied.

Contents

ANU Radiation Safety Policy

The Australian National University policy on the Radiation Safety should be read in conjunction with the ANU Occupational Health and Safety Policy and ANU OHS Management Plan.  These documents provide an overview, objectives and direction statements for health and safety at the University.
This document aims to provide practical guidance on fulfilling the objectives of the policies.

Supervisors – what you need to know

As supervisors and research leaders, there are various expectations and responsibilities placed upon you.  As a supervisor, you should –

 Conduct research and dealings that are justified, that is, they must produce a net benefit to the individual or the community, taking into account social, economic and other relevant factors.

 Comply with society’s laws and regulations , through

 Documenting the proposed work/research

 Complying with the ANU ‘new work’ approval process

 Conducting a risk assessment as part of the ANU hazard management process.  Where significant risks are identified, these should be acted upon to reduce those risks to an acceptable level.

 Ensuring an individual’s exposures are kept below relevant exposure limits and to the lowest level that can be achieved consistent with best practice.  

 Providing appropriate training and supervision to staff and students

 Providing appropriate resources (work area, safety devices, personal protective equipment etc.)

 Communicating with and involving your Radiation/Laser Safety Officer.

 Being aware of personnel issues.

‘New Work’ Approval Process

It is an ANU requirement that no new work is undertaken without a risk assessment being conducted.  In a radiation context, all radiation work should be considered and assessed.  This may occur at one of three levels –

1. In-house Assessment - A new experiment involving radiation that is already documented in the Budget Unit inventory.

Action – Conduct a risk assessment as per the ANU Guidelines and document.  It is encouraged to conduct and document the process as described below.  The risk assessments for ionizing radiation can be found at Risk Control Protocol for Ionizing Radiation, while those for lasers and non-ionizing radiation are best covered in the application process.

You need not formally submit this documentation.  However, approval from your RSOs is generally required and encouraged.  The designated work group OHS Committee may wish to be informed. The risk assessment document should form the basis of the safe work practices and be attached to it.

2. Radiation Safety Committee Assessment - New work includes: possession, use of a material, use or operation of an apparatus, or disposal of material or an apparatus that is not currently undertaken.  Thus the following proposals by a Budget Unit would constitute new work that would need to be reviewed by the Radiation Safety Committee:

• A new radiation-producing apparatus,
• A new sealed source,
• A new unsealed source not currently listed in the inventory,
• An unsealed source of a radioisotope that exceeds the cumulative activity for that radioisotope shown on the inventory,
• An unsealed source of a radioisotope of different physical form (i.e. solid, liquid, gas) than shown on the inventory for that radioisotope,
• An unsealed source of a radioisotope to be used in a different application or use than that shown on the inventory for that radioisotope.
• Disposal of radiation apparatus (for ARPANSA approval)
• Some other scenarios as determined by the OHS Unit or RSOs.

Please discuss your proposal with your RSO/LSO or the OHS Unit to determine which approval process category is appropriate for the proposed work.

Action – Complete the application details below.  A specialist sub-committee of the ANU Radiation safety Committee assesses individual applications, with feedback provided as soon as possible.

3. ARPANSA approval - A new radiation dealing, which involves radiation apparatus or materials not currently listed on the Budget Unit inventory (ARPANSA Workbook).  Disposal of radiation apparatus also falls in this category.  These dealings would need to complete the same application as new work (2), with the possible additional stage of official notification to, and approval from ARPANSA.

Action – Complete the application details below.  A specialist sub-committee of the ANU Radiation Safety Committee assesses individual applications, with feedback provided as soon as possible.  ARPANSA approval may however take time .

Application - The application should include the cover page of general information, and a relevant radiation category form.  The forms are –

• New Work Radiation Application cover page (must be completed for all applications) (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Radiation_Application_New_Work.rtf)
• Ionizing radiation apparatus application form (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Ionizing_Radiation_Apparatus_Application.rtf )
• Ionizing radiation isotope application form (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Ionizing_Radiation_Isotope_Application.rtf )
• Laser application form (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Laser_Application.rtf )
• Non-ionizing radiation equipment application form http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Non_Ionizing_Radiation_Equip_Application.rtf )

Please complete the relevant application forms and forward to your Coordinating Radiation Safety Officer (http://info.anu.edu.au/hr/OHS/OHS_Networks/Radiation_Safety_Officers.asp ). Copies from approval process 2 or 3 should be forwarded to the OHS Unit (Roy.Schmid@anu.edu.au). Electronic copies are acceptable. Your application will be treated quickly.

Safety and Hazard Management

A hazard is the physical entity with innate properties of an agent or process that has the potential capacity of causing harm or adverse effect on the health of people.  Workplace accidents and occupational diseases are caused by definable and identifiable hazards in the workplace.  Under the umbrella of ‘radiation’ we have both ionizing radiation (alpha, beta, gamma, x-rays, neutrons) and non-ionizing radiation (infrared, visible, ultraviolet light, microwaves, radiofrequency waves, static magnetic fields) that have various hazards.  It is however the risk that these radiations pose to us that we should concentrate on.  The risk is the likelihood that the hazard will cause harm, through injury or disease.  The level of risk to health increases with the severity of the hazard and the duration and frequency of exposure to the hazard.  The risk can be evaluated by the appropriate exposure measurements.

Risk management process -

The need for systematic management of OHS hazards and their attendant risks applies to all organisations and all activities and function within an organisation.

The process or procedure should be constrained by restrictions on the doses to individuals (dose constraints), or the risks to individuals in the case of potential exposures (risk constraints), so as to limit the inequity likely to result from the inherent economic and social judgements – Optimisation of protection.  Since risk can never be totally eliminated when working with hazardous processes and materials, the aim is to reduce the risk as far as is reasonably practicable and acceptable . 

Risk management is a four stage process:

1. Identify the hazard,

Hazard identification is covered in detail in the ANU Safety courses.

2. Assess the risk associated with the hazard,

The risk assessment process is covered in the ANU Safety courses.  In addition, consider information in the new work approval process, and risk control protocols.  Both Actual and Potential exposures need to be assessed.

3. Control the risk, and

This involves providing appropriate measures to reduce identified risks to an acceptable level.  The plan for control of exposure to radiation in the workplace is based on a hierarchy of controls, including:

• avoidance of exposure, where practicable;
• isolation of sources of radiation, where practicable, through shielding, containment and remote handling techniques;
• engineering controls to reduce radiation levels and intakes of radioactive materials in the workplace;
• adoption of safe work practices, including work methods that make use of time, distance and shielding to minimize exposure; and
• where other means of controlling exposure are not practicable or not sufficient, the use of approved personal protective equipment.

Other measures should be used when appropriate, including:

• the designation of controlled areas;
• the use of appropriate signs and labels; and
• the use of investigation levels of exposure for specific categories of work.

In general OHS situations, risk reduction can be achieved by a combination of the ‘hierarchy of controls’ - Elimination, substitution, segregation (distance), process control (by using pellet material or solution rather than powder, master batching, pre-packaging, power level reduction etc.), automation, enclosure/isolation (shielding) of the process, exhaust ventilation, timely equipment maintenance for optimal performance, restriction of exposure (by limiting/controlling the number of employees, time, hours worked, loads, rest periods, job rotation, overtime etc.), safe work practices, education and involvement of the workers, work environment (Control of temperature, humidity, noise, air movement, etc.), supervision, personal protective equipment (safety glasses etc.).

4. Review the process

Regular reviews of protocols, procedures, and equipment will encourage safe thinking, as well as being a requirement of the regulations.  In addition, new processes and techniques may have become available and should be considered. In the event of an accident or incident (or near miss) the conclusions and improvements should be incorporated into the protocols.

Education is a major aspect of achieving appropriate risk management.  The relevant ANU safety training courses and associated notes are an integral part of the risk management process and ARPANSA required documentation.

Accident/Incident notification -

In the event of an accident or incident (hazard or near miss) involving radiation, these should be reported as soon as possible using the ANU incident notification system.  This includes injuries from exposure to ionizing radiation, ultraviolet light, intense visible, infrared radiation, radiofrequency fields, static magnetic fields, laser beams and ionizing radiation.

In addition, whole body ionizing radiation doses (reports) of greater than –

1000 microSieverts/year
250 microSieverts/reporting quarter
80 microSieverts/month

for an individual should be reported using the notification system.  The average ANU radiation worker ionizing whole body dose is 22 microSv/year for beta and 22 microSv/year for gamma/x-ray [reference: OHS Unit Summary report].  Hence these reporting levels are considered excessive ANU exposures.

New radiation laboratory design details -

Details on the design requirements for new (wet chemistry) radiation laboratories are available from the OHS Unit.

The design and construction of laboratories housing radiation apparatus should ensure that any radiation measured externally to the laboratory is below the appropriate public exposure limits.

Existing laboratory compliance with Australian Standards -

Compliance with the current Australian Standards on laboratory safety can be assessed by using the check lists -

Ionizing radiations (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Ionizing_Radiation_Audit_Form.rtf)
Non-ionizing radiations  (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Non_Ionizing_Radiation_Audit_Form.rtf)
Lasers  (http://info.anu.edu.au/hr/OHS/_Procedure_Attachments/Lasers_Audit_Form.rtf )

The forms should be completed by -

• Italic  text circled,
• boxes filled in with -
  • ticks ( ) for applicable/present/correct/ etc, or
  • crosses (X) for non-compliance, or
  • dashes ('-') for not applicable.

Deficiencies should be discussed with the RSO and Budget Unit management.  In the event of a dispute, the OHS unit should be contacted.

Radiation stores -

Storage containers for beta emitting isotopes should reduce bremsstrahlung radiation.  The storage location/cupboard for radioactive material should have the following attributes –

The location should be secure and restricted to authorised personnel only.  See the section on security and the associated audit security checklist.
 Be restricted to radioactive material only.
 A register (for waste stores) or manifest (for radiation stores) should be kept and readily accessible by authorised staff.
 A person should be made responsible for the housekeeping associated with the store.
  Packages should be stored in an appropriate manner to –

• Prevent physical damage
• Reduce effects of the chemical properties
• Reduce radiation exposure on the outside of the package to below 1000 microSv/hr (approximately packing group III).
• Contain any spill or leak
• Segregated from incompatible materials, heat sources, food stuffs etc.

  Containers should be

• Strong
• Durable
• Made of compatible material
• Kept closed
• Labelled clearly and correctly

  The store should have

• Sufficient lighting to easily read labels etc. (240 lx)
• Good natural or mechanical ventilation
• Emergency contact details (names and phone numbers) displayed.

  The average and maximum radiation dose rates should be determined for the

• Central area within the store
• Outside the entrance
• Any major path or public area next to the store,
  and recorded by the RSO.

Transport of radioactive material within buildings -

Transportation of radioactive material may occur between –

• Radiation store to laboratory
• Laboratory to laboratory
• Laboratory to radiation store
• Laboratory to waste store

It is important to ensure that the material is –

• Labelled with a radiation trefoil and substance/material identification,
• Well contained (at least a primary and secondary level of containment), and
• Shielded to reduce exposure to an acceptable level (generally less than 10 microSv/hr or < 500 counts per second).

Additional information can be found in the ANU Hazardous Waste Disposal Procedures.

Transport of radioactive material outside of buildings -

The transport of radioactive material and radiation producing apparatus around the ANU Campus should only occur between licensed Budget Units and with the consent of the Radiation Safety Officers. 

Modifications of the ARPANSA workbook and Licence schedules may be required.

Transport of material and apparatus on public roads around the ANU, should consider the requirements given above (transport around buildings) and those in Radiation Protection Series 2 – Code of Practice for the Safe Transport of Radioactive Material (2001) (http://www.arpansa.gov.au/Regulation/index.cfm ). 

The RPS 2 Code of Practice is intended to apply to the transport of radioactive material by road, rail, and waterways under the jurisdiction of States and Territories in Australia.  The transport of radioactive material by air is covered by the Civil Aviation Act 1988 and IATA requirements.  Materials to be transported (off campus or) by air must be packaged and documented by an IATA certified person.

Packaging requirements for radioactive materials is available from the OHS Unit.

Relocation of radioactive devices and materials -

The relocation of controlled radioactive material and controlled radiation producing apparatus will fall into one of three categories -

•   Relocation within the ANU
•   Relocation to another Commonwealth agency (Transfer)
•   Relocation to a non-Commonwealth agency (Disposal)

Relocation within the ANU - This may only occur between areas of the ANU that are licenced by ARPANSA, and with the approval of the Radiation Safety Officer in both the areas involved. This type of movement of controlled items does not require notification to ARPANSA, but must be indicated on the relevant source inventory workbooks and the subsequent ARPANSA quarterly report.

Relocation to another Commonwealth agency - Under the ARPANS Regulations (Regulation 53), relocation of controlled items to another licenced Commonwealth agency is called a “transfer”. ARPANSA must be informed of a transfer of controlled material or controlled apparatus within 7 days, via the completion of a Transfer Notice.

Relocation to a non-Commonwealth agency – The ARPANS Regulations (Regulation 53) define this as “disposal”. Disposal includes the relocation of controlled items to outside of the Commonwealth, the decommissioning and discarding of controlled apparatus, and the disposal of laboratory wastes containing or contaminated with controlled material. Before disposal can occur, written approval must be obtained from the CEO of ARPANSA via the completion of a Request For Approval To Dispose Of Controlled Apparatus Or Controlled Material form.

The disposal of radioactive laboratory wastes that is in accordance with the relevant Radiation Disposal Permit issued by the ACT Radiation Safety Section has already been approved, and does not require written approval for every individual disposal that occurs.

ARPANSA’s Transfer Notice and Request For Approval To Dispose Of Controlled Apparatus Or Controlled Material forms are to be to signed by the relevant ANU Radiation Controlled Person.

Personnel Issues

Age -

No persons under the age of 16 years are to be subjected to occupational exposure to radiation.

No person under the age of 18 years is permitted to work in a hazardous or restricted area (radiation controlled area) unless supervised, and then only for the purpose of training.  Also see the ANU Procedures for Control of access to Hazardous and Restricted Locations.

Qualifications / Training / Competency -

Operational activities, which may affect safety, are only carried out under the control of suitably qualified, experienced and authorised personnel, and according to approved written protocols.

In general, the minimum training, qualifications, and experience required are –

A list of ANU (Safety) Courses is available.

Exceptions - to these rules may be granted by application to the ANU Radiation Safety Committee.  External courses/ other institutional courses may be recognised as a substitute for the ANU safety courses by agreement with your local Budget Unit Radiation Safety Officer / OHS Unit or ANU Radiation Safety Committee.

Re-training – Personnel relying solely on the ANU safety courses should consider re-training every 5 years.  All personnel should re-visit the ANU radiation web sites on a regular (at least 6 monthly) basis, or upon notification of changes/additions to its information.

Female Personnel and Pregnancy -

The new work application process and associated risk assessment should indicate and provide appropriate measures to reduce all occupational exposures to a safe level.  However, in some instances additional risks to an embryo, foetus or through lactation may be present.  It is for these reasons that female members should notify their supervisor (or radiation safety officer or Occupational Health and Safety Unit) as soon as a pregnancy is suspected, or an infant is receiving breast milk.  Information on the associated risks to the embryo or foetus, or to an infant ingesting radioactive substances in the breast milk, can then be discussed.

Supervisors and managers of the Budget Unit should make every reasonable effort to provide suitable alternative employment in circumstances where it has been determined that the person, for health reasons, may no longer continue in employment involving occupational exposure to radiation.

Medical conditions and implants -

Where a person has a medical condition or medical implant that may be affected by exposure associated with the radiation work (eg a heart pace maker in a magnetic field), these should be discussed with the supervisor, Radiation Safety Officer or Occupational Health and Safety Unit. 

Supervisors and managers of the Budget Unit should make every reasonable effort to provide suitable alternative employment in circumstances where it has been determined that the person, for health reasons, may no longer continue in employment involving occupational exposure.

Contract Researchers / Visiting Fellows / Summer students and other short-term workers -

Contract researchers, visiting fellows, summer students and other short-term workers (and other non-ANU employed workers) participating on ANU projects or working in ANU buildings or on ANU grounds, are to have an ANU Supervisor responsible for their work.  The type of work, conditions and approval must be documented (see form) before the work can commence.

It is an expectation that these external people will meet (or exceed) all the appropriate ANU requirements.

These people need to be made aware of –
  Their roles in continuing best practice and maintaining a safe and healthy workplace,
  Their responsibilities in conducting their work and how that may impact on ANU operations, safety, and the environment.
  ANU and local Budget Unit requirements for conducting work with radiation.
  ANU personnel issues regarding age, pregnancy and medical implants.

They should also be introduced to the local RSO and discuss their work with them.

Persons working in a radiation area must undergo the induction section related to radiation safety.  When their stay at ANU is expected to exceed 10 business days, they should undergo the full local Budget Unit Induction process.  When the duration of stay exceeds 4 months, a training requirement similar to that for ANU staff should be offered.

Contract workers may enter a formal safety agreement with their employing group.

Trade Contractors, Maintenance Personnel, and Workshop Staff

Tradesmen, workshop and maintenance staff (including equipment technicians) must abide by the ANU control of access to hazardous and restricted locations policy (http://info.anu.edu.au/Policies/_DHR/Procedures/Hazardous_and_Restricted_Locations.asp).  They must seek prior approval from the laboratory/area supervisor, or in their absence, the Radiation Safety Officer.  Approval should be requested at least 1 day before access is required.

Facilities and Services Supervisors of trade contractors must ensure that access and the type of work undertaken is gained well in advance of the work.  In the event of an emergency situation requiring urgent access, staff in the laboratory/research group must be consultant and approval gained. 

These requirements are also applicable to after-hours access.

ANU staff visiting External Organisations

When ANU staff are to be involved in radiation work in external organisations, the type of radiation work should be documented and approved by their ANU Supervisor and relevant Radiation Safety Officer.  The external contractor form can be used for this situation.

Consideration needs to be given to which organisation provides the radiation monitoring and how these results will be combined with their ANU dose results.  Many external organisations (eg ANSTO) issue visitors a radiation badge for their duration.

ANU Staff are expected to comply with an external organisations induction/training requirement.

Radiation Monitoring

All staff, students and visitors should be provided with information relating to their exposure.

The following relevant types of radiation monitoring should be conducted –

Personal - whole body

Personal – extremities

Emergency action levels

Area

Contamination monitoring

Leak testing of sealed sources

Monitoring an individual’s radiation exposure –

Previous employment –

The RSO, Supervisor, or monitoring agency may request that an individual provide previous radiation exposure reports (eg. a cumulative radiation dose report, accident reports, retinal scans etc.) as appropriate.

Previous employment ionizing radiation doses should be assessed against the maximum allowed dose limits (see Radiation Protection Series Number 1, schedule A).  Where a person’s dose approaches or exceeds these limits, radiation work should be strictly monitored and reviewed to ensure compliance with the limits.

During employment at ANU –

Appropriate radiation exposure monitoring must be undertaken for all staff conducting ionizing radiation work.  It is the responsibility of staff to ensure that they wear the relevant radiation dosimeter during radiation work.  An individual’s records of dose must be available on request.

An individual should be notified (by the RSO) of any unusual ionizing radiation doses received.  In addition, whole body ionizing radiation dose results of greater than 1000 microSv/year, 250 microSv/reporting quarter, or 80 microSv/month should be reported using the notification system.

The type and details for monitoring personnel is available.  Clarification of these issues is available from your Budget Unit RSO, Coordinating RSO or the OHS Unit.

Radiation monitoring badges / dosimeters should be regularly checked for contamination and regularly maintained and cleaned as per the manufacturers guidelines. The ARPANSA TLD badge holders (not the actual envelope) may be cleaned with a suitable detergent. This should be done at least annually.

On completion of employment at ANU –

Staff are entitled to a report of radiation dose and a copy of their incident/accident reports, on request.

Emergency action –

In the event of an emergency situation, exposures should be kept to a minimum, via evacuation.

In the event that emergency response is required to control the situation and personal exposures are likely to exceed the allowed dose limits, these responses should only be undertaken following the guidelines of the International Atomic Energy Agency or ARPANSA, the ACT Radiation Safety Section and/or local Budget Unit management processes.

Doses to radiation received due to an accident or incident should be recorded and treated separately to a person’s normal dose.

Area/Zone/Equipment –

It is important to ensure that radiation is contained within a vessel, zone, laboratory or within the equipment.  As such the regular monitoring for leaks, contamination and personal exposures must be conducted.

The type and details of area/equipment monitoring is available.

Environmental monitoring –

The release of radioactive material into the environment is strictly regulated and controlled.  Consult the ANU Procedure for the Disposal of Hazardous Waste and disposal section.

Radon, a naturally occurring radioactive gas that originates from rock and concrete, permeates into buildings.  When the ventilation is poor, radon levels may increase.  The ANU OHS Unit conducts radon monitoring of buildings.  The radon concentrations to date have not been a concern in the majority of buildings and areas on campus.

Various environment monitoring details are available.

Sealed Sources –

Sealed ionizing radiation sources/material should (where practicable) be leak tested using a method from ISO 9978 or similar.  A copy is available from the OHS Unit.

Records Management

The following documents are the minimum that should be held by each relevant –

Budget Unit –

• ARPANSA – ANU Licence Conditions Handbook, containing –
  • ANU Source (and facility) Licence and relevant Schedule
  • Organisational Licence Conditions - ANU
  • Standard Licence Conditions
  • ARPANSA Expectations Guideline
  • RPS 1 – Recommendations for limiting exposure to ionizing radiation (March 2002) Update documentation as required .
• Radiation Safety Officer contact details
• ACT Radiation Council – Waste Disposal Permits
• Minutes of DWG OHS Committee meetings

Radiation Safety Officer -

• A copy of the ARPANSA Inventory Workbook (held by the coordinating Radiation Safety Officer)
• ANU radiation safety course documentation
• Applications for new conduct / dealings
• Safety assessments, reviews and approvals
• Personal radiation dose records -
  • ARPANSA Personal Radiation Monitoring Service records
    • TLD badge whole body
    • Extremities results, or
  • Other exposure monitoring results. eg. QFE (quartz fibre electroscope) results, or electronic dosimeter results, together with the appropriate dose calculation methods.

Records of ionizing radiation doses that have been received by a radiation worker, including details of monitoring results and dose calculation methods, are to be kept during the working lifetime of the person and afterwards for not less that 30 years after the last dose assessment and at least until the person reaches or would have reached the age of 75 years.  When records can no longer be retained, the records should be forwarded to ARPANSA .

• • OHS Unit exposure assessment reports
• Area monitoring results (contamination checks of equipment etc)
• Radiation Store dose rates

Radiation User Group -

• Documentation for new work / dealings
• Safe operating procedures/protocols
• Radiation apparatus and laboratory design specifications for new or refurbished installations
• Waste disposal guidelines, based on Budget Unit procedures and ACT Radiation Council Disposal Permit.
• Calibration certificates
• Source certificates
• Seal source leak testing methods and results
• Area monitoring results (contamination checks of equipment etc)
• OHS Unit exposure assessment reports

Human Resources Section or Personal File -

• Training and qualifications obtained
• Relevant radiation experience
• Medical records –
  • Eye/Optical examination for persons using class 3B or 4 lasers.
  • Accident/Injury/hazard/near miss reports
  • Accident related medical tests/reports
• A copy of the final radiation dose report upon leaving the University
• A copy of relevant radiation incident reports / investigation results.

OHS Unit -

• Training attendance records (ANU course details only)
• Minutes of committee meetings
• OHS Unit exposure assessment reports
• (Centralised) Environmental monitoring results (eg. radon).
• Incident/Accident reports and resultant investigation reports

An individual’s exposure report should be available to them on request.

Records shall be made available for inspection by the appropriate authority.

When records can no longer be retained, the records should be forwarded to ARPANSA.

SECURITY ARRANGEMENTS

Access
All radiation areas are considered hazardous locations under the ANU procedures for the control of access to hazardous and restricted locations. Access to a radiation area should be restricted to authorised persons. An authorised person is a person who is authorised to deal with the radioactive source(s) or radiation apparatus(es) by management of the area.

Other persons requiring access to a radiation area (e.g. tradespersons) should be accompanied by an authorised person, ideally the Radiation Safety Officer.

Emergency services personnel may access a radiation area in an emergency situation without authorisation. Radiological and other hazards should be communicated to emergency services personnel by the relevant radiation safety officer and/or facilities manager.

Basic security requirements
An initial security inspection of a radiation area should be conducted to ensure that the area meets the security requirements set out in AS2243.4—Safety in laboratories, Part 4: Ionizing radiations. Regular audits of the area should address any security concerns.

Radioactive sources
When not in use, a radioactive source should be stored in an appropriate storage location that meets the requirements set out in AS2243.4—Safety in laboratories, Part 4: Ionizing radiations.

Radiation apparatus
When not in use, a radiation apparatus should be secured against unauthorised access and operation.

Lasers
A key switch should be used as an administrative control for Class 4 lasers to secure against unauthorised operation.

Additional security requirements for sealed radioactive sources
Additional security requirements are to be implemented by persons dealing with a sealed radioactive source in order to decrease the likelihood of the unauthorised access to or acquisition of the source by persons with malicious intent. These requirements are set out in the Code of Practice for the Security of Radioactive Sources.

The responsible Dean or Director, through relevant supervisors and managers shall ensure the security of sealed radioactive sources under their control.  Each responsible person shall ensure that each sealed radioactive source, or aggregation of sealed radioactive sources, is assigned a security category based on the methodology described in the Code of Practice for the Security of Radioactive Sources. Each responsible person shall also ensure that the security requirements to be implemented for a sealed radioactive source, or aggregation of sealed radioactive sources, are commensurate with the security category of the source(s) and in compliance with the Code of Practice for the Security of Radioactive Sources.  The OHS Branch may be consulted on security requirements and compliance with the Code of Practice for the Security of Radioactive Sources.
           

Ionizing Radiation stores –

Radioactive material should be stored separately.  Storage areas (cupboards, rooms etc) used solely for the purpose of storing radioactive material are considered radiation stores.

Access to radiation stores should be restricted to –

• The Radiation Safety Officer, and
• Research leader or designated staff of the research group (eg. Head Technical Officer).
• A central radiation store (eg. radiation waste store) should have limited access (via a registered key system). 
• Students must not have access to the radiation store without written authorisation from the Research Group Leader and Radiation Safety Officer.

Radiation stores must be kept locked (or otherwise secured) when not being accessed.

A store security checklist is available.

Laser Systems -

Research group leaders should encourage the use of the key switch as an administrative control of class 4 lasers and their associated experiments.

Disposal of Radioactive Waste

It is an expectation under the ANU Hazardous Waste Disposal Procedures that every effort will be made to minimise the generation of hazardous and radioactive waste.  Where radioactive waste is to be generated, the disposal of any residual material, contaminated equipment, consumables or other items, and waste products, shall be considered at the design stage of the experiment.  A protocol or waste disposal route must be available (and approved) before the work can commence. 

You must notify your RSO of disposal amounts approaching the allowed limit, or levels above average disposal amounts.  Report any unusual events that may lead to excessive waste generation.

The disposal of radioactive waste in the Commonwealth authorities is controlled under the Australian Radiation Protection and Nuclear Safety Act 1998 and Regulations and administered by ARPANSA – the Australian Radiation Protection and Nuclear Safety Agency. Regulation 48 requires that dealings with the disposal of radioisotopes are in accordance with:

• National Health and Medical Research Council,  Code of practice for the disposal of radioactive wastes by the user.    NHMRC, Canberra, 1985.
• National Health and Medical Research Council,  Code of practice for the near-surface disposal of radioactive waste in Australia.    NHMRC, Canberra, 1992.
• Where disposal involves the release to the environment (sewage, burial etc) an ACT Radiation Council Disposal Permit must be current for the Budget Unit.

Radioactive waste can only be disposed of under the terms of these disposal requirements and of any restrictions imposed. Methods of disposal in compliance with the above Codes must be strictly adhered to and new radioactive experiments requiring different disposal methods or larger quantities of radioactive material must not be attempted without prior approval from the ANU Radiation Safety Committee and ARPANSA.

Disposal routes -

The hazard from radioactive material may be greatly reduced by the strategies of:

• Concentrate and contain,
• Store and decay,
• Dilute and disperse, and
• Return to manufacturer/supplier for reprocessing.

The details are provided in the ANU Hazardous Waste Disposal Procedures.  Contact your Budget Unit Radiation Safety Officer or Hazardous Waste Safety Officer.

Emergency Procedures

The following section contains information that should be considered in developing radiological procedures or emergency plans for Budget Unit responses.

Radiological Incidents

A radiological incident with ionizing radiation may be defined as an unexpected deviation from normal conditions leading to an actual, potential, abnormal situation which causes irradiation or contamination of persons or contamination of the working environment.  For example –

• Suspected exposure to a person greater than the action level indicated in the personal monitoring section.
• Radioactive contamination on a person or clothing exceeding 50 Derived Working Limits (DWL) (see Australian Standard AS2243.4-1998, appendix C).
• An intake of radioactive substances greater than 1/5 of the relevant Annual Limit on Intake (ALI) (Inhalation).
• A spillage of an unsealed radioactive substance in excess of 20 ALI (inhalation).
• A fire or explosion damaging the room (or its contents) in which radioactive substances are used or stored.
• Loss of, or damage to, a sealed source or its container, or loss of more than 200 ALI(inhalation) of an unsealed radioactive source.

Action plan

Any serious injury to a person shall be treated immediately,
 taking care to minimize the spread of contamination.

Emergency treatment for serious or life-threatening injury shall take priority
over treatment for contamination.

Accidents and Incidents must be reported using the University’s accident and incidence reporting system.

The following documents may assist in the development of local guidelines for dealing with emergency situations –

Additional assistance may be required from the RSO (or other Budget Unit RSOs), ANU Security, University Maintenance staff, Emergency Services personnel, and ACTEWAGL staff in dealing with the emergency.

Radiological Incidents - Specific Details

Fire and explosions

Inform senior officers of the fire brigade of radioactive and radiation hazards and the risk to their fire fighters as soon as possible.

Fire fighting shall take precedence over contamination control

BUT all reasonable efforts shall be made to minimize the spread of contamination, particularly at the clean up stage.

After extinguishing a fire - Fire Fighters shall remain at the site until monitored for radioactive contamination.  Decontamination may be required on site.

Emergency Equipment

An emergency response kit should be available within each Budget Unit.  The kit should contain

• Personal Protective Equipment suitable for the variety of tasks undertaken or may be required in the event of an emergency
• Items for the decontamination of persons
• A spill containment kit and materials
• A radiation contamination monitor
• Access to a radiation dose rate meter

Spillages –

Spillages of radioactive material that present minimal hazard to personnel, the Chemical spill management procedures should be followed with additional precautions to reduce exposure and prevent the spread of contamination. 

Personal contamination –

Persons who might have had an accidental intake of radioactive material shall be referred to the RSO as soon as possible for consideration for medical monitoring.  Where necessary, they should also be referred to a medically qualified person with knowledge of appropriate procedures to reduce the effect of, or assist elimination of, internal radioactive contamination.  Assistance on this matter is available through the RSO, OHS Unit, ACT Radiation Health Section and the Canberra Hospital.

Body decontamination, carry out decontamination as follows:

EYES - 

Irrigate eyes with saline solution (1 % common salt solution).

HANDS - 

Wash hands with soap and water, scrubbing lightly with a soft nail brush; if this does not remove the contamination repeat using a detergent.  If necessary use other decontaminants OR

Immerse hands in a saturated solution of potassium permanganate, allow to dry and remove the resultant stain with 5 percent sodium metabisulfite solution. OR

If the above treatment does not remove contamination from the hands have the person wear cotton gloves, covered by tight fitting rubber gloves, for several hours to promote perspiration of the hands and assist removal of the contamination.

SKIN - 

Rub skin, other than that on hands, with a cotton wool pad soaked in a complexing agent.  NOTE: Cetavlon has been found to be a suitable complexing agent.

MOUTH - 

Wash out the mouth several times with hydrogen peroxide solution (one tablespoon of 10 volume solution in a tumbler (approximately 300 mL) of water).

WOUNDS - 

Wash contaminated wounds under running water and encourage bleeding.  If the wound is on the face take care not to contaminate the eyes, nostrils or mouth.  Continue personal decontamination until monitoring shows that contamination has been reduced to an acceptable level.

WARNING: Do not continue if there is a risk that the contamination could enter the bloodstream through an abrasion or break in the skin.

All possible attempts shall be made to estimate the radiation dose received and to provide guidance for any necessary subsequent medical treatment.

The irradiated person should be counselled and, as appropriate, be referred for medical observation and management.

Floods

Should a flood occur in a radiation laboratory, or radioactive storage area, the Radiation Storage Flood Procedures should be implemented to minimise the consequences for people and the environment.

Radiation Detector Efficiency Testing

The Australian National University has a range of radiation monitors and detectors that contribute to the overall risk management strategy associated with ionizing radiation work that is undertaken on campus.  This equipment can be divided into three groups; radiation monitors, standard radiation detectors, and special radiation detectors.

To provide user confidence and assurance that the equipment is performing as expected, the following guidelines are recommended.

Radiation Monitor calibration

Radiation monitors are those devices that measure radiation in terms of an exposure assessment.  That is, they are dose rate meters.  They may read microSv/hr, mREM/hr etc.

These monitors should be calibrated by an accredited or approved calibration service annually.  Efficiency checks should be conducted on a regular basis and recorded in a logbook.

Calibration can be undertaken by -

• Australian Radiation Protection and Nuclear Safety Association (ARPANSA)
• Australian Radiation Services, Mitcham, VIC
• Neomedix Systems, Warriewood, NSW (agents for Mini-monitors)
• GammaSonics, Five Dock, NSW
• others

Radiation Detector efficiency / performance checks

Radiation detectors are those devices that simply measure count rate.  For example counts per second.

These detectors should have their efficiency and performance checked every year, and a simple detector test upon every use.  The simple detector test is to ensure that the probe is capable of detecting the radiation being used.  Radiation detectors should be calibrated by an accredited or approved calibration service at least once every five years.

An annual efficiency and performance check involves determining the detector's response to relevant radioactive sources.

A pure beta sources (eg. 90Sr/90Y)
A gamma source (eg. 137Cs/137Ba).

The two beta sources (of different activity levels) are used to check the linearity of the detector.

Special Radiation detectors

The special radiation detectors may be those associated with low energy x-ray detection or neutrons.

These detectors should be calibrated or their efficiency checked annually or at least every two years.  Simple checks and / or detector operation should be conducted regularly.

Identification -

All radiation monitors and detectors must be identified by -

Identification number*
Make
Model
(Probe model)
Serial Number (and/or year of manufacture)
Date of test/check*
Pass (Failed detectors shall be repaired/serviced and calibrated, or replaced)
Initials of person testing*
* these details are to placed on the label.

All radiation detectors shall be entered into a central database along with their efficiency / performance check test results (maintained by the OHS Unit).  Those detectors with a larger than normal variation from the average reading (for that type of detector probe) shall be labelled as ‘failed’ until repaired/checked and calibrated by an approved external service.

Procedure –

The radiation efficiency testing sources are available for short-term loan from the OHS Unit (Roy Schmid, x54485) by relevant Radiation Safety Officers.  The ANU radiation safety officer should be aware of the general ionizing radiation safety protocols are given in 'The Australian National University - Ionizing Radiation Safety' manual and the 'Risk control protocol for the use of ionizing radiation at the ANU'.

1. Enter the equipment's details in the appropriate form or compare the Identification number details with those on the instrument.

2. Visually inspect the detector for cleanliness, damage and wear.  If damaged, have the detector serviced by a qualified repairer.  If present, remove any protective film (added by the user) from the probe.

3. Switch on the detector and confirm that the battery is OK.

4. Uncover one radioactive source

5. Place the detector probe on top of the source to best obtain a maximum reading.  Allow at least 20 seconds for the probe to respond, taking note of the upper and lower count rates.  Record the average or median count rate in the appropriate column on the form.  Reject the detector if the count rate is too unstable.

6. Cover/return the radioactive source.

7. Compare the reading/results with those of similar detectors.  Fail detectors which have a discrepancy in results greater than 40 %.

8. Repeat step 4-6 with the other two radioactive sources.

Radiation detectors that fail the efficiency comparison test should be labelled, removed from service, and checked by a qualified person/organisation and repaired or replaced as appropriate.

Laser User Eye Sight Testing

It is a requirement that all new staff involved with class 3 B or 4 lasers undergo an eye examination before commencing work with the laser.  This provides a baseline condition of the eyes.  The test is repeated after any accident or suspected exposure.  It is not envisaged to conduct eye examinations at completion of employment, but these can be considered by the Laser Safety Officer.

An extract of the OHS Unit memorandum (available in the laser safety notes) is given below -

EYESIGHT TESTING FOR LASER OPERATORS/TECHNICIANS

It is a recommendation of the Australian Standard on Laser Safety (AS 2211.1:1997) and the ANU Radiation Safety Committee, that workers who have a risk of exposure to laser radiation have an eye examination before commencing employment as a laser worker.  This may also include technicians who repair or calibrate a (powered) laser.  The purpose of the eye examination is to obtain a baseline, for comparison in the advent of an accident.

Could you please ensure that such an examination forms an integral part of the induction procedure for new laser workers.  The examination should be arranged through the Departmental Administrator.  The test is preformed by ophthalmologists and involves an examination, report and retinal photo.  A requesting letter may be required.  The appointment takes approximately 1 hour.  The person should be chauffeured (to and) from the ophthalmologist because of impaired vision.

The cost would be expected to be paid by the Budget Unit, not the Department or the worker.  A copy of the test report and photos should be requested to be included in the employee’s file.

Ultraviolet Light - Precautions

Ultraviolet light sources at the ANU consist of -

• Hand-held UV light sources, used for detecting bands on TLC plates, electrophoresis gels, etc.
• Larger UV sources, (transilluminators and fixed UV light sources), used when photographing electrophoresis gels, curing UV glues, etc.
• UV sterilising tubes in biological safety cabinets.
• Small UV sources in spectrophotometers, microscopes and alike.
• UV accompanying other processes, such as plasmas, arcs, welding, electrical discharges etc.

Note: UV lasers are not considered in this document.

Ultraviolet light is a hazard to the eyes and skin.  Over exposure to the cornea and conjunctiva causes keratoconjunctivitis (welder's flash or snow blindness), while cataracts may be produced from high UV-B radiant exposure.  Erythema is the main observed effect of overexposure to the skin, but chronic exposure accelerates skin aging and increases the risk of skin cancer.  Sunlight is the major source of UV exposure.  The exposure time to sunlight that produces the ARPANSA daily occupational dose limit to exposed skin is quite short [Canberra, 11 minutes (summer), 33 minutes (winter)].  Outdoor workers follow approved public health sunlight abatement procedures for this reason.

In order to meet ARPANSA requirements for control, it is envisaged to formally implement the following procedures -

Laboratories and rooms containing ultraviolet sources should have a sign at the entrance. A sign is available.

Hand-held UV light sources -

1. Affix an appropriate warning sign to the unit.  This would include -

• A readily identified "UV Source" symbol.
• The principal wavelength or UV range (UV-A, B, C) of the source.
• The exposure limit of the source.  ie. the allowed exposure time when measured at a certain distance.  A suitable distance would be 0.2 m from the filter plate or glass tube (as appropriate).
• The date of measurement
• The recommended minimum personal protective equipment required.

2. Document procedures for its use, to be displayed near the equipment. (if not already attached to equipment)

3. Provide relevant information to group training sessions.

Larger UV sources. eg. Transilluminators

1. Affix an appropriate warning sign to the unit.  This would include -

• A readily identified "UV Source" symbol.
• The principal wavelength of the source.
• The exposure limit of the source.  ie. the allowed exposure time when measured at a certain distance.  A suitable distance would be 0.2 m from the filter plate or glass tube (as appropriate).
• The date of measurement
• The recommended minimum personal protective equipment required.

2. Document procedures for its use, to be displayed near the equipment.

3. Provide relevant information via group training sessions.

4. A program requiring the phasing in (over a 2 year period) of protective enclosures with appropriate interlocks, where practical.

Biological safety cabinets

1. Affix an appropriate warning sign to the cabinet.  This would include -

• A readily identified "UV Source" symbol.
• The principal wavelength of the source.
• The exposure limit of the source.  ie. the allowed exposure time when measured at a certain distance.  A suitable distance would be at the opening of the cabinet, and centre of the work area.
• The date of measurement
• The recommended minimum personal protective equipment required.

2. Document procedures for its use, to be displayed near the equipment. For example,

• Close cabinet before turning UV light on.
• Do not routinely work in the cabinet with the UV light on.
• If working with the UV light on, eyes, face and skin must be covered with appropriate UV absorbing material/clothing/equipment.

3. Provide relevant information via group training sessions, which will be detailed in the Biological safety course.

4. Establish a program of interlocking the UV light with the protective cover or fan. OR removal of the UV sterilising tubes and making the light fixture electrically safe.

Enclosed UV sources and UV accompanying other processes

These sources do not lead to exposures above the guidelines, due to appropriate shielding and limited accessibility.

History

These hazard management procedures were prepared by the OHS Unit, reviewed by the Radiation Safety Committee, reviewed by employees and management at the OHS Policy Committee of 3 September 2003, and approved by Mark Clisby, Director, Human Resources on 14 October 2003.