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Module 8: Regulatory Requirements
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MODULE 8: REGULATORY REQUIREMENTS
The possession, storage, use and disposal of radioactive materials is highly regulated at the international, federal, provincial, municipal and local (U of T) levels.
The United Nations established the International Atomic Energy Agency (IAEA) in 1956, with headquarters in Vienna (Austria). An important IAEA activity is to establish rules for international transport, use, and disposal of radioactive materials. However, their publications serve mostly as guidelines for each country. The agency has the power to control enforcement of international treaties banning the use of nuclear technology for military purposes. Their safeguard inspectors also have the right to visit U of T and ask questions about the use, storage, and disposal of strategic radioactive materials.
In 1928, an international committee was formed to recommend radiation protection measures and to propose limits on radiation exposure. In 1950, the committee was reorganized and named the International Commission on Radiological Protection (ICRP). Recommendations from the ICRP are used as the basis for radiation protection programs in countries all over the world.
In Canada, the federal body with regulatory powers on all aspects of radiation safety is the Canadian Nuclear Safety Commission (CNSC). It exercises control over radioactive materials through the tenets of the Nuclear Safety and Control Act and enforces its mandate through licence, report submissions and regular inspections and audits. The CNSC also establishes federal dose equivalent standards for the public and nuclear energy workers all across Canada.
Other federal and provincial agencies are involved in the control of radioactive materials. These include Transport Canada, Health Canada, Environment Canada, Ontario Ministry of Health, and the Ontario Ministry of Labour.
8.2 Licensing and Permits
The main method for controlling the use of radioactive materials employed by the CNSC is the licensing system. The University of Toronto possess a Nuclear Substances and Radiation Devices Licence. This type of licence allows considerable flexibility, which is required in a dynamic research centre such as U of T. It requires the University to maintain a well-managed and documented radiation protection program to ensure that radioactive materials are used safely.
The licence contains information about the federal and provincial acts and regulations for the use of radioactive materials. The Radiation Protection Service maintains copies of the licence. Any company that delivers radioisotopes to U of T must have a copy of this licence.
8.3 University of Toronto Radiation Protection Authority - UTRPA
The University of Toronto Radiation Protection Authority (UTRPA) is a committee composed of academics and administrators who are appointed by the U of T Governing Council. The UTRPA oversees the radiation protection program at U of T. It is the responsibility of the UTRPA to establish policies and procedures to ensure the safe use of radioactive materials in accordance with federal and provincial legislation.
Under the terms of the Nuclear Substances and Radiation Devices Licence, the UTRPA is responsible for authorising qualified individuals to use radioactive materials and has the power to issue internal Radioisotope Permits.
8.3.1 UTRPA Responsibilities and Duties
The UTRPA oversees all aspects of the radiation protection program at the U of T. Their control of the program is complete and all embracing. The UTRPA has all necessary executive power delegated to it by the Governing Council to enforce and maintain the required standards of radiation protection necessary for a complex teaching and research institution.
The responsibility of the UTRPA includes all sources of ionizing and non-ionizing radiation (from both materials and machines) on all properties owned or controlled by U of T.
The UTRPA has the power to enforce and set standards through policies, inspections and disciplinary action, if necessary. It issues, administers, reviews, and amends Radioisotope Permits.
Membership consists of academic personnel (including active permit holders) and administrative staff . It meets regularly to discuss and implement new radiation protection initiatives in the interest of improving the overall radiation safety program.
The UTRPA maintains the radiation safety-training program to ensure that all users of radioactive materials receive appropriate training.
8.3.2 RPS Responsibilities and Duties
The UTRPA executes its mandate through the University of Toronto Radiation Protection Service (RPS). The RPS resides administratively within the Office of Environmental Health and Safety. The function of the RPS is to carry out the daily operation of the radiation safety program, as directed by the UTRPA.
Duties of the Radiation Protection Service include:
8.4 Responsibilities and Duties of Permit Holders and Radioisotope Users
8.4.1 Permit Holders
The Internal Permit Holders are responsible at all times for all aspects of radiation safety in areas under their supervision. They must provide adequate training of persons under their supervision in the proper use, handling, and storage of radioactive materials.
An applicant for a radioisotope permit must be a person experienced in working with radioactive materials. He/she must be faculty member with the U of T, or otherwise acceptable to the UTRPA. Work with radioactive materials must be performed on the University properties or other properties under the control and authority of the U of T. A chart listing the criteria necessary to become a permit holder, along with an application form and other necessary information for obtaining a radioisotope permit has been prepared.
After completing the form, supporting documents establishing previous work experience with radioisotopes should be attached to the form. Both the applicant and Chair of the department under which the work will be performed must sign the form, and the signed form forwarded to the RPS. The Radiation Protection Officer in charge of new radioisotope permit approval and commissioning will visit the applicant and discuss the application. After all additional information (if any) is clarified, the application is sent to the Chair of the UTRPA.
After approval of the permit, purchasing of radioactive materials under that permit will be approved and work with radioactive materials can be begun. At the next UTRPA meeting, all applications for new radioisotope permits will be analysed. If more information is necessary, it will be obtained from the applicant and the permit will be amended, if necessary.
Permit Holders must:
Students, research associates, research assistants, technicians, etc. must:
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